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 Large reductions ince ~he pollution prevention concept
:.-
%2,$”. emerged man:: years ago, environmental pol-
$+
i~ ~ox;c vvasfes ~~;. icv makers have expressed widespread in-
,.< ?>: te;est in using pollution prevention tech-
and emissions b?,..>., niques to improve emironmental conditions
at factories operating across the country. I\Ttereas pol-
~~s achievable at lution control technologies are applied at the “end of
the pipe”, pollution prevention seeks opportunities to
many if not rmst minimize reliance on [oxic chemicals, increase effi-
ciency, and decrease waste and emissions rhrough pro-
ccmpawy sites. cess changes. Unlike polhttion control, pollution pre-
vention often saves money, making the approach a
potential “win-win” for industry and en~ironmental-
ists. Many environmental experts have believed that be-
cause pollution prevention techniques save money they
would be adopted voluntarily bv industry without the
LIN D.-\ E. GREER
need for explicit go~rernrnen[ regulation or intense pres-
sure by environmentalists.
For reasons that remain somewhat elusive, the pol-
lution prevention approach has failed to grab the at-
tention of the business world. ,’Nthough initially some

254 A s JUNE !, 20G0 ! ENvlaoNhlENTAL SCIENCE & TEcHNOLOGY I NEVJS G 2000 Amencm Cnem)cal Sociely

blamed regulations for impeding pollution preven-
tion (believing regulations might be inadvertently
posing barriers to various corporate initiatives), few
or no case studies have proved this theory to be cor-
rect. Currently a more tvicfely held theo~; holds that
good opportunities to prevent pollution and save
money must “bevery rare; if sLIch opportuni~ies re-
ally existed, they would have already been seized by
business.
A second daborative attempt
In the fall of 1996, the Natural Resources Defense
Council (>;RDC), the Dow Chemical Company, and
a group of communir; activists initiated a project
at Do\v’s kIidland, MI, chemical manufacturing fa-
cili~ to achieve aggressive reductions in to,xic ~vastes
and emissions at the plant using only pollution pre-
~;ention techniques. only projects that met busi-
ness criteria for capital investment Lvould be pur-
sued [o achieve these reductions. This project
foiiowed up on a more iimited collaborative pol\u-
;
!Iy
Dow Chem!cal Company
tion prevention project at Dow’s LaPorte, TX, plant
that had identified some profitable reduction op-
portunities but had not implemented them (1).
Dow’s Midland site is home to 8 of Do[v’s 15 gio-
bal business lines (see photo above). It occupies 1900
acres, employs 4200 people, and manufactures more
than 500 products, including pharmaceuticals, plas-
tics, and pesticides. .-\t the start of the project, Dow’s
Midlanci ~acility was Michigan’s eighth-largest emit-
ter of Toxics Release Inventory (TRI) releases and
the simh-iarges~ generator of TN wastes. Its total TR1
emissions had been approximately level for the prior
five years, and its TRI wastes (except HC1) had risen
slightly. Do~v–Midland was a particularly signifi-
cant source of numerous chemicals of concern to
the environmental communi[y, as >[ichigan’s top-
ranked emitter of acrylonitrile, formaldehyde, bu -
tatiiene, dichloropnenol, tetrachloroethy lene, vi-
nyl chloride, and other priority toxic compounds.
It \vas a nationally significant source of many pol-
lutants as well, contributing: more than 10% of the
JUNE 1, 2000 I ENvIRONMENTAL SC! EJNCE & TECHNOLOGY/FJE)/S, 255 A

