Regional Highlights Pacific Northwest
Pollution Prevention Roundtable
June 16-17, 1999 in Olympia, Washington — Full Report

Table of Contents

June 16 Sessions:

Goals and Audiences
Toxics in Wastewater: Laying the Groundwork
Strategies for Small Dischargers
Strategies for Large Dischargers
Water Efficiency: Overview of Opportunities
Water Efficiency Part 1: P2 Examples
Water Efficiency Part 2: Water Reuse
Water Efficiency Part 3: Tools You Can Use

June 17 Sessions:

Preliminary Discussion
EPA Headquarters Update
National Pollution Prevention Roundtable: Update and Discussion
Using Market Tools to Achieve P2: Overview of Opportunities
Market Tools Part 1: Procurement for P2
Market Tools Part 2: Certification or Eco-Label Programs
Market Tools Part 3: Extended Product Responsibility (EPR)s

List of Attendees


Full Report

dot GOALS AND AUDIENCES

Summary of Goals

  1. Day One: 1) Foster networking between pollution prevention practitioners and wastewater treatment operators, and 2) Identify opportunities for the two communities to work together on mutually beneficial projects that prevent pollution.
  2. Day Two: Build understanding of market tools to achieve pollution prevention.

Audience: Pollution prevention technical assistance providers (TAPs), P2 program managers, permit writers, wastewater treatment plant operators

 

Wednesday, June 16, 1999

dot WELCOME and INTRODUCTIONS

The roundtable was opened by Laurel Tomchick from the King County Local Hazardous Waste Management Program. Chris Wiley from the Pacific Northwest Pollution Prevention Resource Center asked attendees to describe their reasons for coming to the meeting. Among the reasons stated were: 1) Learn more about P2, and 2) Identify P2 opportunities in wastewater treatment, water efficiency and watershed management.

 

dot TOXICS IN WASTEWATER: LAYING THE GROUNDWORK

Facilitator:
  Judy Kennedy
    Washington Department of Ecology (Ecology)
    360-407-6744,
jken461@ecy.wa.gov
    Web: http://www.wa.gov/ecology

Discussion Participant:
  Dave Galvin
    King County Local Hazardous Waste Management Program (LHWMP)
    206-263-3085, dave.galvin@metrokc.gov
    Web: http://www.metrokc.gov/hazwaste

Handouts Available

The Bottom Line

  1. Hazardous waste discharges to sanitary sewers are increasing. Such discharges can harm salmon runs, cause upsets in the sewage treatment process, damage treatment systems, endanger workers, and expose POTWs to greater regulatory liability.
  2. The concept of a "super-inspector" having expertise in all media is not practical, but media inspectors should have a working awareness of pollution or compliance problems that other media programs see in order to make referrals.
  3. P2 programs have greater perceived value when seen in the context of salmon restoration.

Toxic Discharges to Sewers
Judy Kennedy: P2 is relevant to wastewater because of increasing amounts of metals, chlorinated solvents and other toxic wastes being discharged to sanitary sewer systems. Publicly owned treatment works (POTWs) are a potentially valuable partner to P2 programs for preventing the discharge of toxics into sewers. Washington waters receive more discharges of carcinogenic substances than the waters of any other state, according to 1996 Toxics Release Inventory (TRI) data. Between 1991 and 1995, TRI data show, the discharge of toxics to Washington POTWs increased 19 to 27 percent annually, while air releases were falling. Between 1992 and 1996, 140 million pounds of partly treated toxics passed through POTWs in the U.S. (To find complete TRI data and reports, visit http://www.epa.gov/opptintr/tri/tri97/access.htm.)

The pass-through of toxic wastes from POTWs into surface waters is relevant to restoring threatened and endangered salmon runs. For example, surfactants found in dishwashing detergents, cosmetics, pulp mill waste, and plastics can act as endocrine disruptors. Nonylphenols are an example of surfactants suspected of having endocrine disruptive properties. (For more information about nonylphenols, see web sites listed at end of discussion on this topic.)

Toxics are difficult to control through discharge permits. According to a U.S. General Accounting Office study, 77 percent of industrial toxics are not addressed by industrial discharge permits. Two-thirds of toxic metals in wastewater come from small, non-permitted dischargers.

