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Journal of the Air & Waste Management Association

ISSN: 1047-3289 (Print) (Online) Journal homepage: http://www.tandfonline.com/loi/uawm18

Industrial Pollution Prevention

David T. Alien , Terry Foecke , Howard Klee Jr. , W. B. Beck , Lawrence L. Ross ,
Arthur H. Purcell , Joel S. Hirschhorn & Harry Freeman

To cite this article: David T. Alien , Terry Foecke , Howard Klee Jr. , W. B. Beck , Lawrence
L. Ross , Arthur H. Purcell , Joel S. Hirschhorn & Harry Freeman (1992) Industrial Pollution
Prevention, Journal of the Air & Waste Management Association, 42:9, 1159-1167, DOI:

To link to this article: https://doi.org/10.1080/10473289.1992.10467061

Published online: 06 Mar 2012.

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Industrial Pollution Prevention

Critical Review Discussion Papers

The 1992 A&WMA Critical Review was authored by Harry Freeman and members of
his staff at the Pollution Prevention Research Branch, Risk Reduction Engineering
Laboratory, U.S. Environmental Protection Agency in Cincinnati, Ohio. Mr. Free-
man presented the paper "Industrial Pollution Prevention," at the Critical Review
session held during the 85th Air & Waste Management Association Annual Meeting
in Kansas City, Missouri. Prepared discussions and invited comments presented
during the session are published here, as well as closing remarks by Mr. Freeman.

Prepared Discussion next generation of improvements will require significant

technological advances in reaction engineering, separation
science, and process synthesis. It will also require the
David T. Alien development of pollution prevention measurement tools so
Department of Chemical Engineering that critical emissions and waste streams can be targeted
University of California for prevention. Each of these elements of a third generation
Los Angeles, California of process pollution prevention is discussed in more detail
below, beginning with the complex issues of pollution
prevention measurement.
I appreciate the privilege and opportunity to comment on
the excellent review of "Industrial Pollution Prevention" Pollution Prevention Measurement
by Harry Freeman and his colleagues. Their review is a
comprehensive examination of a rapidly moving and loosely In their conclusions, Freeman et al., note that "Measur-
defined field. In my comments, I will expand on just a few of (ing) pollution prevention is the biggest P2 (Pollution
the many topics covered in the review. Specifically, I will Prevention) issue currently facing the industrial
address the issues of the technological roadblocks to pollu- community." This contentious measurement issue has
tion prevention in manufacturing processes and educa- come to focus on two points. One of the points of contention
tional needs at the university level. is the definition of pollution. Almost by default, the releases
and off-site transfers reported through the Toxic Release
Technological Roadblocks to Pollution Prevention in Inventory has become the dominant measure of industry's
Manufacturing Processes pollutants. The TRI has assumed this role because multime-
dia releases are reported, individual chemicals are identified
In order to understand the nature of the technical and the data are readily available to the public and to
roadblocks to process pollution prevention, one must under- environmental advocacy groups. The TRI has serious flaws,
stand how pollution prevention is currently practiced. however. It accounts for only a small fraction (much less
Initial efforts at pollution prevention have been aimed at than 1 percent) of the estimated 12 billion tons (wet basis)1
the most easily achieved targets. Good housekeeping prac- of industrial pollutants generated annually. In addition, the
tices, inventory control, and minor changes in operating TRI has, for its first four years, focussed on reporting
practices have resulted in an impressive amount of waste releases and off-site transfers, rather than reporting gener-
reduction. This type of activity is rapidly approaching its ation. Thus, it has been difficult to separate pollution
limit, however, and a second generation of waste reduction prevention activities from increased waste treatment. These
is beginning to be implemented. In this second generation deficiencies make the TRI a far from ideal measurement
of waste reduction, industry uses current technology, most tool for pollution prevention, but, other data sources such
often separation technologies and material substitutions, to as the RCRA biennial survey are also flawed (for a critical
reduce emissions and wastes. Many examples of this second analysis, see Reference 2). Recent additions to the TRI
generation of activity are cited in the Critical Review. reporting requirements, mandated by the Pollution Preven-
Among them are ion exchange for the recovery of metals, tion Act of 1990, may improve the situation, but clearly
ultrasonic cleaning and distillation for solvent recycling. much work needs to be done.
These activities have had substantial impact, but, as was A second point of contention in measuring pollution
the case for good housekeeping practices, there will be prevention is the issue of indexing. Most proposed mea-
limits to the effectiveness of current technology and a third sures of pollution prevention recognize the need to relate
generation of pollution prevention will be required. This the generation of wastes and emissions to the level of
industrial activity. For example, in the new TRI form R,
Copyright 1992—Air & Waste Management Association facilities are to provide a production ratio or activity index.

September 1992 Volume 42, No. 9 1159

This index could be the production level (pounds of prod-
uct), number of employees, sales volume, or some other
measure of activity. The relative merits of some of these
measures has been qualitatively reviewed by Research
Triangle Institute, 3 and it seems clear that no single
activity index will be applicable for all industrial sectors. It
would be irrational, for example, to index the releases of
aircraft manufacturing operations to the mass of the
vehicles they produced and compare that to the releases of
the chemical manufacturing industries, indexed to the
same variable. But, if no single index can be universally
applied, then significant research will be required to estab-
lish norms by industry sector.
William Beck and David Allen
In summary, I agree with the statements in the Critical
Review that call for work on measuring pollution preven-
tion. These statements need to be strengthened and ex- ology and a number of examples are available in the
panded, however, noting that the use of a single, universally literature, and I will not discuss them here. The reason I
applied measurement index is unlikely to be successful and present MEN synthesis here is that it defines a realistic
that significant work needs to be done to identify a set of alternative to zero-discharge as a goal for pollution preven-
appropriate indices. tion. In many cases, zero discharge from a process is
thermodynamically infeasible. Techniques such as MEN
synthesis help to define what goals are feasible.
Process Design for Pollution Prevention
To summarize, the Critical Review promoted zero dis-
The development of quantitative flowsheet analysis tools charge as an achievable goal for many industrial processes.
for pollution prevention is currently in its infancy, but My reaction, typical of many trained in thermodynamics, is
powerful new tools are on the horizon that will permit the that it is often impossible to achieve zero discharge and it
systematic analysis of process flowsheets for pollution can be misleading to target zero as a goal. Instead, process
prevention. To understand the fundamental principles analysis tools that identify thermodynamically feasible
underlying these methods, it is helpful to consider the targets should be employed.
somewhat analogous problem of the design of energy
efficient processes. During the late 1970's and early 1980's, Reaction Engineering and Separation Processes for
design methods were developed for Heat Exchange Net- Pollution Prevention
works (HENs) that would minimize the energy lost by
processes. Simply stated, heat exchange network synthesis Process design and analysis methods can be identify
systematically examines all of the heating and cooling targets of opportunity for pollution prevention. Some of
requirements called for in a flowsheet and then determines these opportunities can be exploited using conventional
the extent to which streams that must have their tempera- technologies; exploiting other opportunities may require
ture raised can be heated by streams that need to be cooled. novel new unit operations. Several forums have been
Although incorporating thermodynamic and equipment convened to review these needs, including the meeting cited
constraints into the problem can be mathematically com- in the Critical Review, held by the American Institute of
plex, the concept of heat exchange networks is beautifully Chemical Engineers' Center for Waste Reduction Technolo-
simple: if a stream must be heated, why not use the energy gies and the Department of Energy's Industrial Technolo-
from streams that must be cooled? gies Program.6 Others include a workshop jointly spon-
Heat Exchange Network synthesis has seen widespread sored by the National Science Foundation, the U.S. EPA
application by industry and has resulted in considerable and the American Institute of Chemical Engineers,7 and
energy savings. Analogous concepts in Mass Exchange the EPA's own pollution prevention research plan.8
Network (MEN) synthesis have been developed by Manou- Taken together, pollution prevention measurement, pro-
siouthakis and coworkers4'5 and have significant potential cess design for pollution prevention and unit operation
for pollution prevention. Simply stated, mass exchange design for pollution prevention represent a hierarchical
network theory determines the extent to which molecules method for performing P2. If measures of pollution preven-
that are potential pollutants can be transferred to streams tion are available, then critical waste and process streams
in which they have a positive value. As an example of the requiring prevention can be identified. The targeted streams
implementation of a MEN, consider refinery wastewaters. and processes can be examined for their pollution preven-
One of the waste components of interest in refinery waste- tion potential using flowsheet analysis tools and, where
waters is phenol. Phenol can be found in the water effluent necessary, new technologies can be developed. The imple-
of catalytic cracking units, desalter wash water and spent mentation of this type of systematic approach to pollution
sweetening waters. In these streams, phenol is a pollutant, prevention has been reported only occasionally, but these
but in other refinery systems phenol can be a valuable few examples, such as the Amoco/EPA Pollution Preven-
additive. The goal of the MEN synthesis is to identify the tion project,9 present a picture of how process pollution
optimal process configuration for transferring phenol be- prevention will be carried out in the decade ahead.
tween the streams in which it is a pollutant into streams in
which it is a product. The Mass Exchange Network (MEN) University Education in Pollution Prevention
synthesis identifies the process configuration that mini-
mizes the amount of phenol that appears as a pollutant. In the previous section, I outlined some of the technologi-
The synthesis incorporates thermodynamic and equipment cal barriers to pollution prevention in three sections:
constraints and helps to determine the maximum extent to pollution prevention measurement, process design methods
which pollution prevention can be achieved for a specified and unit operation design. Do these technological areas
process and a specified pollutant. The details of the method- form a new discipline of pollution prevention? This ques-