.
..
Manufacturing of chloroacetylchloride
Process Description and Sources:
Chloroacetylchloride {CAC]is used
primarily as an-intermediate in the
manufacture of monochloroacetic
acid (MCAA).Most of the MCAA at
Dow-Midland is sold. However,
some is used as an intermediate to
manufacture the pesticide 2,4-di-
chlorophenoxy acetic acid, more
commonly known as 2,4-D.
Vinylidene chloride and oxygen
are the primary raw materials used
to produce CAC (see Figure 1). The
oxidation reaction is highly exother-
mic, generating significant heat
Currently, the reactor is cooled with
water from a cooling tower system.
The source of all wastes in CAC
is the formation of byproducts in
the reactor. These wastes exit the
process “at two prima~ sources:
vent gases from the reactors and
overhead tars from distillation.
Wastes from these two sources
account for about 18% of all
wastes addressed in this project.
Source
(luantity,”pounds “”.
Lost raw material sa~ngs/year’ “ “’
Waste treatment savings/year
Project cost
25e A Z JUNE 1, 2000/ ENVIRONMENTAL
SCIENCE& TECHNOLOGY/NEWS
—
siol
sib!
sio:
Pollution Prevention Options and Financial Savings/Costs: Savings
by
Reductims: Several pollution pre- from the avoided cost of lost raw
for
vention options were explored, in- materials and waste treatment from
cluding improved cooling, distilla- CAC was estimated to be S375,000
tie’
tion column optimization, and in- per year. ity
process recycling. The pollution Costs derived largely from the tio
prevention option of choice fo- purchase of new refrigeration ag?
cused on the fundamentals of the equipment. New equipment was tio
chemical reaction to improve the estimated to cost $500,000. In addi- Wa
overall efficiency through improved tion, .S!0,000 was requested to en- in:
cooling. All the wastes from the able technical staff to conduct H(
process are generated as byproti- more detailed technical analysis for in,
ucts through inefficiencies in the the project ce
reaction. Lower reaction tempera- In an effort to improve the eco- w’<
ture would decrease the formation nomics of the project, Dow CAC ga
of these unintended byproducts staff contacted brokers of used
and increase yield of CAC product refrigeration equipment. A suitable p;.
Dow determined that additional refrigeration unit was identified, dt
cooling could be provided through which greatly improved the eco- th
refrigeration instead of the existing nomics of the project. CAC staff kc
cooling towers. Improved refrigera- then contacted the business lead- ti(
tion was estimated to reduce the ers who make funding decisions to C(
generation of byproduct wastes by discuss tha new information. Fund- Al
approximately 1.8 million lb, 1.3 mil- ing was approved in less than one tl
lion of which were priorii chemi- week. Equipment will he fully oper- 01
cals for this project (see Table 3). ational bv fall 2000.
nation’s loading of 2,4-D (see sidebar above), di-
chlorophenol, ~richlorophenol, vinylidene chlo-
ride, and tetrachloroethane.
The specific goals of the 30-month collabora-
tion were
● to reduce waste and emissions of 26 priority
chemicals generated at Dow–lMidland by 359’o
using only pollution prevention techniques (see
Tabie 1);
s to foster institutional changes throughout Dow
that would further shift the corporation’s think-
ing from regulatory compliance to pollution pre-
vention and further integrate health and envi-
ronmental concerns into core business planning
and decision making;
● to develop and rely upon a participatory pro-
cess that leads to changes in business decision
making throughout Dow and that provides an
opportuniw for the citizen participants to gain
an understanding of the company’s business de-
cision-making process; and
● to monitor waste reduction and pollution pre-
vention accomplishments and provide account-
ability of the project results to the general
public.
1
Reaction
$ 1;800,000 Project design
‘ $225,000 The project was designed in large part on the basis
~~$250,000 of successes and limitations of the pilot project done
$300,000 at Dow’s LaPorte, TX, facility. TRI data were used at
the onset to set priorities for target chemicals. Dow
provided process-level data for the wastes and emis-
 *
sions of interest. Those business divisions respon-
.
sible for the largest portions of the wastes and emis-
sions of concern to the project were then approached
‘~
by Dow environmental health and stiey (EH&S) staff
for participation in the work.
1 The group relied on an expert pollution preven-
tion assessor, Bilf Bilkotich, of Environmental Qual-
ity Consultants, in Tallahassee, FL, to find reduc-
tion opportunities. After signing confidentiality
agreements, Bilkovich generatedideas for reduc-
tion opportunities by minutely inspecting data on
wastes and emissions at the plant and then meet-
ing with Dow experts to brainstorm opportunities.
He located, mobilized, and requested from Dow the
information needed to support the envisioned pro-
cess changes. Bilkovich also found the persons who
would champion change within the business and
gathered the team needed for implementation.
Workin: with Bilkovich, Steve Anderson, princi-
pal with Kerr, Greiner, Anderson, and April, in Bor-
dentown, NJ, developed a detailed framework to mack