Many toxics are not easily broken down by sewage treatment processes designed to degrade biological wastes. While a portion may be broken down, others may simply pass through the system, volatilize into the air, or end up in sewage sludge, meaning that the waste is being shifted from one environmental medium to another. The extent to which wastes are broken down or shifted to other media depends on both the type of substance entering the system and the way a treatment plant is operated. For example, the duration and rate of aeration plays a large role in determining how much of a toxic volatilizes.

An example of what happens to an organochlorine in a treatment plant was provided through computer modeling of 1,4-dichlorobenzene, a substance used in the manufacture of dyes, agricultural chemicals, restroom deodorants, and moth balls. Modeling of 1,4-dichlorobenzene in an activated sludge treatment process showed that 44 percent of the substance was degraded, while 32 percent passed through, 19 percent volatilized, and 5 percent ended up in sewage sludge. (1,4-dichlorobenzene is on EPA’s list of Hazardous Air Pollutants and must be managed as hazardous waste under the Resource Conservation and Recovery Act [RCRA]. There is evidence that this chemical causes cancer in lab animals, and European tests have turned up evidence of aquatic toxicity.)

A 1995 Idaho study found that 20 percent of wastewater treatment plant upsets were caused by toxics, but that few upsets took place in areas where there were industrial pretreatment programs. Pretreatment removes substances from wastewater that POTWS are not designed to degrade.

The presence of toxics in wastewater can cause numerous problems for POTWs. They include the following:

The benefits of reducing toxic discharges to wastewater through pollution prevention include the following:

Coordinating Among Agencies
Dave Galvin: Environmental agencies have common public health and environmental protection goals, to "keep the green green and the blue blue." However, environmental programs have been segmented by medium, and there has been little communication among air, water, or waste programs. It makes sense to better integrate the work of the media programs, although the concept of a "superinspector" with detailed knowledge of all media and their regulations is not practical. One person could not be expected to know all of the regulations that apply to all media.

A better alternative is to improve coordination among media programs. Program staff should know enough about other programs to be able to share information and coordinate efforts. Two examples illustrate the potential benefits:

Pretreatment programs generally focus on larger businesses, but there are many small companies that can discharge potent chemicals into sewer systems. An example in King County was a small biotechnology company using sodium azide as a bactericide. Sodium azide is acutely toxic, but the company was simply pouring sodium azide-laced wastewater down the drain. Another hazard is this substance’s reactivity. Sodium azide reacts with copper and lead in piping, which could result in an explosion. The Local Hazardous Waste Management Program found an alternative for the company and the sodium azide discharges were stopped. The company also changed its RCRA status from Large Quantity Generator (LQG) to Small Quantity Generator (SQG). (In Washington, an SQG is equivalent to a Conditionally Exempt Generator in other states.)

Agencies should think of their programs in a watershed context, so that the relevance of agency activities to restoring endangered salmon and steelhead runs is apparent. The more that agencies portray their activities in the salmon context, the better off they will be in promoting their programs and demonstrating their value. Networking helps program staff see beyond their areas of immediate interest and share ideas for improving the effectiveness of all programs.

Discussion
Discussion issues included coordinating programs and non-permitted discharges.

Coordinating Programs: The Interagency Regulatory Analysis Committee (IRAC) is a forum at which representatives of King County agencies review fire, drainage, hazardous waste and other ordinances and regulations to prevent duplication and conflict. There is discussion of using IRAC as a forum at which inspectors from various local and state programs could trade information about businesses that any of the inspectors have visited. King County already has a database that hazardous waste and pretreatment personnel can use to examine each other’s records. (To read an article about IRAC, visit http://www.metrokc.gov/hazwaste/lhwmp/fpmay98.html#irac.)

Non-permitted Discharges: Identifying pollutants by name in a permit has disadvantages as a way to prevent their discharge to sewers, because the limit must be justified and the substance monitored. By avoiding the creation of wastes in the first place, through P2, environmental goals can be attained without those disadvantages.