1160 J. Air Waste Manage. Assoc.

tion is central to the evolution of the field. Although Mr. ing of pollution prevention must become a part of a broader
Freeman and his colleagues do not directly address this environmental literacy provided to all citizens and, in
question in their review, a consensus on this issue is addition, curricula for pollution prevention experts must be
critically important for the further development of pollu- developed.
tion prevention. Having reached this conclusion, I must disagree with the
Is there a field of Pollution Prevention? Many of the assessment made in the Critical Review that there may be
topics discussed in the Critical Review indicate that pollu- more benefit in focussing on pollution prevention education
tion prevention might become an area of specialization in public policy programs, business schools and design
within some existing disciplines. Life cycle analyses, design programs than on the continued development of engineer-
for environment and the design of clean chemical technolo- ing education in pollution prevention. Both are necessary.
gies are becoming areas of specialization that require a
definitive set of skills and knowledge. To illustrate this Summary
point, consider the design of clean chemical processes.
Chemical process design for pollution prevention is a Harry Freeman and his colleagues have provided a
variation of traditional chemical process design, as prac- comprehensive review of a challenging subject. Their Criti-
ticed for decades by chemical engineers. It requires all of cal Review has given structure to a seemingly amorphous
the traditional skills required of chemical engineers, and field. My comments are intended only to add emphasis in
some additional degree of specialization. The specialist in certain areas, specifically education, the technological barri-
chemical process design for pollution prevention must have ers to pollution prevention, and measurement of pollution
skills in emission estimation methods, in designing unit prevention.
operations for minimum production of waste, in evaluating
flowsheets for pollution prevention, in determining the true References
costs of wastes and in measuring success in pollution 1. Allen, D. T.; Jain, R., Eds., "National Hazardous Waste
prevention. Certainly some of these skills should be taught Databases: generation and fate of hazardous materials in the
to all chemical process designers, but real mastery of the USA," Hazard. Waste Hazard. Mater. 9:1 (1992).
issues will require pollution prevention specialists. Fur- 2. U.S. General Accounting Office, "Hazardous waste: data man-
ther, these experts must be exposed to disciplines not agement problems delay EPA's assessment of minimization
efforts," GAO/RCED-91-131 (1991).
normally studied by engineers, including public health and 3. Research Triangle Institute, "Alternatives for Measuring Haz-
public policy. This type of interdisciplinary education is ardous Waste Reduction," Final Report to Illinois Hazardous
beginning to emerge at some universities, such as UCLA, Waste Research and Information Center, Champaign, IL
but it is in its infancy. It is also important to note that while (1989).
4. El-Halwagi, M. M.; Manousiouthakis, V. "Synthesis of mass
pollution prevention experts will be required, it is likely exchange networks," AIChEJ. 35:1233 (1989).
that several different types of experts will be necessary. An 5. El-Halwagi, M. M.; Manousiouthakis, V. "Automatic Synthe-
expert in Chemical Process Design for Pollution Prevention sis of Mass Exchange Networks," Chem. Engineer. Sci. 45:
might be a chemical engineer who has specialized in 2813 (1990).
6. U.S. Department of Energy, "Report of the CWRT Workshop
pollution prevention while Product Design for Pollution on: Waste Reduction R&D Opportunities in Industry," DOE/
Prevention/Design for Environment might be a specializa- CE/40762T-H4 (1991).
tion within the field of Industrial Design. 7. Jefcoat, I. A.; Overcash, M. "AIChE/EPA/NSF Workshop on
This emphasis on experts does not mean that environmen- Waste Minimization Research Needs," Gulf Coast Hazardous
Substance Research Center Report (1989).
tal literacy, including literacy in pollution prevention, will 8. U.S. Environmental Protection Agency, "Pollution Preven-
not be important. Some measure of environmental literacy tion Research Plan: Report to Congress," (1989).
will be an essential part of the body of knowledge that a well 9. Klee, H. "Final Report: Amoco/EPA Pollution Prevention
educated person must have in the 21st century. Progress in Project," to be available through NTIS (1992).
10. Report of the Academic Focus Group, Pollution Prevention
pollution prevention education must proceed on several Education Committee National Advisory Council on Environ-
fronts, which are described in Reference 10. An understand- mental Policy and Technology, in preparation (1992).

Prepared Discussion is my high expectations for such excellent and experienced

Before going on to the specifics of my discussion, I would
Terry Foecke like to posit two organizing statements. One, I believe that a
WRITAR critical review should not only select, analyze and explicate,
Minneapolis, Minnesota but that it should also cast aspersions where needed and
give praise where deserved, in an attempt to set the agenda
for future efforts in the field of endeavor under examina-
My overall impression of this paper is that it considers the tion. Two, I believe that a critical review should not only
right content areas, in the right order, and offers some solid review the literature that exists, but also assess the quality
insights in its concept summaries, especially in the sections of that body of information in the aggregate, and then point
on Total Cost Assessment, Management and Business, and out where more work is needed. Held up against these
Life Cycle Analysis. In addition, this critical review showed guiding principles of judgment and guidance, this critical
particular intelligence in selecting and analyzing articles on review earns a B—. Therefore, it being easier and more
Toxics Use Reduction, Research Needs, and Development interesting to criticize than to praise, I will focus my
of New Unit Operations. These content areas are breaking comments on those conclusions where I found judgment
new ground rapidly, are very important and/or influential and/or guidance to be particularly lacking.
and deserve the thought given them. My overall grade is a Especially in a field in search of definition and organiza-
B+. The only reason this paper does not earn a better grade tion, such as pollution prevention is, one of the most