the project, creating templates for each business and
keeping overall tallies of progress toward the reduc-
tion goals that allowed full transparency and ac-
countability of the project to the general public.
Anderson, NRDC, and the activists did not sign con-
fidentiality agreements and relied instead upon Bilk-
ovich and Dow to explain relevant details about how
wastes and emissions were generated in a way that
did not reveal business-sensitive information about
manufacturing processes.
NRDC and the other environmental activists ne-
ii- gotiated p reject priorities, quantitative goals, and
o- deadlines with Dow staff members, who subse-
quently reviewed and commented on reduction op-
a- portunities during the life of the project. The activ-
ists created and sustained a dynamic tension for
ty progress, innovative risk taking, and aggressive re-
% ductions throughout the project. The group relied on
?e a professional facilitator, John Ehrmann of the IMe-
ridian Institute, in Dillon, CO, to create ground rules
Lv for participation and to keep both sides working pro-
<- ductively together during the ups and downs of the
~- project.
~- Several key features of the design of the project
‘g were based on lessons learned in the first attempt
at this project in LaPorte. The design was based on
)- the hypothesis that projects were most likely to be
3 implemented if the business peopie ultimately re-
a sponsible for capital investment decisions in the
,1 business divisions interacted directly with the
.. project. Although most understanding of the ben-
efits of the project, EH&S staff members were not
in a position to ultimately approve business invest-
ment decisions. Furthermore, the design was based
:1 on the hypothesis that deadlines and quantitative
reduction targets, combined with a transparent and
accountable tracking system, would construc-
tively serve to keep the group focused on achiev-
> ing reductions in a timely way. Finally, parties agreed
> that success lay not only in the technical opportu-
t nities for reductions that would be identified but also
,,,
in effective advocacy for these projects from out-
siders, as well as internal Dow advocates for change.
The group met at least quarterly throughout the
project. Representatives from each business divi-
sion came directfy before the group, first to intro-
duce themselves and learn about the project, and
subsequently to present information on their pro-
cesses and the ways in which their wastes and emis-
sions were generated. Business divisions then peri-
odically came before the group to describe progress
in developing options and to hear
gro”up opinions and preferences. PoIlution
Conference calls were held fre-
quently between meetings to keep prevention
all participants abreast of spe-
cific problems or issues. Tracking projects are
sheets were reviewed regularly to
ensure progress. often viewed by
a business as
Dramatic reductions achieved
Emissions were reduced by 43%, elegant solutions
from 1 million to 593,ooO lb, and
wastes by 37%, horn 17.5 million to to a problem
11 million lb. The reductions ex-
ceeded the project reduction goals they do not
of 35Y0.Akhouu@ a few chemicals,
such as acrylonitrile and dichloro- think they have.
phenol, were not affected, the vast
majority (20 of 26) were reduced. Some chemical
wastes and releases, such as formaldehyde, were
nearly completely eliminated, and five chemicafs—
chloroethane, chloromethane, methylene chloride,
tetrachloroethylene (waste product), and toluene (air
releases) —were reduced by more than half.
A total of 17 projects delivered these reductions
(see Table 2). All of them were directly related to in-
creasing production yield, capacity, or quality im-
provements. For example, one project required only
improved cooling to reduce nearly 2 million lb of
waste. Another reve’afed that transferring a chemi-
cal twice a day to storage tanks instead of only once
a day would eliminate vapors that were being vented
to an incinerator. Reducing a residual solvent in a raw
material in one process both greatly reduced a waste
tar and facilitated recovery of other chemicals in the
remaining tar. Reordering production schedules to
concentrate impurities in yet another wastestream
greatly enhanced recovery of the waste. In all projects
relying on process modifications were responsible for
the largest proportion of the reductions achieved, fol-
lowed by those relying on in-process recycling.
The project achieved these reductions with a to-
tal capital investment of $3.1 million (see Table 2).
Do~v estimates the project will save the company
$5.4 rniUion annuafly through raw materials costs sav-
ings and reduced waste treatment costs alone, for an
overalf annuaf rate of return of 180’?ZO.
The savings fig-
ure does not include some other clear financial ben-
efits, such as increased capacity and lower produc-
tion costs on sales that result from process
modifications to reduce waste. All but one of the
projects easily met business hurdle rates (the amount
of profitability required to be achieved by a project
for a business to invest in it), and the exceptional
project was undertaken in part for other reasons by
the plant.
JUNE 1, 2000/ ENVIRONMENTAL
sCIENcE& TECHNOLOGY
/ NEWS.257 A
:
:*,

