Pollution prevention and waste reduction under RCRA regulations

Pollution prevention has various meanings and is frequently used. Toxics use/reduction and sources reduction are the most narrow terms, being restricted to raw material or production process changes. Pollution prevention promotes a hierarchy that favors source reduction, but also promotes other minimization techniques or treatment where production changes are infeasible. Explain why the best approach is one that cost-effectively reduces waste, minimizes worker exposure to toxic materials, optimizes use materials, improves a product's competitiveness in local and world markets, and enhances a company's image of responsibility to the community.

"Environmental, Health, and Safety Guidelines for Waste Management Facilities" published by the International Finance Corporation states that these guidelines "contain the performance levels and measures that are generally considered to be achievable in new facilities by existing technology at reasonable costs." (Environmental, Health, and Safety Guidelines, 2007) the guidelines "should be tailored to the hazard and risks established for each project on the basis of the results of an environmental assessment in which site-specific variables, such as host country context, assimilative capacity of the environment and other project factors are taken into account." (Environmental, Health, and Safety Guidelines, 2007)

The work entitled: "Sustainable Development and Society" published by the GSA Office of Governmentwide Policy (2004) states that the most economical choices "are those that have the lowest life cycle cost in order to make those choices..." (GSA Office of Governmentwide Policy, 2004) the complete sustainable development model is stated to consider "the simultaneous pursuit of economic prosperity, environmental quality and social equity is a useful framework for informing the business decisions we all must make." (GSA Office of Governmentwide Policy, 2004) the first two factors of the "sustainable development triad, economic concerns and environmental stewardship are well understood and being applied effectively today - particularly in the area of facilities design and construction." However there is a need for a greater comprehension of the third factor which is that of 'social equity'. Social equity is stated to be a "broad topic that includes both individual and corporate responsibility.

I. The RESOURCE CONSERVATION and RECOVERY ACT (RCRA)

The Resource Conservation and Recovery Act (RCRA) is a federal environmental law that regulates solid and hazardous wastes from generation through disposal. Hazardous wastes are divided into to categories: (1) listed and (2) characteristic. Characteristic Hazardous wastes are stated to exhibit "one or more of the four hazardous characteristics" which are those of: (1) ignitability; (2) corrosivity; (3) reactivity and (4) toxicity. (Ohio EPA, nd) Listed hazardous wastes are stated to be listed specifically by name or process in the hazardous waste regulations." Pollution prevention is stated to use "source reduction and environmentally sound recycling to reduce or eliminate hazardous waste and other pollution at the source. Pollution prevention, also termed P2 is stated to include "good operating practices, material substitutions, process changes and recycling." (Ohio EPA, nd) P2 further addresses "all waste streams" including solid and hazardous waste, air and water." (Ohio EPA, nd)

II. CASE STUDY in WASTE REDUCTION

The Tennessee Valley Authority (TVA), the Environmental Protection Agency (EPA) and the eight states in EPA's Region IV are stated to have joined in funding a waste reduction assistance project which included the industries as follows:

2281 Carpet Yarn Spinning

2295 Fabric Coating

2434 Wood Kitchen Cabinets

2721 Magazine Printing

2752 Offset Printing

2771 Greeting Cards

2893 Printing Ink Manufacturer

3011 Trailer and Industrial Tires

3052 Hydraulic Industrial Hose

3069 Rubber Molded Products (Car Floor Mats)

3069 Rubber Weather Strips

3295 Fused Magnesite Ore

3429 Automotive Locks

3451 Screw Machine Products

3465 Automotive Suspension Systems

3471 Electroplater

3479 Hot Dip Galvanizing Service

3499 Metal Cabinet Manufacturer

3535 Conveyor Systems

3546 Bench Top Power Tools

3651 Speaker Enclosures

3728 Aircraft Parts and Auxiliary Equipment

3728 Aircraft Assemblies and Sub-Assemblies

3732 Boat, Bus and Truck Seats

3751 Bicycle Seats

3823 Electric Power Generator

4911 Electric Power Distribution - Urban (Transport and Service

4911 Electric Power Distribution - Rural (Vehicle Maintenance and Service Shops)

7699 Aircraft Repair

8062 General Medical and Mental Hospital

8744 Airbase Support Service

In the case of each of these industries waste streams were identified and a stated total of the reduction of 950 tons of hazardous waste and 600 tons of nonhazardous solid waste as well as 680.000 gallons of wastewater are reported. One case study extracted from this report is that of the industry of 'Fabric Coating' which is a manufacturer of vinyl and polyurethane coated fabrics that are used in boot liners, show uppers and insulating jackets and cap material. It is stated in the report that in 1989 "this company's use of 4,200 gallons of VOC solvents contributed to 30,000 pounds of VOC emissions, including wash solvents." The replacement of solvent materials with a "water-based material with the following product line potential percentages was suggested:

Vinyl Coating

Printed Top Coat

Vertical Cans

The result is stated to achieve a significant reduction in VOC emissions. Suggested as well was a replacement of the solvent type ink with water-based ink which would "generate cost savings of $35,000" per year with the solvent changes alone saving the amount of $29,000 annually. The results was substitution of solvent coating with a water-based coating and 'plastic sol' stated to be a material which is used to make vinyl and which can be recycled in the process" substituted for solvent for cleaning pumps. VOC emissions were reduced annually by 206,000 pounds and Hazardous material disposal costs experienced at $7,000 reduction annually. Solid waste reductions were by 31,000 pounds annually with raw material costs savings totally $13,000 annually.

SUMMARY & CONCLUSION

Pollution prevention and reduction in the use of toxics and reduction in waste are greatly at focus for the Environmental Health and Safety Guidelines (2007) which are guidelines that can be specifically tailored to the established hazards and risks for each individual process depending upon the various factors that are applicable at each site. The Resource Conservation and Recovery Act (RCRA) is a federal environmental law that regulates solid and hazardous wastes from being generated during disposal. Hazardous wastes are those that may ignite, that are corrosive or reactive and those which are toxic. (Ohio EPA, nd) Pollution prevention is also important in establishment of operation practices that are considered best practice as well in substitution of materials, and during process changes and recycling. (Ohio EPA, nd)

The three pillars of sustainable development are stated in the work of Norris (2004) to include those of: economic, growth, ecological balance, and social progress. Life Cycle Analysis in assessing environmental impacts has various applications including ecolabeling and according to Norris is a method that may be used to explain "cradle-to-grave' consequences on the environment of decisions related to products. Norris reveals that the LCA has a capability for allowing processes to be tagged within the supply chain model within given countries or regions. The key finding in this study is that more accountability will be the guiding principle in the future relating to material and waste reduction and disposal methods. Thereby making it critically important that this best practice approach is adopted which enables the cost-effective reduction of waste and minimizes the exposure of workers to toxics as well as optimizes the use of materials which ultimately results in improving the competitiveness of the product in both local and world markets due to enhancing the image of the company that follows these best practice guidelines.