September 1992 Volume 42, No. 9 1161


important functions of a critical review is to clarify who is

doing what. This paper reviews 51 papers, nearly 25 percent
of the total cited, in an attempt to reach this clarity. The
paper then builds six of its 21 conclusions around that body
of information. (I found Conclusion #2, which states that
the literature shows that pollution prevention yields "bot-
tom line" savings, to be misplaced, intermingled as it is
with commentary on different sectors and their program-
matic efforts). Of those six conclusions, I have significant
differences of opinion with two. (As in all these comments Terry Foecke and Harry Freeman
on the Review itself, my intent is to show whether or not
the Conclusions are supported by the literature, or whether
or not the literature itself is reflective of experience). assessment document, and, for example, workers in vehicle
Conclusion # 3 states: "While there are those who persua- maintenance knew that substitutes to solvent cleaning
sively point out deficiencies in current federal P2 efforts, it needed to be made, the information in the assessment
is concluded that the federal government is promoting report, which would have given chapter and verse the
pollution prevention." implementation steps to be taken, had never been transmit-
In my opinion, this conclusion suffers in its quality of ted beyond the environmental officer's office.
judgment, perhaps because of the closeness of the authors At DOE, we have worked with the Idaho National
to the subject matter at hand. While an impressive amount Engineering Laboratory in Idaho Falls and found reactions
of activity can be cited and analyzed, little concomitant ranging from confusion to anger on the part of DOE
structural organizational change can be used to support the contractors who are attempting to interpret DOE waste
conclusion. That desire for structural change within organi- reduction guidances they considered to be at the very best
zations is not merely my own. To hoist the authors upon vague (as well as unfunded). An especially egregious exam-
their own petard, I will paraphrase from their discussion of ple of this is the requirement that each contractor complete
education and its effects on the implementation of pollution Process Waste Assessments (which characterize waste
prevention: streams as well as identify pollution prevention opportuni-
"There is a lack of literature detailing any refinement of ties) on a mandated percentage of their waste streams by
environmental values with traditional management values . . . the end of 1992. This arbitrary goal ignores the difficulties
[The values of] future managers would not be sustainable of waste source identification, the lack of a "chargeback"
against institutional disinterest." system for waste management and disposal costs (effective-
ly thwarting options analysis and comparison), and the
There is a similar lack of literature chronicling refinement reality that many DOE programs are in a transition period
of pollution prevention values with traditional environmen- and find it difficult to confront the long horizons of pollu-
tal management values within federal agencies. Program- tion prevention implementation.
matically, federal agencies are more or less healthy as
regards pollution prevention, showing considerable activ- Perhaps the safest thing to say about these examples and
ity. However, there is a grave risk of mistaking activity for this Conclusion is that the Conclusion is at best premature,
progress. Organizationally, the federal government falls and at worst misleading. I also would like to make it clear
short of the mark. I offer as support examples that I find that I understand that major organizational change re-
damning of the efforts of each of the agencies cited in the quires much more time than the five to nine years already
Conclusion: EPA, DOD and DOE. expended, making counterexamples to progress fairly easy
In the EPA Regions, resources are provided to secure and to locate. However, I mean to qualify the Conclusion, not
maintain a Pollution Prevention Coordinator in each Re- attack the organizations cited.
gional office, and sometimes a Pollution Prevention team. Continuing with the theme of who is doing what, the
Yet examination shows that these Coordinators are placed review also examines the literature on state and local
variously in Policy offices, RCRA, Water and several who pollution prevention programs, and makes the following
are simply on "special assignment." This variety of place- statements:
ment, often seen (and condemned as wanting) in industrial "State pollution prevention programs continue to expand and
programs, does not bespeak management commitment or provide ideas for encouraging pollution prevention that the
excellent teamwork. But those are two of the basic priciples federal government should be aware of."
of excellent programs cited by the authors themselves in "Active local pollution prevention programs seem to be the
their section on "Industrial P2 Programs." exception rather than the rule."
At DOD, we have had occasion to work with both the This Conclusion suffers mostly from a lack of guidance on
Marine Corps Logistics Base in Barstow, CA and the the part of the authors, and in my opinion is not supported
Aberdeen Proving Ground in Aberdeen, MD, and found by the literature. The presumption is that state and local
piles of documentation in the form of assessments and programs present (or lack) something of material value. Yet
reports, but little buy-in at the management level or even the authors themselves in Conclusion #18 call for "evalua-
simple understanding at the operations level. To illustrate tions of recently implemented state programs...." It is
the first, we were told of requests going back six years (to precisely this evaluating of information that is absent from
the beginning of the DOD HAZMIN program) for reforma- the literature cited, and that lack of evaluation seems to
tion of the purchasing and inventory systems for laboratory condemn the statement in Conclusion #4:
chemicals because of the extremely high volumes of waste
being generated. Those requests have been reviewed by "The incorporation of such [facility planning] requirements
managers, and never funded, because management saw its into national legislation will have an enormous effect on
job to be facilitating research, not managing (or reducing) reducing generation rates throughout the country."
waste. To illustrate the second, even though a facility was This Conclusion at least potentially repeats the error of
in possession of a detailed pollution prevention opportunity mistaking activity for progress. Even if we set aside the

1162 J. Air Waste Manage. Assoc.

hesitations, pointed out by the authors, in such areas as trial programs. Good guidance on their part, however,
measurement, cost effectiveness, education, incentives and would bring that lack of change to the fore.
barriers, we are still left with the problem of saying exactly Another 23 papers (approximately 12 percent of the total)
what effect or even influence state and local programs have. are cited in an effort to describe assessments, an activity
All we can say with certainty from the literature, in my whose objective is to compile information about processes
opinion, is that state and local programs exist, that they and wastes in an effort to identify and implement appropri-
have ideas, and that they are attempting to implement ate pollution prevention opportunities. Conclusion #16
those ideas. states in part:
On the matter of local programs, the literature clearly "It is an apparent general truism that a company's taking the
lags reality. Although the authors mention an effort to base time to carry out assessments usually identifies opportunities
pollution prevention efforts in publicly owned treatment for reducing wastes and saving money.''
works as evidence of some progress, the facts are that a
number of realizations are urging and facilitating the The literature does indeed support this truism. I would,
creation of ever more and more integrated, local pollution however, look to the authors for some judgment of whether
prevention efforts. One of those realizations is that pollu- this truism is reflective of the actual value of assessments,
tion prevention at the local level has much to do with jobs, as well as some guidance on what the literature lacks.
economic vitality, and the survival of neighborhoods. An- Several specific examples of unanswered questions come to
other is that the original focus of industrial hazardous mind. Are "outsiders" or "insiders" the better assessors?
waste has expanded to include air, energy, transportation, How do you choose? How often does assessment lead to
agriculture and municipal solid waste, all of which may implementation? If assessment is an inventory and analysis
have their own programs or any of which may band of processes and options, how does assessment examine and
together to attack the broader issue of resource steward- plan for barriers to implementation such as resistance to
ship. Local efforts may very well be the next powerful wave change, lack of capital, lack of time, lack of direction?
of innovation and implementation. Pointing out that current assessment procedures and re-
The final conclusion with which I will take issue in the sults are at least unevaluated, if not automatically wanting,
"who is doing what" vein is #7, which states in part: would be more useful than documenting a truism.
Finally, in my opinion, Conclusion #9 has no place in this
"There is no shortage of successful impressive industrial Critical Review. It states in part that:
pollution prevention programs. The literature is full of reports
from primarily large companies on their impressive results." "Achieving zero discharge, at least for hazardous wastes, is
[emphasis added] possible in selected industries."
Guidance and judgment both seem lacking in this Conclu- At the core of pollution prevention lies the concept of the
sion, but my concern is more with the adjectives "successful" prevention of cross-media transfers. Therefore, a focus on
and "impressive." If we cannot measure, if we do not have any one type of discharge or release, such as hazardous
standards, (both of which are difficulties pointed out by the waste, is antithetical to what is being posited in nearly
authors), how can we say that a program is either success- every other section of the review. Given the authors'
ful or impressive? Just as in federal agencies, industrial analysis of Life Cycle Assessment, and more than one
programs have as of yet only rarely achieved structural instance of suggesting that a more global view of environ-
organizational change, if the literature (or lack of same) is mental management is desirable, it is at the least confusing
our source of information. We look in vain for even that this conclusion is included. The literature may very
anecdotal evidence that shows not only that the compo- well support this conclusion; however, it is poorly chosen.
nents are in place, but that the ethic has been integrated To conclude, I found this Critical Review to be an
throughout all functions of a company. For example, if the excellent piece of research. However, I found analysis to be
authors are correct in linking Total Quality Management lacking in two particular regards, which I choose to call
and pollution prevention as sharing principles and ap- judgment and guidance. I took issue with Conclusions
proaches, then the conclusion of that linkage should also be relating primarily to progress and evaluation, and couched
shared: integration of principles accomplished so thor- my disagreement in terms of a desire for more discretion on
oughly that what began as projects and then became a the part of the authors. However, I found myself in
program has now become simply a part of standard opera- agreement with most of the 21 conclusions, and appreciate
tional practice. The authors may tacitly acknowledge this the effort required to compile, digest and comment upon the
lack of organizational change by omitting praise of indus- literature on pollution prevention.

Prepared Discussion both to offer different views on some literature, and provide
"real-world" examples for a rapidly growingfieldwhich has
been largely driven by hypothetical arguments and assump-
Howard Klee, Jr. tions in place of data.
Amoco Corporation,
Chicago, Illinois

Amoco Corporation recently completed a unique, two-

These comments were developed as part of an invited year program in partnership with the United States Envi-
review of "Industrial Pollution Prevention: A Critical ronmental Protection Agency identifying and analyzing
Review," prepared by Harry Freeman of the EPA's Risk pollution prevention opportunities at Amoco's Yorktown,
Reduction Engineering Laboratory, presented at the An- Virginia Refinery.1 This effort involved over 200 people,
nual A&WMA meeting in Kansas City and appearing in the from 30 organizations—more than 40 from EPA and the
May issue of the A&WMA Journal. The comments serve Commonwealth of Virginia alone. The Project considered