Insights into pollution prevention widespread because good opportunities are rare is
The active nature of this collaboration, its success clearly incorrect.
in finding projects that Dow business divisions The vast majority of pollution prevention projects
●

implemented, and the details of the 17 projects that
were implemented reveal important insights into
pollution prevention for policy analysts and cor-
porations interested in further reliance on this
approach for the next generation of pollution
reductions.
● Pollution prevention techniques proved ex-
tremely capable of dramatically reducing toxic wastes
and emissions, even at a chemical manufacturing fa-
cility. Wastes were reduced by more than one-third
and emissions by nearly one-half in only a 30-
month time frame and at a factory whose wastes and
emissions had been essentially unchanged for nearly
five years. The theory that pollution prevention is not
required relatively small amounts of capital and
promised very respectable returns on investment. At
first giance, the fact that small projects can result in
such dramatic reductions would appear to be very
good news. Small size certainly did help accelerate
the speed with which the projects were approved, as
no high-level intervention whatsoever was re-
quired to change business capital allocation deci-
sions to move the projects along. However, from a
business perspective, these small projects were of-
ten not of great interest financially, because even for
cases in which these projects promised large rates
of return, the actual amount of capital returned to
the business would remain insignificant. Further-

mzm
1996 TFU waste generation at Dow
As indicated in public reporting of Dow 1996 TRI wastes and releases, the” company’s Midland site was a significant source of
numerous reportable chemicals.

Chemical Total waste Total release Fugitive air Stack air Surface water

Acetonitrile 280,587 1608 1220 383 5

Acrylamide 35,745 1155 411 38 706
Acrylic acid 21,753 3008 1874 1134 0
Acryionitriie 242,699 28,637 21,150 7471 16
AHyl alcohol 769 768 768 0 0
Ammonia 595,370 13,595 10,333 3037 0
Antimony compounds 169 164 0 148 0
Benzene 230,225 7681 1557 6117 7
Biphenyl 570,575 599 132 466 1
Bis(chloromethyl) ether .0 0 0 0 0
Bromine 468 468 421 “47 0
1,3-ButadDene 277,223 15,419 14,357 1062 0
1,2-Butylene oxide 536 530 476 54 0
Certain glycol ethers 209,625 1545 1109 29 407
Chiorine 754,415 48,945 23,167 25,778 0
Chloroacetic acid 598,616 3 1 2 0
Chlorobenzene 320,343 5673 3534 2100 39
Chlorodifluoromethane 9472 8744 8744 0 0
Chioroethane 208,202 204,721 14,987 189,734 0
Chloroform 83,372 2677 2118 338 221
Chloromethane 1,529,395 9963 6169 3794 0
Chloromethyl methyl ether 197 197 197 0 0
Chlorophenols 7930 23 6 4 13
Chioropicrin 180 77 68 9 0
Chloroprene 34,958 972 972 0 0
Chromium compounds 12,294 12,294 0 32 0
Copper compounds 15,990 15,719 0 14 0
Cumene 26,086 .52 31 18 0
Cyclohexane 178,168 206 1 205 0
2,4-D 26,553 1613 11 775 827
2,4-D Sodium salt 3956 0 0 0 0
Decabromodiphenyl oxide 462 376 0 376 0
1,2-Dichloroethane 7031 4092 3762 330 0
Dichloromethane 767,740 23,390 21,736 1514 140
2,4-Dichlorophenol 420,844 281 70 158 53
1,3-Dlchloropropylene 884 382 336 46 0
Dimethylamine 207,976 1177 767 410 0
Dinitrobutyl phenol 278,930 3832 32 0 3800