Toxics in Wastewater Resources

Nonylphenol Resources

 

dot STRATEGIES FOR SMALL DISCHARGERS

Facilitator:
  Freda Tepfer
    Snohomish County Solid Waste Management
    425-388-6473,
freda.tepfer@co.snohomish.wa.us

Discussion Participants:
  Gail Savina
    King County Local Hazardous Waste Management Program (LHWMP)
    206-263-3062, gail.savina@metrokc.gov
    Web: http://www.metrokc.gov/hazwaste
  David Wigglesworth
    Alaska Department of Environmental Conservation (DEC)
    907-269-7582, dwiggles@envircon.state.ak.us
    Web: http://www.state.ak.us/local/akpages/ENV.CONSERV
  Judy Kennedy
    Washington Department of Ecology (Ecology)
    360-407-6744, jken461@ecy.wa.gov
    Web: http://www.wa.gov/ecology

Handouts Available

The Bottom Line

Lessons from Dental Outreach Project
Gail Savina: King County’s dental outreach campaign began in the early 1990s after mercury spikes were detected in wastewater. A 1991 study found that 14 percent was coming from dental offices using mercury-containing amalgam for teeth fillings. There are 1,600 dental offices in King County, an estimated 1,440 of which use amalgam. The outreach campaign began in 1996.

Amalgam is an alloy consisting of approximately 50 percent mercury and 50 percent other metals, such as silver, copper and tin. Mercury-bearing amalgam waste is discharged from dental offices in several undesirable ways — mixed with bio-medical waste, thrown out with solid waste, or sent down the drain. Few dental offices have treatment systems to extract mercury from wastewater.

The county decided against a purely regulatory approach to preventing improper mercury waste discharges because of the economics of treatment systems. Dentists indicated they would be willing to work with the county on preventing improper mercury waste discharges, if given sufficient time. The goal of the resulting outreach campaign was for dentists to properly manage metal-bearing and other hazardous wastes, such as used x-ray fixer solution.

The nature of the dental business had significant influence over the county’s selection of outreach strategies. Since the business is characterized by a large number of small offices, mercury discharges are small and diffuse. It made more sense to work with the sector as a whole, rather than work with a few individual offices.

It’s important to thoroughly understand the business targeted by the outreach campaign. Assistance providers should be humble, and ask lots of questions to understand the reasons for operating practices that affect the environment.

In learning about the dental business, the LHWMP identified a number of barriers to proper handling of mercury waste. Dentists had little knowledge about mercury, there were few disposal options, and no explicit environmental model to follow. At the time, there was no infrastructure in place to collect mercury in tiny individual quantities from a large number of dental offices. A cultural barrier is that dentists don’t think of their business as polluting.

Dentists are well organized into professional associations at the local, state and national level. They are quite collegial and learn from each other. Also, they prefer to receive written materials with technical, detailed information.

The information the county learned about the dental business was used to overcome barriers, and informed the preparation of materials and activities, such as a poster, articles in dental journals, site visits, and workshops. The poster, for example, provides detailed guidance on proper management of amalgam, bio-medical waste, x-ray fixer, lead foils, and precious metals. The poster includes a list of vendors that provide reclamation, recycling, waste transport, and wastewater treatment services.

A key strategy was to collaborate with professional dental associations and dental equipment suppliers in preparing and communicating information about proper waste management. The associations and suppliers served as a credible, trustworthy channel for conveying the information, and the LHWMP served as technical support. The EnviroStars program was promoted as a way to create sector leaders for other dentists to follow. (To see a list of EnviroStar dentists in King County, visit http://www.metrokc.gov/hazwaste/estars/dentist.htm. To see a waste management help page for dentists, visit http://www.metrokc.gov/hazwaste/dental.)

Results: As of the first quarter of 1999, about 90 dentists were collecting at least some of their amalgam waste for reclamation. Through March 31, 1999, 11 to 13 dental offices had installed wastewater treatment units. A total of 45 King County dental offices are EnviroStars, including all the officers of the local dental society. Sixteen articles had been published on dentists and the environment.

The dental outreach campaign could not be characterized as a wild success, but awareness is building slowly about this sector’s waste issues. The Washington State Dental Association recently published an article about EnviroStar dentists, and Safety-Kleen is marketing a dental waste management program.

Lessons learned from the campaign include the following:

Discussion
Issues raised in discussion included different attitudes toward environmental issues among older and younger dentists, substitutes for amalgam, working with dental assistants, and linking P2 and public health.