September 1992 Volume 42, No. 9 1163


all releases from the Refinery to the air, water, and land.
The Project then identified over 50 potential options which
might reduce these releases.2
A subset of 12-14 options was developed and analyzed in
detail to define quantitative information about each, in
terms of the potential impact of the option on the quantity
of pollutants released, risk and risk reduction potential,
cost, position on the pollution prevention hierarchy, etc.
Based on this information, the options were ranked, both
from our individual organizational perspectives, and jointly,
to select the "best" ones. Finally, the Project identified why
we were not doing the things identified today: What was Howard Klee and Maureen Sullivan
getting in the way?
Needless to say everyone involved learned a great deal
about both the myths and realities of pollution prevention enforceable pollution prevention activities, including not-yet-
at a complex industrial facility. Some of the Review's points defined in-process recycling. Even more unfortunate, these
and my concerns with them are illustrated by a few of the kinds of definition debates divert substantial limited re-
many lessons learned during the 2+ years of experience. sources away from more constructive activities.
During the course of the Yorktown study, our EPA/
Amoco Workgroup analyzed and debated how to classify a
Overview number of options. What really was source reduction? What
was recycling? For example, improved seals on gasoline
As Harry Freeman and his coauthors so aptly noted, the storage tanks were viewed by some members of the Work-
literature on pollution prevention has exploded in the last group as source reduction. The source was the tank, better
several years. The written Review provides an excellent seals reduced emissions, QED: source reduction. Others
literature survey on the topic. The authors are to be viewed the contents of the tank as the source; seals are a
commended for categorizing such a broad range of refer- control technology. Therefore this was treatment, and
ences, particularly given the unusually short time they had perhaps recycling, since the products remained in the tank.
to complete this effort. The Review itself, however, appears Counting all the people around the table during these
to be missing the "critical" element noted in the title on discussions, literally hundreds of person-hours were spent
two fronts. First, several important citations are missing, in these debates. The discussions neither improved the
particularly those with more industrial input. A Review efficiency of the tank seals, nor hastened their installation.
specifically entitled by its authors "Industrial Pollution
Prevention" might be better co-authored with industrial
representatives. Some missing literature citations include: Limited Definition = Limited Results

1. Material published by the American Institute of Chem- For the Yorktown Project, had we focussed on the narrow
ical Engineers' second topical review on Pollution definition of Pollution Prevention as source reduction, we
Prevention held in Pittsburgh last fall.3 would have missed more than 60 percent of the opportuni-
2. The Amoco/EPA Pollution Prevention Project, which ties for environmental improvements. The Project con-
involved so many EPA offices and produced 50 pounds cluded that Pollution Prevention, as narrowly defined, was
(literally) of documentation on a variety of subjects.4 simply not good enough to get the environmental results
3. Material or reference to recent work by the American that responsible corporations, governments and the public
Petroleum Institute, and PERF, the Petroleum Envi- want. On other occasions, the Agency has acknowledged
ronmental Research Foundation.5 what we all know: almost any cost-effective environmental
Second, there is a lack of criticality in the Review itself. No management plan will make use of all parts of the waste
attempt was made to distinguish accurate and objective management hierarchy.
material from unsubstantiated opinion. Political decisions,
personal opinions, and technical matters are given equal Where is Risk?
treatment. This approach may again reflect the relatively
short time given the reviewers to complete such a large A difficulty with the present definition, which emphasizes
assignment. source reduction as the "highest" form of activity, is that it
can set priorities on the wrong things. When the Work-
group ranked options identified at Yorktown solely on the
Comments basis of their standing in the waste management hierarchy,
Other comments and observations are provided below, they identified the five options in column A below as the
organized by the conclusion numbers used by the Review "best" things to do. However, when multiple ranking
authors. criteria were used, which considered the concept of risk and
Definitions. The Review quotes (and I echo) Dr. Larry risk reduction, release reduction, cost, impact on liability,
Ross' sentiments about discussions of definitions: these are etc., as factors in prioritizing what we do, a different set of
not very productive discussions. The joint project with EPA "best" choices emerged. These are shown in column B,
was fortunate enough to have started before the legal below.
profession turned to this topic. The Project Workgroup, A: "Best" Source Reduction Options
composed of EPA, Virginia and Amoco representatives, 1. Secondary seals on gasoline storage tanks
chose what all of us at the time considered a more results- 2. Leak detection and repair program
oriented definition: preventing releases into the environ- 3. Eliminate coker pond
ment. Unfortunately, these definitional discussions con- 4. Reduce soil intrusion into sewer system
tinue. They appear to be driven by a need to define legally 5. Improve sampling systems to reduce oil in sewers

1164 J. Air Waste Manage. Assoc.

B: "Best" Options (all criteria) making. One is the impact of facilities (or changes in
1. Reduce barge loading emissions facilities) on .future corporate liability. Liabilities in this
2. Secondary seals on gasoline storage tanks context include (a) potential future remediation costs as a
3. Reduce emissions from process emergency relief result of spills, (b) potential catastrophic failures, and (c)
(blowdown) stacks. potential liability for changes in product quality. These
4. Leak detection and repair program liabilities are real, as are the ultimate costs for cleanup,
It was interesting that in ranking alternatives identified in lawsuits, etc. However, at this time industry simply doesn't
the Yorktown study, the Workgroup came to agreement on have the factual information and analysis techniques to
what were the four best things to do at this facility. This develop a priori reliable and realistic values for these items,
held true regardless of prior institutional biases and past One point which this Review overlooked was that many
experience. The driving factors that dominated the rank- industrial cost accounting systems fail to assign pollution
ings were risk6 reduction potential, cost, and technical management costs to the parts of a facility that are
features of the options. Outside the traditional regulatory responsible for generating pollution. In many large indus-
framework, given reasonable people and sufficient factual trial facilities, pollution management costs are assigned to a
information, the ranking process gave clear-cut results. central environmental or waste management division, whose
Perhaps we would be better served in these discussions sole responsibility is to operate waste water treatment
by simply remembering that pollution prevention is a works, incinerators, and landfills. By separating the cost for
means, not an end. The end or goal is improved environmen- management from the source of generation, facilities re-
tal quality. move a major reward system and tracking mechanism.
Effectiveness. The Review's second conclusion highlights When the area responsible for generating a waste has no
the economic effectiveness of pollution prevention. I would accountability for the cost of its management, there is little
state this somewhat differently. Pollution prevention op- incentive to reduce generation.
tions can be more cost-effective than other pollution man- Barriers and Incentives. Conclusion 14 discussed regula-
agement choices. However, this does not necessarily make tory barriers and incentives. The authors bemoaned the
them cost competitive with other corporate activities. At continued discussion of barriers. It seems fair to say that
Yorktown, the source reduction opportunities were gener- until the barriers are removed, people will still insist on
ally more cost-effective than treatment and disposal. identifying them and possible solutions. The Review discus-
However, most of the projects had rates-of-return well sion, however, missed several key areas that became appar-
below zero. Instituting a leak detection and repair program ent from the Yorktown Project.
to reduce fugitive leaks of volatile hydrocarbons from small Contrary to the view expressed in this Review, barriers to
flanges, fittings, and pumps was the best option. It had an implementing pollution prevention are real, not simply
estimated 19 percent rate of return. Adding secondary seals industrial intransigence. These include:
to gasoline storage tanks had a 10 percent rate of return.
Everything else was less, usually much less. Industrial Barriers
Viewed another way, several projects captured hydrocar- a. Technical Difficulties in developing new processes.
bons which might otherwise be lost to the atmosphere. If This topic is discussed in much more detail by Profes-
the hydrocarbons captured were valued as gasoline, the sor David Allen, another participant on the Critical
"cost" of this gasoline (including capital, operating and Review Panel. Dr. Allen is a leader in efforts to provide
maintenance) ranged from about $0.65/gallon to over improved understanding by, and training for, the
$415.00/gallon. Given a current refinery "gate" price for engineering and academic communities who must
gasoline of about $0.75/gallon, there was no incentive to teach and develop new viewpoints and processes.
install most of these projects on the basis of product b. Technical difficulties in identifying specific sources of
recovery. specific pollutants at complex facilities. At Yorktown,
It is certainly a popular myth that pollution prevention the Project team spent nearly a year and about
will always pay for itself. While recovering products may $1,000,000 identifying sources. While similar costs
provide more economic value than incinerating them, this are not required for every facility, this is a crucial first
does not necessarily make recovery an economically attrac- step in formulating source reduction plans.
tive activity. c. Limited time, limited technically trained people and
Funding priorities. I agree strongly with Mr. Freeman's limited capital. All of us in government and industry
assessment that most EPA funds are still being devoted to have limited resources available to solve environmen-
control, rather than prevention. EPA budgeting is sending tal and other problems. Early environmental legisla-
mixed signals to industry, Congress and the environmental tion and regulation were successful because the prob-
community. While there is philosophical interest in preven- lems were simple and obvious. Almost any activities
tion, there is apparently little interest in financing research would produce visible, positive results. As our under-
and activities to encourage it. standing improves and we tackle more difficult prob-
Many current and pending regulations send similar lems, the solutions are far less obvious. From permit
messages. The Clean Air Act Amendments require the writers to process developers, we need to find better
installation of Maximum Available Control Technology for ways to prioritize where these resources are spent.
designated sources. RCRA typically relies on Best Available d. Sunk costs. Once treatment facilities are built, they
Control Technology for managing a hazardous waste. The generally have long useful lives—20 to 40 years, for
Benzene NESHAP regulation7 discourages prevention by example. Provided these facilities are performing as
mandating controls even if prevention could eliminate a needed and have adequate capacity, there is no incen-
source's potential to emit benzene. While recognizing that tive to abandon them in favor of spending additional
some of these programs are required by statute, giving EPA resources on prevention!
little flexibility, the command-and-control mindset is diffi- At Yorktown, the waste water treatment plant was
cult to give up. There are many in industry who find working well. Under normal operating conditions, the
command-and-control equally appealing. But pollution pre- discharge to the York River was about one-tenth of
vention does not fit a command-and-control framework. values allowed under it's NPDES permit. Most spe-
Cost. Conclusion 11 provided a disappointingly brief cific chemical tests of the effluent were negative: the
discussion about costs. To say there are hidden costs in materials, if present, were below the detection limits.
environmental accounting was not illuminating. There are The treatment system was not fully loaded, providing
indeed costs that are not yet included in financial decision more than enough capacity for the refinery. Thus, the

