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OCR for page 181
Appendix J
Uniform Waste Reduction Standard
The Natural Resources Defense Council
(NRDC) has proposed the most comprehen-
sive approach for mandating a waste
reduction standard (Clarence-Smith,
l98Sa,b). This group defines efficiency as
"the ratio of the total amount of each
hazardous chemical released annually from
the processes at a facility (and from
subsequent recycling operations) to the
throughput in the same year of that chemical
at the facility. Total releases are the sum of
losses from a manufacturing process prior to
treatment, losses from on-site recycling, and
losses leaving a facility as impurities in a
product. Throughput is the sum of
total releases,
the amount leaving a facility in the
product,
· the inventory change,
· the amount transformed on site,
· the amount recycled on site or sent off
site for recycling, and
· the amount entering all downstream
processes.
If a hazardous or toxic chemical is not
found in the raw material, then a raw
181
material other than that chemical is used in
the throughput term, resulting in
inconsistencies in reporting as discussed in
Chapter 5.
Clarence-Smith ( 1 988a,b) recommends
that a uniform standard be set for all
industries. Based on an analysis of the New
Jersey data, he further suggests that an
~efficiency" or a star~dard of 5 percent be
adopted. This implies that the total releases
from all facilities must be less than or equal
to 5 percent of the throughput. Annual
reporting requirements would apply to the
chemicals listed in SARA Section 313, and
facilities would be allowed 10 years to
comply with the performance standard.
Clarence-Smith (l98Sa) gives an example
of an efficiency calculation. He describes a
facility in which TCA is used to decrease
metal parts. TCA throughput includes
14,000 lb emitted to the atmosphere and
7,000 lb recycled off site, for a total
throughput of 21,000 lb. Since the facility
receives credit for the recycling, the
efficiency is the ratio of the atmospheric loss
to the throughput (14,000/21,000), or 67
percent
The facility can meet the standard by
OCR for page 182
182
lowering its measure of efficiency to 5 per-
cent in at least three ways. First, it could
substitute a chemical that is not on the
SARA Section 313 list. Indeed, several
hydrocarbon solvents are currently being
examined for use in place of the listed
chlorinated solvents. The disadvantages of
these replacement solvents are that they are
combustible and photochemically reactive,
and their health effects have not yet been
thoroughly determined. In effect, they are
too new to have been adequately scrutinized
and may eventually prove to be carcinogenic
or to pose other threats to human health.
The facility could also convert to an aqueous
cleaning method. In this case, organic and
metal contaminants would be released to the
sewer, posing a different threat. In both
instances-conversion to the hydrocarbon
solvent or to the aqueous cleaner - the facili-
ty could avoid the reporting requirement
even though these processes may be hazard
ous.
The second way the facility can meet the
efficiency requirement is to increase the
amount of solvent sent for recycling. (Note
that while the example credits solvent sent
for off-site recycling, under present regula-
tions reclamation or reuse may include usage
of the solvent as fuel.) Thus the facility can
simply sell the solvent to a recycler and the
recycler can send it directly to an industrial
furnace or an incinerator that does not per-
form the expected reclamation. In fact, the
facility would have no knowledge or interest
in the final destination of the solvent as long
as it could prove it was sent to an off-site
recycler.
The third method of meeting the
efficiency standard is to decrease the atmos-
pheric emissions of the solvent. For every
pound of solvent used in a degreasing opera-
tion, between 0.43 and 0.85 lb is lost to the
MASS BALANCE INFORMATION
atmosphere; the balance is contaminated
liquid solid waste (EPA, 1985b). Through
the purchase of more conservative cleaning
equipment, emissions can be reduced signifi-
cantly. This reduction of emissions trans-
lates into a corresponding reduction in total
solvent use. Even with this decline in the
absolute level of solvent use, however, the
proportions of solvent emitted and produced
as waste remain roughly the same per pound
of solvent used. Therefore for every pound
of solvent used (Clarence-Smith's [198Sa]
concept of throughput), the atmospheric loss
still amounts to 0.43 to 0.85 lb. For cleaning
applications with solvents, then, the 5 per-
cent efficiency standard can never be met.
There are probably hundreds of
thousands of degreasers in the nation,
ranging from small units holding less than a
gallon to large conveyorized units containing
thousands of gallons. These degreasers are
used in numerous facilities that are classified
under the SIC Codes in the Manufacturing
Division and thus represent a significant
number of the facilities covered by SARA
Section 313. These facilities would be un-
able, even with a 10-year compliance period,
to ever meet the efficiency standard
specified in Clarence-Smiths (l98Sa) model.
Thus this model, like others that attempt to
treat all industries and all facilities uniform-
ly, would not accomplish the intended goals.
Instead, they may increase the threat to pub-
lic health or cause small- and medium-size
generators to close their plants.
Thus it is clear that significant problems
arise when this uniform approach is used for
even the most rudimentary processing situa-
tions. Serious problems can be expected
when this concept is applied broadly within
the many complex processing situations
found throughout industrial facilities
covered by SARA Section 313.
Representative terms from entire chapter:
efficiency standard