258 A 8 JUNE1, 2000/ ENVIRONMENTAL

SCIENCE& TECHNOLOGY/ NEWS
——
.,

-ar$ is more, although the rates of return were very decent, ● Nearly all the poflution prevention projects were
they were often not the very best investment for Dow designed and implemented in a relatively short
ejects capital being considered by the business at that time. time—less than one year—even those that focused
1 and The smafl amount of capital involved and the rate on basic process changes. Much mythology exists
mt. At of return thus worked both for and against most of concerning the difficult nature of fundamental pro-
-ult in the pollution prevention projects internally at Dow. cess changes and what might be necessary to re-
: very The small size helped speed implementation be- duce materials inefficiencies. In this project, the pro-
icrate cause relatively little review was required to ap- cesschanges that would lead to substantial waste and
:d, as prove the expenditures. The small size hurt be- emission reduction required only a little R&D and
.s re - cause it was harder to interest the businesses in anafysis and hence were not excessively time con-
deci- freeing up technical staff to do the initial work to suming for Dow to assess and implement.
om a identify potential projects and in pursuing the ● Reduction opportunities were broadly avail-
-e of- projects once they were identified strictly on finan- able in the various process lines in the plan~ they
-n for cial grounds. It was at this juncture that the inter- did not confine themselves to “new” or “old pro-
rates action between the activists and Dow helped ele- cesses, batch or continuous processes, or a partic-
ed to vate the importance of these opportunities and ular type of manufacturing. Again, conventional wis-
:her- influenced business priorities to create success. dom had suggested that relatively new processes

ater Chemical Totalwaste Total release Fugitiveair Stackair Surface water

—
Ethylbenzene 891,906 22,486 17,721 4,775 0
Ethylene 258,664 258,664 0 258,664 0
Ethylene glycol 279,733 3676 3,665 11 0
Ethylene oxide 5386 4251 3342 909 0
Formaldehyde 1,370,113 47,165 44,769 0 2396
Formic acid 6766 604 604 0 0
Hydrochloric acid 1,402,820 54,031 17,447 36,584 0
4,4’-lsopropylidenediphenol 605 1 0 1 0
Methacrylonitrile 1448 945 943 2 0
Methanol 7,496,643 61,781 41,954 15,616 4211
Methoxone 47 2 1 1 0
2-Methoxyethanol 1308 1067 491 576 0
Methyl acrylate 46,222 804 721 24 59
Methyl isobutyl ketone 14,762 22 16 6 0
Methyl methacrylate 8190 1023 949 51 23
Naphthalene 123,925 157 20 87 47
IWButyl alcohol 15,168 1619 920 699 0
Phenol 411,433 1409 164 1,196 49
2-Phenylphenol 705,? 15 1586 45 1,540 1
Phosgene 406,954 14 0 14 0
Phosphoric acid 32,937 0 0 0 0
Picloram 1466 2 1 1 0
Propylene oxide 51,162 11,109 6658 4,451 0
Sec-butyl alcohol 80,688 10 9 1 0
Styrene ‘t ,492,945 186,109 33,402 139,909 0
1,1,1,2-Tetrachloroethane 284,804 907 2 899 0
Tetrachloroethy lene 1,453,162 39,306 35,399 3,822 85
Toluene 2,472,964 353,900 45,465 308,435 0
Trans-1 ,4-dichloro-2-butene 137 137 137 0 0
2,4,6-TrichIorophenol 1,02?,242 319 136 155 28
Triethylamine 60,931 1288 1128 160 0
1,2,4-Trimethylbenzene 2059 495 275 220 0
Vinyl chloride 296,018 11,350 11,288 62 0
Vinylidene chloride 612,907 20,654 16,165 4,339 150
Xyiene (mixed isomers) 1,462,809 1985 560. 1,395 30
zinc compounds 13,947 13,947 26 25 0

Total 30,141,144 1,523,415 424,940 1,030,253 13,314

Note:Chemicalsin bold were priorities for reduction.