September 1992 Volume 42, No. 9 1165

CRITICAL RB/IEW DISCUSSION year. For example, the voluntary 33/50 program
instituted by EPA Administrator Reilly uses 1988 as a
base year for evaluating emission reductions of 17
chemicals. The Clean Air Act Amendments Early
Workgroup had a great deal of trouble devoting re- Reduction Program uses 1987 as a base year. Preven-
sources to preventing material from reaching the tion of Significant Deterioration (PSD) review for air
treatment plant, since it was clear adequate treatment permits starts with emissions present in 1977. Still
would be provided. other programs use different base years.
Regulatory Barriers Reducing emissions before required reduces a com-
a. Short compliance time frames favor "quick-fixes" pany's baseline emissions and makes achieving future
which meet legal deadlines at the expense of more regulatory requirements more difficult and costly,
comprehensive, long-term solutions. Typical statu- because the most cost-effective reductions would have
tory and regulatory compliance deadlines range from already been made. Those companies that have made
90 days to three years. Yet, a well defined large-scale minimal emission reductions are indirectly rewarded
industrial project typical of those in the petroleum because when required to reduce, they can do so more
industry takes 2-3 years to complete, assuming there economically than a "more progressive" company
is agreement on what to build, no equipment delivery that has already made substantial reductions. While
problems, no permitting delays, no unusual safety emissions banking has been discussed for years,9 and
considerations, and no startup problems. Many projects used with success in some programs such as the
take longer, particularly when regulatory and/or de- phaseout of lead from gasoline, no acceptable solution
sign requirements are unclear, or new (undeveloped) has been developed for airborne hydrocarbons, and
technology is involved. many other pollutants.
b. Overly prescriptive statutory and regulatory language.
The Yorktown study found that this Refinery could
achieve equivalent levels of environmental protection References/Endnotes
for 15-25 percent of the cost of current regulatory
requirements. Most current programs mandate (or 1. "Project Workplan," prepared by H. Klee, Jr. (Amoco) and M.
Podar (USEPA), for the Amoco/USEPA Pollution Prevention
imply through Control Technology Guidelines) the Project, Chicago, October 1990.
use of specific technology, rather than establishing a 2. "Pollution Prevention Workshop," prepared by H. Klee, Jr. and
performance standard for an industrial facility. Since SAIC for the Amoco/USEPA Pollution Prevention Project,
all facilities are not equivalent, this "one-size-fits-all" Chicago, 1991.
3. "2nd Topical Conference on Pollution Prevention," sponsored
approach does not allow a facility to develop a solution by the American Institute of Chemical Engineers and the
tailored to the unique process and geophysical charac- Center for Waste Reduction Technology, Pittsburgh, PA, Sep-
teristics of their site. tember 1991. Papers were published by the Center and are
At the present time EPA does not have a policy goal, available through the AIChE national office in New York.
4. "Executive Summary," prepared by H. Klee, Jr. and M. Podar,
and may not have statutory authority to simply set a for the Amoco/USEPA Pollution Prevention Project, Chicago,
release reduction "target" or performance standard, 1992. All documentation for the Amoco/USEPA Pollution
without prescribing how that standard should be Prevention Project is currently available at copying cost from
achieved. Ms. B. Bush at the Health and Environmental Division, Ameri-
can Petroleum Institute in Washington, D.C. EPA will be
c. Inadequate accounting for both the benefits and costs distributing this material through the National Technical Infor-
of environmental regulations is an obstacle to develop- mation Service (NTIS). As of this writing, NTIS numbers have
ing more efficient environmental management prac- not been assigned.
tices. Few EPA accounting systems measure direct 5. Some PERF projects are paid for and undertaken by a specific
set of industrial clients. Results may not be publicly available
benefits of the Agency's activities, such as improved without charge.
ecological health, biodiversity, reduced risk to human 6. For other discussions of risk in environmental decision making
populations, etc. Rather, accomplishments are usually see "Reducing Risk: Setting Priorities and Strategies for Envi-
measured in terms of activities, such as number of ronmental Protection," Science Advisory Board, United States
Environmental Protection Agency, Washington, D.C, 1990.
permits written, amount of fines collected, or number Also, "The Report of the Strategic Subcommittee, Relative Risk
of enforcement action pursued.8 The lack of direct Reduction Project, Reducing Risk, Appendix C," (EPA-SAB-EC-
connection between Agency activities and environmen- 90-021C) United States Environmental Protection Agency,
tal results reduces accountability for program costs Washington, D.C, 1990.
7. "Benzene Waste Operations NESHAP," Federal Register 55:
and benefits. Without adequate measurement sys- 8292, March 7,1990.
tems, it is difficult to tell when environmental manage- 8. "Environmental Protection: Meeting Public Expectations with
ment practices actually improve the environment. Limited Resources," General Accounting Office, (GAO/RCED-
d. No release banking system is available to encourage 91-97), Washington, D.C, June 1991, Chapter 3.
9. Liroff, L. A. Reforming Air Pollution Regulation: the Toil and
early reductions. Many regulatory programs mandate Trouble ofEPA's Bubble, The Conservation Foundation, Wash-
specific emission reductions compared to a "base" ington, D.C, 1986.