Different Attitudes: The LHWMP found that attitudes about environmental issues differ between older and younger dentists. It was found that younger dentists are more receptive to addressing environmental issues, and the county now works with a young dentists committee.

Amalgam Substitutes: The LHWMP decided not to push dentists to stop using amalgam altogether, because the issue is very controversial in the dental community. A push to stop using amalgam would have created strong resistance from the American Dental Association, increasing the danger that the county’s overall waste management message wouldn’t have registered. Dentists who have stopped using amalgam altogether are considered by some in the dental community to be "fringe." In some cases, dental insurance will not pay for fillings unless amalgam is used.

The city of Portland, which started a dental outreach campaign on July 1, 1999, found in designing its program that a push to eliminate amalgam would have been "a kiss of death."

To learn more about the amalgam issue, visit:

Dental Assistants: An effective strategy is introducing waste management information to dental assistants, who often are the dental office personnel assigned to deal with wastes. Dave Waddell of the LHWMP said his experience is that dental assistants are very responsive to information on proper dental waste management.

P2-Public Health Link: David Wigglesworth from the Alaska DEC suggested highlighting the relationship of dental health with prevention of mercury pollution – if people take care of their teeth, fewer fillings will be needed in the first place.

Working with Community on Managing Non-Domestic Wastewater
David Wigglesworth: The Alaska DEC has undertaken a compliance assistance and pollution prevention outreach project on the Kenai Peninsula. The goal of the project is to prevent water pollution from the improper disposal of non-domestic wastewater and hazardous waste into "Class V" shallow injection wells. Class V wells are usually "low-tech" holes that rely on gravity to drain the injected wastes into the ground. Their simple construction is not effective for protecting groundwater against contamination by hazardous wastes.

DEC is attempting to build awareness and implementation of locally acceptable land use policies and other practices to protect groundwater and drinking water quality on the Kenai Peninsula. Objectives include:

DEC has identified a number of problems with waste discharges on the peninsula. In some cases, businesses are discharging to septic systems plumbed for residential loads. In other cases, properties have changed hands, and new businesses bring new disposal problems. Many businesses on the peninsula operate with slim profit margins.

DEC is using financial institutions as one channel for conveying information to customers about the benefits of avoiding liabilities with shallow injection systems. One bank has agreed to change its loan approval checklist after being informed that septic systems are not capable of degrading toxic waste.

Local comprehensive plans are a tool for achieving objectives such as groundwater protection. The DEC is working with three communities to develop pretreatment plans.

The state is working to build rapport with local governments and businesses in the area, many of which are suspicious of state government and government in general. Community goals may be at odds with the goal of the assistance project. The city of Soldotna, for example, favors discharges to septic systems instead of sewers. Taking the extra step to build personal relationships is helpful. In one case, for example, a DEC staffer bought a German chocolate birthday cake for a person in a local planning office.

Discussion
Discussion focused on working with communities and plumbing inspectors to reduce toxic discharges that threaten groundwater and surface water.

Working with Communities: In Oregon, the Community Solutions Program is a vehicle to incorporate environmental objectives into local land use plans. Dave Waddell from the LHWMP said that shop owners who fish for salmon understand the connection between preventing toxic discharges and water quality protection. Freda Tepfer of Snohomish County suggested that property value protection is a good hook to use in working with septic tank owners.

The city of Everett’s sewage treatment plant will accept septic tank waste from throughout Snohomish County. Manifests are required of businesses sending septage to the treatment plant, so that treatment personnel can check for toxic constituents if necessary.

Plumbing Inspectors: Dave Waddell said an untried avenue for getting a P2 message across is to educate plumbers and plumbing inspectors about hazardous chemicals that they can be exposed to when reviewing or working on wastewater piping.

Class V Shallow Injection Well Resources

Sector Outreach Campaigns
Judy Kennedy: Ecology has undertaken a number of sector campaigns to help small businesses and institutions reduce hazardous waste generation through P2 and to properly manage wastes they do generate.

More than 1,700 auto repair shops were visited in the 1992-1993 Shop Sweeps campaign. A total of 82 percent of the shops adopted some recommended changes, 61 percent of all recommended changes were adopted, 82 percent of the shops kept educational materials they were given during visits, 59 percent gave the visits a high rating, and 67 percent believed the visits were more effective than inspections.