JUNE 1, 2000/ ENVIRONMENTAL SCIENCE & TECHNOLOGY/ NEWS ■ 259 A

 would already be optimized with regard to efficien-
cies, that global competition in this industry seg-
ment would have already caused alI practical im-
provements to have been implemented. This project
largely defied these assumptions.
There were no regulatory barriers to implement-
● tons of toxic polhtants are legalIy discharged into the
ing any of the pollution prevention projects that de-
livered these results. None of the changes required
permit modifications, and no new rules or restric-
tions were invoked by these actions.
●Finally, confidentiality agreements between the
environmental participants and Dow were not nec-
essary it proved possible to explain both processes
and engineering opportunities for reductions with an
amount of detail that supported informed conver-
sations about opportunities without disclosing any
business-sensitive information. Since confidential-
ity issues are often considered a barrier to begin-
ning these projects with outsiders of any kind, the
experience of this project is quite encouraging.
Reducing pollution in the future
Many in the business community believe that we
have gone as far as is practical in our efforts to pro-
tect the environment without harming profitability
and U.S. commerce. For example, it is commonly
stated that we have achieved 90%, reductions in in-
dustrial emissions to date, and that the last IO% of
the reductions will be disproportionately and un-
necessarily expensive to achieve (z). Yet millions of
environment annually, inciuding chemicals that are
persistent and/or bioaccumulative and those that can
cause toxic effects during a single brief exposure. As
populations grow and manufacturing expands, the
impact of manufacturing on health and the envi-
ronment will only worsen unless we fundamentally
change what we manufacture and how we manu-
facture it.
This collaborative initiative suggests that vast ad-
ditional reductions in toxic wastes and emissions—
perhaps as much as one-third or one-half-could be
achieved at many if not most of the nation’s facto-
ries with sufficient motivation and focus. Dow-
Nlidlands conditions me likely typical of much of in-
dustry, as the plant has a wide range of old and new
processes, batch and continuous processes, and wefl-
knownlless-understood chemistries. Thus, across
much of industry, it might well be possible to achieve
aggressive reductions in a very short time frame and

BmEH’
The economic benefits of pollution prevention
Reduction of chemical wastes and emissions, some by more than half, achieved by the 17 pollution prevention
projects involved a total capital investment of $3.1 million and will provide annual estimated savings of s5.4 million.
Units for ali numerical waste and release quantities are given in pounds per year.

Baseline Funded reductions

Priority chemical Waste Relaasa Waste Release

2,4-D 25,167 1054

Acryionitrile 231,458 17,392 0 o
Aliphatic process tar, BCH 769,776 0 500,000 0
Butadiene 275,389 13,583 43,893 0
Chlorine 32,585 31,116 9842 9842
Chloroethane 210,460 210,460 114,000 114,000
Chloromethane 1,487,657 9253 799,000 798
Chromium 10,948 10,948 1300 1300
Cyclic process tar, BCI-2 1,278,500 0
Dichloroethane (1,2) 11,604 4166 3000
Dichlorophenol (z,4) 267,960 281
Ethylbenzene 1,488,966 36,909 364,800 0
Finished product BCI-1 355,895 1328 10,000
Finished prod’uct BCI< 739,350 566 319,000
Formaldehyde 1,387,657 66,653 1,300,000 63,621
HC1-priority 1,392,043 35,862 487,740 7740
Intermediate BC1-4 -“ 128,038 0 31,000
Methylene chloride 489,170 18,608 283,350 339
Phosgene 406,954 14 156,000
Styrene 2,134,370 110,922 663,554 12,478
Tetrachloroethane (1,1,1 ,2) 284,807 901 120,000
Tetrachioroethylene 1,466,099 21,239 984,000
Toluene 683,020 423,178 243,000 243,000
Trichlorophenol (246) 1,021,222 319
Vinyl chloride 296,021 11,350 0
Vinylidene chiorjde 605,295 20,650 82,000
Total 17,460,411 1,046,752 6,515,479 453,118
Percent reduction 37% 43”/0