1166 J. Air Waste Manage. Assoc.

Prepared Discussion focus, and failure to overhaul the media-specific approach
will severely inhibit industry's pollution prevention efforts
for years to come.
W. B. Beck While it has made serious strides to change this through
Pilko & Associates its pollution prevention office, and with the pollution
Houston, Texas prevention legislation, and its research and development
activities, I think it is still very far from reaching its
potential. The Clean Air Act amendments, and beyond
As a discussant, I would like to comment on several specific these, the upcoming RCRA revisions, will be the acid test of
aspects of this review and offer some alternative perspec- EPA's real commitment to pollution prevention.
tives. This is an effort to present some points in a new light However, there are already some disturbing signs:
and by no means intended to negate what has been Clean Air Act. EPA, in the Clean Air Act, is between a
presented. rock and a hard place. The pressure to get out certain parts
Industrial pollution prevention is probably as old as the of the regulations has not allowed the Agency to really build
industrial revolution itself, if not older. I know from in accommodations and encouragement for pollution preven-
personal experience that it is at least fifty years old. tion, or the support for source reduction via new technol-
However, industry has not always called it pollution preven- ogy. In retrospect, the agency should have tried to convince
tion. To industry, making their processes and operations congress and the many lobby groups that influence con-
more efficient, increasing yields and cost reduction pro- gress that any new environmental legislation must be
grams were a necessary part of staying competitive. Indus- couched to include an all-media approach to whatever
try has not practiced it for the primary purpose of protect- problem the legislation is trying to address. This wasn't
ing human health and the environment. Nevertheless, done and now we have a very narrow media-specific CAA
industry worked to make its processes and factories more amendment package that pays lip service to pollution
efficient and this has indirectly reduced waste. prevention but really does nothing to aggressively support
What society is asking industry to do now is pay more it. In fact, the amendment and the evolving regulations and
attention to the last few percent of waste, particularly to guidance to the states actually create effective barriers to
toxic waste. Certainly that is not too much to request. pollution prevention.
Industry should and must. For example, the initial draft HON for hazardous air
But it must also juggle pollution prevention with a pollutants for the Synthetic Organic Chemical Manufac-
number of other societal demands. Added to this are the tures Industry sector in its 821 pages is basically a prescrip-
ever-increasing economic burdens and what you have is a tion for a 98 percent end-of-the-pipe "control by flare"
floundering industry. Certainly industry should meet its' approach. Yet, innovative approaches involving the use of
responsibilities but it needs help to do so. Help must come end-of-the-pipe scrubbers and condensers to return or
from the society it serves, if it has any hope of getting the recover VOC's, or the Biofiltration technology to destroy
job done and surviving in the global economy. VOCs if not 98 percent effective—and with excellent up
Although industry has been working on reducing wastes, time reliability, probably will not be allowed.
they unfortunately have no reliable measure or chart of More critically, process change that attempts to increase
progress over the past two or three decades with respect to product yield, and that might in turn reduce both air
pollution reduction. Nor do we have an idea of whether this emissions as well as solids, tars, or other residual hazardous
was accomplished through process change or mere end-of- waste and waste waters will probably not be allowed
the-pipe treatment. because they cannot match end-of-the-pipe abatement.
This critical review entitled, Industrial Pollution Preven- From reading this draft I cannot expect industry will be
tion, interestingly is broken down roughly into one third given any time on credit for attempting other process
concerning EPA program descriptions. Ordinarily this would modifications.
be considered as selfserving, but because pollution preven- Technology changes are by this nature highly individual
tion is so inexorably tied into other EPA programs, the and very situation specific. They must be evaluated on such
agency and its policies dominate this activity, and therefore a basis. This requires considerable experience, judgment
where its going and what it will allow in its regulations is and latitude on the part of the permitting agency. More-
critially important. That being said, this review fails to over, if cross media benefits are involved, there is no
really critique the EPA regulatory efforts to encourage guidance on how to judge or value such bandits from a total
industry to practice pollution prevention. environmental pollution prevention stand point. This is far
The second-third describes industrial programs, largely beyond the scope of the CAAA of 1990. Also no allowance
big industry, plants and factories. Leaving one third of the has been made to encourage this kind of thinking. EPA is
article to cover miscellaneous topics such as product stew- missing a golden opportunity to really aid pollution preven-
ardship, Life Cycle Analysis, and Education. tion. The recently issued Part 70, or Title 5, basically a
In reviewing this document there are several areas I guidance to the EPA and state permit writers, doesn't even
would like to focus on for expansion and to offer a fresh mention pollution prevention as an element to look for in
perspective: the new operating permit program.
• The roles of EPA and the federal government in pollu-
tion prevention. EPA's 33/50 Program
• Measurements
• Toxic Use Reduction Program This voluntary industrial initiative has been held up as a
• Education model of what can be done, given the proper encourage-
ment. There is no question that the 33/50 program will
Role of EPA result in reduced pollution—significant reductions. How-
ever, given the tight timetable for these reductions, indus-
The EPA's classic role is to protect the environment— try has relied on end-of-the-pipe abatement or ingredient
and its classic approach has been to control the discharge switching rather than technology development to accom-
and release of pollutants. plish the major part of these. Here again the rush to do
It has been an end-of-the-pipe, command and control something to be counted as a good company and the lack of
approach, and the agency and has done so by focusing on really understanding industry's situation has resulted in a
media-specific strategies. This double problem, the wrong missed opportunity or at best a reduced success.

September 1992 Volume 42, No. 9 1167

Turning Now to RCRA Education

EPA's next big test will be RCRA reauthorization or How do we change our attitudes about pollution, about
whatever form it takes. Again—it is largely a congressional waste, about resources and throw-a-ways? While the review
issue, with a lot of conflicting lobbies that will influence covers many of the programs now in existence, and that are
congress. EPA could take a strong stance on the side of being started up, it does not stress enough how critically
pollution prevention by encouraging recycling/recovery, important the general education of the public is to pollution
process changes, etc., but it will take working closer with prevention. Better still, respect for the environment needs
industry to understand all of the processes and the various to become an integral part of our curriculum, from pre-
options that will provide a win-win situation for all parties. school through college and integrated into all the core

Measurements Pollution prevention has been practiced by industry for

many decades, and for many reasons. While it's generally
It has been said that if source reduction is the heart of been able to remain competitive, these efforts have not been
pollution prevention, then measurement is the key to optimized to protect the environment or, in general, to meet
source reduction. It's very important, and so measurement all of the demands of society, which are themselves chang-
of pollution prevention progress deserves more discussion ing. Overall, industry is probably 95 percent efficient. What
in this review. It is pivotal to the congressional perception is needed now is for industry to push this few remaining
and to societal concerns. Of course both of these are major percent toward zero. This can be accomplished by a number
influences on legislation. of options. Each of these have pluses and minuses:
Instead of focusing on the problems and doubts cast on 1. By Law; no more wastes, and there are some who
the existing data, the review should have cited more believe this is the only way.
positive programs and successes. For example, the TRI, for 2. By Taxes; pricing wastes so high as to force their
all its problems is probably directionally correct in showing reduction. This could only be doiie under some sort of
a strong downward trend. A number of individual compa- international agreement such as the Montreal accords.
nies, trade associations, media and others have accumu- 3. By creating a combination of incentives and circum-
lated data to support this. Perhaps the earliest and longest stances to encourage a higher level of innovation and
effort in this regard is the CMA's annual waste survey. This discovery around process efficiency than exists today.
data base has ten years of consistent data from the chemical And by being patient to accept the reality that such
industry. deep cultural changes will take a generation or two.
As the GAO pointed out in its recent review of EPA's data I subscribe to this last option. Government, society, and
management activities, the agency has yet to develop the industry need to work together to make this concept of
definitions, systems and methodology to cope with the pollution prevention really work. Adversarial approaches
dynamics of industry, products and other activities. Per- have not worked; they delay progress and only favor the
haps the EPA needs to pay closer attention to efforts such lawyers. We must accept one another as partners, each with
as were described by McCartney and Holland in their paper some good ideas and a genuine interest in succeeding.
on Dupont's waste reduction program, covered in the Government needs to rethink its role and relationship
Journal's series on this subject. It's a good system that has with industry in the area of new technology development, in
demonstrated it can work. Polaroid, Northrup, General energy development and options and in general resources
Dynamics and others have comparable systems. There uses. The European and Japanese approach might serve as
needs to be more national consensus around a single system a model. Closer to home, the recent cooperative spirit of the
or at least fewer competing systems that are designed to government and the auto industry to develop electric car
track waste first-—and serve as a tool for enforcement technology could certainly provide some useful ideas. Pollu-
second. The AIChE, Air & Waste Management Association, tion prevention needs to be given its rightful role at the top
and ASME with EPA might form a task force to come up of the hierarchy in regulation development just as it now is
with such a system. in the waste management field. >

Any review—and this one is no exception even allowing

Invited Comments for the generous space allocated—cannot take a field as
wide and controversial as pollution prevention and satisfy
Lawrence L Ross every reader's interests or biases. And so, I would like to
AIChE, Center for Waste Reduction Technologies touch on two important issues alluded to indirectly, which I
New York, New York feel are crucial to pollution prevention needs, identified in
this article. In fairness to the authors, my comments may
well be outside the purview of the article's objectives.
Let me begin by commending the authors for this most However, I believe that it provides a wider perspective to
timely undertaking. For one who has had to keep abreast of the important needs more narrowly addressed.
the fast changing landscape of pollution prevention, this It's one thing to zero in on such obvious "slam dunk"
review represents a much needed distillation and interpre- targets as legislative and regulatory barriers to the imple-
tation of the growing literature of the field. It should mentation of innovative environmental solutions. It's quite
provide an excellent base for future debates and targeted another to dig deeper and get at the underlying causes of
studies. these barriers. The causes—everyone knows them, but

1168 J. Air Waste Manage. Assoc.

rarely addresses them head on—are our nation's adversar- these new processes must not only be cost-effective and
ial mindset, and our difficulty in developing and implement- reliable, but they must also be clean.
ing a long-term technology strategy. Given the elusive Achieving and maintaining a sustainable competitive
nature of causes, effects, and cures for many environmental advantage, therefore, will require the continuous applica-
problems, it is not surprising that we created a combative tion of new and improved technologies to reduce environ-
climate in which it's difficult for industry, government and mental damage fast enough to outpace production in-
the public to talk with each other, much less lay a founda- creases. This is at the heart of a long-term competitive
tion for mutually beneficial regulations and innovative strategy. To realize this goal will require a major transfor-
technologies. Given our failure in overcoming these barri- mation, with:
ers during previous periods of intense public concern over • Environmental factors being incorporated into design at
treatment and disposal, and cleanup and remediation, why the earliest stage
would we expect a different attitude now that concerns have • Environmentally compatible design becoming a perma-
turned to clean production and manufacturing? And, why— nent feature of industrial practice
beyond our often-mentioned love of litigation—does this • The next and future generations of scientists and engi-
dilemma seem to be a peculiarly American one? neers being' 'pollution prevention professionals.''
Some answers to these questions can be gleaned from A key to achieving these long-term goals is cooperation
recently published analyses of U.S. competitiveness. Of between industry and government. Although there are
many such partnerships in place or under development—
these, I believe Lester Thurow's publication Head to Head the AIChE's Center for Waste Reduction Technologies
is singularly on the mark in confronting the hard choices being one—their ultimate success will be dictated not so
that will need to be made. Although his main thesis does not much by the quality of the individual players but by the
specifically address environmental competitiveness, many commitment of their stakeholders to a change in the
of the compelling arguments, I believe, can be directly industrial culture of revolutionary proportions.
transferred to this setting—^which is what I propose to do. This commitment is not for the faint-hearted. It will be
Thurow states, "In the twenty-first century, sustainable costly, and require high investment and sacrifice. And it
competitive advantage will come much more out of new will only be achieved by a radical transformation in U.S.
process technology and much less out of new product industrial policy away from short-term profit maximization
technologies (i.e., inventing new products). Reverse engi- to one based on long-term market expansion (or what
neering has become an art form. New products can be easily Thurow calls "strategic conquest"). To quote Thurow,
reproduced. What used to be primary (inventing new America will "have to shift from being a high-consumption,
products) becomes secondary, and what used to be second- low-investment society in the 1980s to being a high-
ary (inventing and perfecting new processes) becomes investment, lower-consumption society in the 1990s. From
primary." Given increasingly demanding standards of being present-oriented, it will have to become future-
environmental improvement, there is a recognition that oriented." .