The Snap Shots campaign, carried out in 1994-1996, concentrated on keeping silver out of wastewater from printing and photo processing shops. In some cases, the shops were visited by POTW personnel. Seventy-five percent of shops adopted some recommended changes, 51 percent of all recommendations were adopted, 83 percent of visited shops said they learned useful compliance information, 59 percent said they learned useful P2 information, 77 percent kept educational materials, and 96 percent said the "sweeps" approach should continue. (To see Ecology’s Shop Sweeps and Snap Shots publications, visit http://www.ecy.wa.gov/programs/hwtrhwtrpubs/index.html.)

Outside the Northwest, assistance campaigns have been effective in reducing hazardous waste discharges to wastewater. In Palo Alto, Calif., for example, visits to photo processors resulted in a 75 percent reduction in silver discharges after two years and an 83 percent reduction after three years. A wastewater treatment agency serving Sacramento was violating its Title V air operating permit as a result of perchloroethylene, or "perc" discharges entering the treatment system and volatilizing. A campaign to reduce perc discharges into the sewers reduced the concentration of perc at the treatment headworks from 29 micrograms per liter in 1988 to 6.2 micrograms per liter in 1993.

 

dot STRATEGIES FOR WORKING WITH LARGE DISCHARGERS

Facilitator:
  Hugh O’Neill
    Washington Department of Ecology (Ecology)
    360-407-6354,
hone461@ecy.wa.gov
    Web: http://www.wa.gov/ecology

Discussion Participants:
  Chuck Hopkins
    Oregon Department of Environmental Quality (DEQ), Pretreatment Coordinator
    503-229-6528, hopkins.chuck@deq.state.or.us
    Web: http://waterquality.deq.state.or.us/wq/Pretreatment/Pretreatment.htm
  John Greeley
  Clayton Brown
    Unified Sewerage Agency of Washington County, Oregon
    503-844-8922, greeleyj@usa-cleanwater.org
    503-844-8923, brownc@usa-cleanwater.org
    Web: http://www.usa-cleanwater.org
  Judy Kennedy
    Washington Department of Ecology
    360-407-6744, jken461@ecy.wa.gov
    Web: http://www.wa.gov/ecology

Handouts Available

The Bottom Line

P2 in Oregon’s Pretreatment Program
Chuck Hopkins: Oregon has incorporated pollution prevention into its statewide pretreatment program. Pretreatment of certain industrial wastewater discharges is designed to prevent the discharge of hazardous substances that can pass through POTWs untreated, interfere with the treatment process and/or pose health and safety risks to treatment plants.

The Oregon Association of Clean Water Agencies (ORACWA) was formed to provide pollution prevention and other educational services to wastewater and stormwater agencies. Today, the organization has 80 members. ORACWA has produced industry-specific P2 materials and a best management practices manual for fats, oils and grease. ORACWA conducts educational events for clean water agencies on pretreatment, urban stormwater P2, sludge management, and other topics. (For information about ORACWA, visit http://www.oracwa.org)

The origin of Oregon’s integration of P2 into pretreatment programs was a Pollution Prevention Incentives for States (PPIS) grant. Pollution prevention is included in an annual Northwest pretreatment conference put on by ORACWA. At this year’s conference, P2 audits and benefits for pretreatment were on the agenda.

The National Pretreatment Excellence Awards, available through EPA’s Office of Wastewater Management, is looking for nominees of agencies that have exemplary pretreatment programs. An example of an award-winning agency is the Central Contra Costa Sanitary District in California, which has an extensive pollution prevention program for businesses and households and won a first place award last year. (To find out more about the Central Contra Costa Sanitary District’s P2 program, visit http://www.centralsan.org/services/pollprev.html.) The second place award was won by the Metropolitan Wastewater Management Commission, serving Eugene and Springfield. (For more information about pretreatment awards, contact Patricia Campbell at EPA, 202-260-9867, or campbell.patricia@epa.gov.)

DEQ’s pretreatment office conducts inspections and compliance audits of local agency pretreatment programs, which include a look at whether local agencies are providing P2 education. The office also offers an annual short school, which includes pretreatment and P2.

Technical assistance is provided to local agencies. For example, bronze casting is a significant industry in northeastern Oregon. The state helped the communities of Joseph and Enterprise incorporate P2 into their pretreatment programs.