26o A ■ JUNE 1, 2000/ ENVIRONMENTAL SCIENCE & TECHNOLOGY / NEWS

 b
ol?ly at a savings to businesses. The initia-
1 il- tive vastfy raises el~ectations for what in-
‘~o Of dustry could deliver in the short term, Reductions achieved via pollution prevention measures
un - without significant harm to its bottom
In the monochloroacetic
Ksof line.
) the gas to the incinerator and tars were dramatically reduced through pollution prevention
Some policy experts claim that only
t are measures such as improved refrigeration. (Data provided are annual figures.)
sources not yet regulated, such as non-
can point sources, pollute enough to be
?.As
worth additional regulatory attention. Yet,
the Source
NRDC analysis of TRI data suggests that
nvi- even”if only a very small number of Vent gas to incinerator HCI
dly highly polluting facilities undertook ag-
nu- gressive pollution prevention projects
such as these, the nationwide loading of Overhead tars
ad- toxics could be vasrly reduced in a short
ls— time frame. NRDC analyzed releases plus
i be transfers to publicly owned treatment
:to- works and considered all TRI contami-
!w- nants except acids and bases, which are
MCAA distillation tars 1,1,1 ,2-tetrachloroethane
in- high-volume and very readily treated and
ie~v destroyed. Specifically, the 1997 TRI data
dl- (the latest figures publicly available) re-
-.
r)ss veal that only 200 of the 19,000 facilities reporting to
we the government are responsible for fuiiy 50% of the
md country’s total toxic wastes and releases. A targeted
pollution prevention initiative directed at only the top
1% of facilities would reduce loading by nearly one-
fifth. TRI reveals a similar pattern of concentrated
emitters of specific toxic compounds as well. For ex-
ample, only 10 facilities are responsible for 6TT0 of
the total air emissions of ethylene dichloride and 4
TRI facilities are responsible for 50’7.of factories’ air
emissions of mercury. A federaf or regional pollu-
tion prevention initiative directed only at impor-
tant facilities, from an overall pollution load per-
spective, merits serious consideration by EPA and
state regulators.
However, the experience of this collaborative
3 project also suggests that business value alone (i.e.,
1 the savings inherent in waste reduction) is not a suf-
1 ficient internal driver of pollution prevention for a
~
business in most instances. To the contrary, pollu-
)
) tion prevention projects are often vie~ved by a busi-
) ness as elegant solutions to a problem they do not
think they have. Businesses point to their permits
to treat and emit their wastes and the relatively small
savings often delivered as reasons for giving these
projects low priority in the general scheme of op-
erating their businesses. Strictly from the perspec-
tive of business value, why invest staff time and re-
sources on this issue when there are much more
pressing problems or profitable opportunities else-
where within the business? Despite the way they are
viewed by environmental professionals, opportu-
nities to reduce waste and save money are not “no-
brainers” to businesses; they implement them not
if they are a “good” use of their time and money, but
only if they are the best use compared, to compet-
ing proposals. Good pollution prevention projects
will not usually be the best use of business time and
resources.
Thus, either an aggressive self-directed and vol-
untary initiative in a trade association or group of
companies, or community-based or regulatory pres-
acid (MCAA) production process, wastes associated with vent
Estimated release Estimated waste
MSRI chemical reduction (pounds) reduction (pounds)
o 480,000
Phosgene o 156,000
.
Vinylidene chloride o 48,000
Non-TRl chlorinated o 500,000
Organics
(aliphatic tar BCI-1)
CAC o 10,000
(finished product BCI-1)
o 120,000
sure is needed to initiate the next generation of pol-
lution reductions possible using pollution preven-
tion techniques. Perhaps an industry sector such as
polyurethane foam blowers, which generates very sig-
nificant methylene chloride emissions from pro-
cesses across the country that vary little from plant-
to-plant, could embark on a pollution prevention
initiative in which research supported by the sector
would be applied across many plants. Perhaps the
ChemicaJ Manufacturers Association, through its Re-
sponsible Care Program, could sponsor a showcase
pollution prevention project for its members to ob-
serve at close range; followed by a sign-up program
for members who want to try it themselves to re-
duce their local environmental impact. Finally, per-
haps EPA could contact specific companies at the
CEO level with a request to reduce certain emis-
sions to a certain level by a certain date (as it did suc-
cessfully in its “33/50” program a decade ago), of-
fering technical pollution prevention assistance to
facilitate these reductions. These and other sorts of
outside initiatives will be necessary to overcome the
inertia concerning pollution prevention that we face
in most of American industry.
Acknowledgment
NRDC gratefully acknowledges financial support pro-
vided for this projecr by the U.S. Department of Energy Of-
fice of Industrial Efficiency, EP.% the C.S. Motr Founda-
tion, and rhe Joyce Foundation. A full description of this
projecr can be found in the NRDC report Prewnring In.
dlLSlrfa~ f%~~tfriorr ar Ifs .kmrce, available rhrough Merid.
ian Institure, Dillon, CO, or on the Web ar www.nrdc.org.
References
(1) Greer, L. E.; van Loben SeIs,C. .Gru’ron. Sci. Techrro[,1997,
31 (17), 418A-422A.
(~) Breyer, S. Breaking the Viciom Circie; Harvard University
Press: Cambridge, M.A,1993.
Linda Greer is a senior scientist Luit]l tjle Nfllllral
Resources Defense Counci[ and the director of its pub-
lic Health Program, where she has worked on to.ric
chemical issues for a decade.
JUNE 1. 2000/ ENVIRONMENTAL SCIENCE & TECHNIJLCIGV / NEWS ~ 261 A