Invited Comments examples. Conventional wisdom dictates that P2 and en-

ergy conservation go hand in hand. Yet this is not necessar-
ily the case. Cutting back energy use in buildings, e.g.,
Arthur H. Purcell without redesign of ventilation systems, will lead to signifi-
Preventive Environmental Management Services cant decreases in indoor environmental quality. Making a
Resource Policy Institute more durable product may mean less pollution in the longer
Los Angeles, California term but more in the shorter term. P2 programs entailing
synergistic research, however, are few. And until we better
understand synergies, we will have to put qualifiers on
Freeman and colleagues have put together a useful snap- claims for overall success of P2 programs.
shot of a rapidly changing picture. I am reminded of the Education and training represent particularly fast mov-
characterization made by a colonel I met many summers ing P2 trains. Five years ago the head of what has become a
ago, when serving as an intern with the old Army Environ- recognized higher education center for P2 research confided
mental Office. He likened keeping up with environmental that "waste minimization has no place in a university
regulations and trends to "painting a moving train." The curriculum." Just as this individual has had a change of
authors have done a credible job of train painting; it is, heart about the academic acceptability of a subject as
however, important, to bear in mind that the field of interdisciplinary as P2, the education establishment as a
pollution prevention (P2)—or waste minimization or clean whole—K-12, undergraduate, graduate, and post-doctoral—
technology or whatever it may be called—is evolving, and has begun serious rethinking of traditional education pro-
growing, daily. grams related to environmental training and management.
As this change occurs, it is becoming increasingly clear The authors note that, at the university level, P2 "tends to
that P2 programs must be developed in the larger context of be taught as a specialized (course)," is "rare in the social
overall resource stewardship objectives. The authors cor- sciences and liberal arts," and "most pollution prevention
rectly note in this regard the importance of improved curriculum development is being done by individuals or
understanding of Lifecycle Analysis (LCA) as a means of small groups, in isolation. . ." This situation must clearly
gaging the long-term implications of P2 activities. This is be improved if P2 programs of the future are to be
one important component of the overall need for programs developed and run by adequately trained personnel.
which assess the synergies between pollution prevention Just as the P2 train finds itself moving rapidly through
activities and other environmental and resource efforts. our educational system, it is causing much activity at the
Synergies between P2 and energy use are illustrative public policy level. As the authors indicate, laws on a

September 1992 Volume 42, No. 9 1169

number of government levels, in the U.S. and abroad, are The P2 train is moving rapidly toward the household
aimed at promoting P2. When the Resource Conservation level, as is evident from the surge in efforts to control and
and Recovery Act was signed into law in the U.S. a decade reduce household hazardous wastes. Management of these
and a half ago, some very strong P2 language was inserted. wastes has, in fact, become one of the biggest environmen-
Section 8002 charged the mandated Resource Conservation tal management growth areas. It is essential to emphasize,
Committee with conducting "a full and complete investiga- in any analysis of P2 programs, that the degree of control
tion and study of... the appropriateness and feasibility of
restricting manufacture or use of categories of consumer exercised over hazardous components of household waste—
products as a resource conservation strategy." While no one the very visible tip of the iceberg of resource consumptio-
wanted to touch that provision at the time of enactment, it n—is strongly indicative of the overall success of industrial
is instructive to note that in the future the study, at least, of P2 programs. Reduction and elimination at the production
this kind of P2 strategy, will likely be part of most P2 level must translate directly into reduction and elimination
program formulation. at the household level.

Invited Comments Equally disturbing is the review's lack of recognition of

the full scope of innovative industrial activities. The review
did not get to industrial programs until the fifth section,
Joel S. Hirschhorn and then only for three pages. A good example of the
Hirschhorn & Associates, Inc. review's undercoverage pertains to the enormously impor-
Lanham, Maryland tant issue of measurement of waste reduction progress with
comprehensive data. The one American company that
showed incredible initiative is Polaroid; it created the first
The critical review on industrial pollution prevention may truly comprehensive corporate measurement system and
seriously mislead and misinform many people. Sadly, the yet the review has no citation to any of the publications by
EPA authors seemed intent on portraying EPA and the Harry Fatkin and his colleagues.
Bush Administration as being leaders in pollution preven- Another example of pollution prevention related indus-
tion. This is simply incorrect, especially if one pays atten- trial innovation is the Warner-Lambert Company's major
tion to the behavior of the Office of Management and investment in agriculturally derived, biodegradable materi-
Budget and the Vice President's Council on Competitive- als which offer environmental lifecycle advantages com-
ness. All of the authors, of course, are from EPA's Office of pared to plastics and paper. In fact, several other companies
Research and Development which is somewhat remote are also leading a major materials revolution. The review
from the main policy and program offices. Still, the evident provided little attention to the application of pollution
hubris of the authors is disturbing. prevention to municipal solid waste issues.
Here is some correct history. The first significant U.S. Nor did the review give adequate credit to the many
government action to use a preventive strategy was in the states (including Massachusetts, North Carolina, Minne-
1984 Hazardous and Solid Waste Amendments, and this sota, and Illinois) that forced early attention to industrial
resulted from Senate reaction to the 1983 Congressional waste reduction, while EPA did nothing. These and other
Office of Technology Assessment report "Technologies and states pioneered with conferences and awards for industry,
Management Strategies for Hazardous Waste Control" and then passed state laws for planning and reporting. In
which stressed industrial waste reduction over waste treat- regard to the latter, however, the review missed a major
ment and disposal. Other efforts, including OTA's 1986 opportunity to address a most serious issue confronting
report "Serious Reduction of Hazardous Waste" and the American industry.
pioneering work of people receiving no credit in the review State and federal reporting and planning requirements
(including Roger Schecter, Don Huisingh, and David Roe) have become so burdensome and costly that they are now
resulted in several pieces of pollution prevention legislation diverting resources from actually carrying out pollution
in Congress which ultimately resulted in the Pollution prevention projects. Planning and reporting has become a
Prevention Act of 1990. punishment for all industry, as if no one in industry can and
EPA opposed the legislation, and for several years prior will do the right thing. Nor has EPA effectively addressed
to passage Congress forced money on EPA for pollution the technical difficulties that many companies encounter in
prevention activities. No accurate account of events in the relating waste generation (or chemical usage) to production
1980s would conclude that EPA showed leadership or data, which is nearly always required.
initiative in pollution prevention. Even its much publicized A most interesting omission by the review is the lack of
33/50 program does not actually require pollution preven- reference to papers by this author which presented a useful
tion actions, although it is an excellent program. What is framework for understanding the non-linear character of
sorely needed is a clear national environmental strategy industrial pollution prevention. The four stage framework
based on pollution prevention, such as the Dutch govern- aids understanding of the increasingly complex and stub-
ment has done, and explicit ways to provide industry with born obstacles facing industrial waste reduction. The re-
greater flexibility in spending limited resources on preven- view also missed an opportunity to present an overall
tion rather than traditional end-of-pipe compliance. framework (which this author has published) for under-
As to the discussion of different terms and definitions, standing the full range of pollution prevention activities,
readers are strongly advised to read a May 1992 EPA from toxics use reduction and resource conservation for
directive by Deputy Administrator Habicht which finally inputs, through source and waste reduction within sys-
removes much of the confusion created by various EPA tems, to redesigning, reformulating, and repackaging prod-
statements, and brings EPA into compliance with the uct outputs. Oddly, discussions on clean technologies,
Pollution Prevention Act of 1990. toxics use reduction, and product design seem to have a