Incorporating P2 into Oregon’s pretreatment programs has been made possible by the following:

Discussion
Issues raised in discussion included state regulation and delegated pretreatment permitting authority. A question that came up was whether it is preferable to regulate pretreatment through a statewide office, as is done in Oregon, or through regional offices, as the Washington Department of Ecology does. Richard Hoiland of the city of Vancouver said full-time dedicated staff is necessary to do the job well. In Washington, pretreatment coordinators often have NPDES permit work and other assignments in addition to pretreatment. Oregon ACWA opposed a move to move pretreatment regulation out to DEQ’s regional offices.

Oregon has 24 local agencies that have delegated pretreatment permitting authority, while Washington has nine. The state handles pretreatment permitting in areas served by wastewater agencies that do not have delegated permitting authority.

P2 in Unified Sewerage Agency Pretreatment Program
John Greeley and Clayton Brown: The Unified Sewerage Agency’s wastewater treatment facilities have a combined capacity of 60 million gallons per day. The agency has 150 permitted industrial users, including 55 significant industrial users. The agency uses education and technical assistance to promote the adoption of P2 in its service area. For the P2 message to get across and stick, it needs to be reinforced at every opportunity, with both agency staff and agency customers, through education and technical assistance. Enforcement activities are good opportunities to focus on P2.

P2 is incorporated into pretreatment programs little by little. ORACWA’s annual pretreatment conference is a good opportunity to learn from others.

The P2 message must be repeated. In 1993, for example, the agency developed an educational brochure as part of a project to develop best management practices for stopping discharge of silver from photo processing wastewater. The agency visited photo processing shops and as a result, 70 percent implemented silver BMPs. Shops like the voluntary approach. There are 90 photo processors in Washington County that the agency visits annually.

Once photo processors have implemented silver BMPs, they don’t typically backslide. The economic return from selling recovered silver is an attractive incentive for keeping the metal out of wastewater. Some shops have used their silver recovery money as their employees’ Christmas party piggy bank.

The Unified Sewerage Agency participates in the Pollution Prevention Outreach (P2O) team, a group of Portland-area agencies which collaborate on P2 projects. The agency tries to attend P2 events in order to gain information.

Tools for Incorporating P2 into Pretreatment
Judy Kennedy: Incorporating P2 into pretreatment programs need not involve a lot of extra work. BMPs and spill prevention plans required in local sewer ordinances are vehicles for integrating P2 into pretreatment. Examples of BMPs include inspection and maintenance activities, secondary containment, and silver recovery from photo processing wastewater.

Under federal pretreatment regulations (40 CFR 403.12 {p}), industries with discharge permits must notify POTWs and their state hazardous waste authority of discharges of substances classified as hazardous wastes by federal regulations. As part of the notification requirement, industrial dischargers must certify that they have programs in place to reduce the volume and toxicity of hazardous waste generation to the extent economically practical.

POTWs may require industrial dischargers to prepare spill prevention plans (40 CFR 403.8) as part of their discharge permits. Under categorical discharge regulations, solvent management plans can be required of some sectors, such as metal finishing. The regulations permit mass-based local limits and concentration limits to encourage volume reductions of hazardous substances.

Under Washington’s domestic sewage exclusion regulations, certain dangerous wastes that are treatable may be discharged to POTWs, if mixed with wastewater. Such wastes must be biodegradable and must comply with local discharge limits. Before a permit authorizing such discharges can be issued, pollution prevention measures must be implemented where feasible. The domestic sewage exclusion requirements apply to all classes of hazardous waste generators.

P2 and Pretreatment Programs Working Together
Hugh O’Neill: In developing P2 approaches to protecting water quality, the further upstream that solutions are applied, the more benefits accrue, but there are always tradeoffs.

When can P2 and pretreatment programs work together? There are numerous opportunities, including: 1) Planning of a new or expanded industrial facility, 2) Crisis such as a treatment plant upset caused by toxics, 3) Imposition of new discharge limits, 4) Permit renewal, 5) Changed level of concern over an individual pollutant, 6) Industrial sector campaign, or 7) Publication of a BMP manual.

Incorporating P2 into water quality protection efforts has a better likelihood of success if process expertise is available, a facility uses water or energy-intensive processes, the facility is motivated by discharge capacity constraints, and/or a legal deadline is approaching.