1170 J. Air Waste Manage. Assoc.

random distribution within the review. Nor did the review of the relationship between pollution prevention and Total
adequately demonstrate the applicability of pollution preven- Quality Management programs in industry. Nor does it give
tion principles to the full scope of local and global environ- credit to the U.S. Agency for International Development
mental problems. which has begun to give very serious attention to bringing
The discussion of economic analysis missed the major pollution prevention to developing countries. Moreover,
point that it is nearly impossible to find companies that there is a major opportunity for American industries to
have established systems which explicitly account for a host export pollution prevention technologies, products, and
of more indirect economic benefits (e.g., reduced long term services. The review's description of DOE's pollution preven-
liabilities, improved valuation of common stock, improved tion activities as "model" is further evidence of the au-
retention and recruitment of professionals, improved cus- thors' governmental isolation.
tomer relations, etc). In fact, industrial pollution preven- To sum up, a critical pollution prevention review by
tion has already reached a level of stagnation (now that all people actually practicing pollution prevention in industry,
the sludge dewatering and simple housekeeping actions both consultants and industry workers, would have been
have been taken), because capital intensive projects are not very different and more accurate. As to scholarship, while
being fully implemented in our present depressed economy. 25 percent of the review's citations are EPA works, a large
Inadequate economic analysis is a major explanation. number of significant pollution prevention publications
Interestingly, the review offers no significant discussion were not cited. Readers beware.

Closing Remarks
Harry Freeman
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
Cincinnati, Ohio

My colleagues and I appreciated A&WMA's inviting us to

prepare the review article on industrial pollution preven-
tion, and we are continuing to enjoy hearing from those
around the country to whom we sent copies of the article.
The comments contained in this issue of the journal were
prepared by individuals invited by the Critical Review
Committee to review the article. We would like to thank Ronald Berglund and Harry Freeman
those individuals, with one notable exception, for taking the
time to review our article and for preparing their com-
ments. It is through such a process that we all advance our issue we may be confusing activity for progress. This could
understanding of the topic in question. Some responses to be, but we would suggest that before making such a
the points raised by our reviewers follow. statement that Foecke be clearer on the baseline to which
Allen effectively highlights the fact that after all or most he is referring. More could always be done regardless of the
of the P2 benefits of modifying operating practices and issue, and P2 is no exception. However, from where we sit
modifying current processes have been obtained there will and from the literature we reviewed, we stand by our
be a need for a third generation of pollution prevention conclusion, especially as it compares to federal government
activities of just five years ago. Foecke's disagreement with
technologies to be developed. We certainly agree with this our statement that state P2 programs continue to expand
statement and would favor the providing of support for and provide ideas for encouraging P2 appears to be based
programs that will contribute to reducing the technological upon his belief that some sort of formal evaluation of the
roadblocks that inhibit the development of the newer state programs needs to be carried out before such a
processes. We found Allen's comments about the P2 mea- statement can be made. We believe that although there may
surements question very useful in focusing the importance very well be a need for such an undertaking, there is
of the question. His well spoken support of the concept of sufficient evidence to support our rather mild conclusion.
developing a pollution prevention specialist similar to an Foecke states, "On the matter of local programs, the
industrial safety specialist is somewhat of a minority literature clearly lags reality." This may very well be true,
opinion in the discussion of how do we best incorporate P2 but this was a literature review, not a reality review.
into the industrial scene. While we are not in complete Near the end of his review Foecke states that in his
agreement with this position, we are sure that we could opinion our conclusion, "Achieving zero discharge, at least
agree with Dr. Allen on most of the points about the for hazardous wastes, is possible in selected industries,"
importance of P2 education. has no place in the Critical Review. We would disagree.
Even though Foecke and Klee were somewhat critical in Eliminating a waste stream is certainly within the spirit of
their comments, it is hard for us to take much umbrage pollution prevention and more often than not, according to
over their comments since we were flattered that they the literature, such an accomplishment is based primarily
would take the time to read our paper in such detail to on the incorporation of P2 strategies rather than the cross
develop such detailed observations. Some comments about media transfer of pollutants. Our not commending such
those observations follow. Foecke questions our conclusion accomplishments because they do not conform to a purist
that the federal government is promoting pollution preven- definition of pollution prevention seems counterproductive.
tion and suggests that maybe because we are too close to the We appreciate Foecke's final comment. If such a well

September 1992 Volume 42, No. 9 1171

recognized and credible player in the P2 game as Terry Beck suggested that we should have focused more on the
Foecke agrees with most of our conclusions, we must have positive P2 measurement programs and successes rather
done something right. than kicking the usefulness of TRI data around so much.
Klee notes that we missed some relevant pieces of We would have liked to do this, but did not find a lot in the
literature. His point is well taken, certainly in the case of literature about these successes. Something we learned
the AMOCO/EPA P2 Project. We agree that this is a from this experience is to expand some of our current P2
significant omission, and had we to do it over, we would measurement research projects at the laboratory to include
highlight this study. As we said in the review, there is a lot documentation of successful measurement projects. Any
out there and a lot of people are doing a lot of things. We assistance that readers of the Journal might be able to
regret that a few slipped through the crack. Klee also notes provide by alerting us to relevant literature is appreciated.
that we tended to give political decisions, personal opinions, He also pointed out that we did riot stress enough how
and technical matters equal treatment. This certainly was critically important is the education of the general public to
not our intention. However, we would say that given the prevent pollution. So to be responsive to his comment and
peculiar nature of the P2 beast, there is a huge overlap to demonstrate our complete agreement with his position,
between the aforementioned items. let us here repeat Beck's statement; "Better still, respect
After reading through Klee's very thorough and percep- for the environment needs to become an integral part of our
tive observations and comments on the paper, our first curriculum, from pre-school through college and integrated
conclusion is that we clearly erred in not inviting him to be into all the core courses."
a coauthor. We recommend his review to the reader for it Finally, Beck believes that we as a nation would be better
adds a lot to the whole question of where pollution preven- served by a government/industry approach based on the
tion is going. His discussion of barriers and incentives is European or Japanese model for encouraging the adoption
especially insightful. of pollution. Endorsing such a broad proposal is rather
Klee notes that we did not include under the "Cost" outside the scope of our critical review project. However, we
conclusion that an effective P2 strategy is to allocate the believe that reflecting on the possibilities of such an organi-
costs of pollution creation and management to the actual zational model is a useful undertaking for those interested
unit that generates the pollution. We appreciate his point- in dissolving barriers to increased pollution prevention.
ing this out. We have found in various studies supported by The observations of Ross about our nation's adversarial
the Agency that such an allocation of costs may very well be mindset and our difficulty in developing a long term
the most effective approach to encouraging industrial pollu- technology strategy, and the observations of Purcell about
tion prevention. the difficulty of painting a moving train are useful in
Klee's comment, "Perhaps we would be better served in focusing the discussions about how to dissolve barriers to
these discussions by simply remembering that pollution the implementation of P2 strategies. Both of these comment-
prevention is a means, not an end. The end goal is improved ers provide useful perspectives on pollution prevention in
environmental quality," is something we all too often the U.S.
forget. And then we come to Hirschhorn, whose otherwise
Beck, as usual, offered perceptive comments reflecting his possibly useful comments get lost in his continuing criti-
long experience as an active participant in developing real cism of the U.S. EPA and anyone else who might disagree
world pollution prevention strategies at DuPont. His high- with him, or who might not pay homage to his articles as
lighting the fact that there are some disturbing signs the seminal works on pollution prevention that he obvi-
related to the EPA's implementation of the Clean Air Act ously believes them to be. Such politically-based statements
Amendments is a useful reality check to those who believe as those penned by Hirschhorn are inappropriate.
that the federal government is indeed 100 percent behind In closing, we would say that the process of preparing the
pollution prevention as the best environmental protection critical review has certainly been an enjoyable and worth-
strategy. His also pointing out that the EPA's 33/50 while undertaking for us. We realized a real sense of
Program is not completely a pollution prevention initiative, accomplishment in completing the work within the time
and that industry will receive credit for end-of-the-pipe allotted, and we enjoyed very much working with the
control strategies is also useful to those of us who occasion- A&WMA editorial staff who did an outstanding job. We
ally tend to overlook this point. hope the Journal readers found our work useful.

Critical Review Subcommittee to Expand

The A&WMA Publications Committee invites nominations for the Critical
Review Subcommittee. This Subcommittee selects the topic for each Annual
Meeting Critical Review, selects the critical reviewers and commenters, provides
peer review for the manuscript, and conducts the Critical Review Session. The
committee meets each year at the Annual Meeting. Please send nominee's name
with a brief resume to the Chairman of the Publications Committee:
Dr. William Pierson
Desert Research Institute
P.O. Box 60220
Reno, NV 89506

1172 J. Air Waste Manage. Assoc.