Regulatory strategies include requiring a best available technology (BAT) study that includes a P2 evaluation, a zero discharge study, or a P2 evaluation that contains a "must do" provision.

A good example of a BAT evaluation was Novation, a Spokane electroplater that was discharging 40,000 gallons of wastewater per day. The company was seeking a discharge permit modification to triple its flows. Through the Toxics Reduction Engineer Exchange (TREE) program, Ecology performed an evaluation and provided technical assistance. After implementing recommendations, the company cut its discharge below 8,000 gallons per day and saved $100,000 per year. No permit modification was necessary. For water quality permit managers, the evaluation approach reduces workload, makes P2 and compliance an easier sell, increases the effectiveness of permits, and identifies the true costs of inefficiency.

P2 can be required through a BAT evaluation performed as part of the NPDES permitting process, required for discharges to surface bodies of water. This is accomplished through identifying sources of water pollutants and P2 alternatives, performing technical and economic analyses, and setting priorities and schedules for Top 10 P2 opportunities.

In February 1999, Ecology finalized a renewed NPDES permit with "must do P2" provisions for the Tesoro oil refinery, the first permit of its kind. Factors that led to the "must do P2" approach were lackluster implementation of measures identified in the refinery’s state-required P2 plan, an outdated existing BAT evaluation, a substantial public interest in requiring P2, and a legal opinion that P2 could be included in the All Known, Available and Reasonable Methods of Prevention and Treatment Technologies (AKART) evaluation process used in Washington for BAT studies. Additionally, the refinery is a high profile facility, its NPDES permit was up for renewal, the persistent, bioaccumulative toxics (PBT) issue has emerged, and environmental groups applied pressure to include strong prevention measures in the new permit. (For more information about this permit, contact Stan Springer at Ecology, 360-407-6723, sspr461@ecy.wa.gov)

The basics of joint P2/water quality strategies are:

Contacts Resources

P2 & Pretreatment Resources

Discussion
Issues raised in discussion included industrial laundries and marketing P2 to companies.

Industrial Laundries: Chris Wiley of PPRC said industrial laundries are a unique communications channel for delivering P2 messages to industry. (See PPRC’s resources for industrial laundries at http://www.pprc.org/pprc/sbap/laundry.html.) A proposed categorical pretreatment standard has been withdrawn by EPA after the agency concluded that few of the pollutants in laundry discharges pass through POTWs. (See http://www.epa.gov/ostwater/Rules/laundry/finaction.html for more information.)

Marketing: A question that came up is how far agencies can push companies to adopt P2 measures. Ying Fu of Ecology suggested that agencies visit companies to encourage them to explore zero discharge, show them case studies, and point out the economic benefits of P2.

 

dot WATER EFFICIENCY: OVERVIEW OF OPPORTUNITIES

Facilitator:
  Ray Hoffman
    Seattle Public Utilities
    206-233-5008,
ray.hoffman@ci.seattle.wa.us
    Web: http://www.ci.seattle.wa.us/util/RESCONS/default.htm

The Bottom Line
Water efficiency makes sense for social, environmental, legal and economic reasons. Endangered species listings are forcing the Northwest to re-examine its management of water resources. Efficiency can be a cost-effective way to relieve pressure on streams and aquifers, while deferring costly projects to develop new water supplies. Marginal cost pricing is a tool to help customers understand the true cost of water and use it more efficiently.

Ray Hoffman: The shift from incinerating solid waste to recycling it was a paradigm shift. In the same way, a paradigm shift is occurring with water efficiency. "Efficiency" is perhaps a preferable term to "conservation," since "efficiency" does not carry the quality of life baggage that the word "conservation" carries.

Why should Northwesterners care about water efficiency? There are four reasons: 1) Social, 2) Environmental, 3) Legal, and 4) Economic.

Social: Efficient use of resources looks after the interests of future generations. Thrift is an American value.

Environmental: The thinking about conserving water has changed because of greater awareness of habitat protection issues. For example, dams once were viewed as a way to conserve water, because water flowing out to sea was viewed as a wasted resource. However, healthy stream flows are essential for fisheries. Now, serious consideration is being given to removing dams to allow rivers to flow freely for the benefit of salmon.

Legal: Endangered species listings of salmon and other fish runs are forcing the Northwest to re-examine its management of water resources. Hydroelectric generation, water supply dams, and groundwater withdrawals all affect salmon. Seattle Public Utilities obtains 95 percent of its water supply from the Cedar and Tolt rivers, and supplies 75 percent of King County’s water needs. Water conservation is evolving toward integrated, comprehensive programs to minimize waste without significantly affecting quality of life. For example, replacing all the toilets in King County with efficient models would save 12 million gallons per day, about 8 percent of the water consumed by Seattle and the communities to which it wholesales water. Installing efficient clothes washers would double those savings, and ending summer lawn watering would double them again.

Economic: How do businesses make money? They can either increase prices or cut costs. Water efficiency cuts costs.

Efficiency is an alternative resource for supplying new water needs. Efficiency measures that cost less than new water supply projects can serve new water needs at a lower cost to the ratepayers. Additionally, water efficiency measures can be implemented in a modular fashion as needed, avoiding the need to tie up capital in a large supply project. Another benefit to water efficiency is that it can bring certainty to long-term water supply planning.

While the need to use water efficiently may seem counterintuitive west of the Cascades, the Seattle area is short on water storage capacity. Moreover, the lowest amount of rain falls during the summer, when demand peaks. Tucson gets more summer rainfall than Seattle does.

Ten years from now, golf courses will be irrigated with reclaimed water. Inefficient toilets will be out of service, horizontal-axis clothes washers will be commonplace, and households and businesses will have a better handle on how much water they use. Water suppliers need to make consumption visible to customers. Bills are a good way to let customers know how much water they’re using and how much they’re using compared to the same period in the previous year. Seattle Public Utilities tells its retail customers how much they’re using in both cubic feet and gallons.

Discussion
Issues brought up in discussion included calculating efficiency potential, water efficiency’s value to POTWs, and water pricing.

Efficiency Potential: Hoffman said that efficiency potential is calculated by determining how much water is sufficient for specific purposes.

Value to POTWs: Judy Kennedy of Ecology said that water efficiency can benefit POTWs by reducing hydraulic loading and extending their treatment capacity.

Water Pricing: Marginal cost pricing of water sends a price signal that gives customers accurate information on the costs of using water inefficiently. Hoffman said knowing the marginal cost of water, the cost of the next increment of supply, allows water utilities to compare the cost of freeing up new supplies through efficiency or developing new supplies with wells, pumps and pipelines. Seattle Public Utilities uses inverted block rates, in which a higher rate per hundred cubic feet (ccf) is charged for the next increment of water use. In other words, the more you use, the more you pay per unit of water. (One ccf is equal to about 750 gallons.)

In order to get efficiency messages across, Hoffman said it’s important to help consumers focus on bottom-line water costs rather than the rates they pay per unit.

From a water quality perspective, Judy Kennedy said it is cheaper to get a pound of pollutant out of 1,000 gallons of wastewater than out of 10,000 gallons, because fewer treatment chemicals are needed.

 

dot WATER EFFICIENCY PART 1: P2 EXAMPLES

Discussion Participant:
  Christa Colouzis
    Washington Department of Ecology
    425-649-7143,
cboe461@ecy.wa.gov
    Web: http://www.wa.gov/ecology

The Bottom Line
The Toxics Reduction Engineer Exchange (TREE) program has helped companies in Washington analyze and implement pollution prevention opportunities that reduce water waste, toxic discharges and costs.

Presentation Christa Colouzis: Ecology’s TREE program offers intensive technical assistance for companies that need a site-specific technical and economic analysis of pollution prevention opportunities. Ecology has completed its fifth TREE project, which took place at Basin Frozen Foods, a potato processor in Warden, Wash. (See Ecology press release on this project at http://www.wa.gov:80/ecology/pie/1999news/99-063.html.)

The processor proposed tripling its wastewater discharge in order to add a french fry production line. The plant’s discharge permit limited its discharge to 350,000 gallons per day. The problem was that Warden’s wastewater treatment plant could not handle the proposed additional load. Also, the community did not have a water right for additional water withdrawals to serve the plant expansion.

The TREE approach was implemented as an alternative. On Ecology’s first visit to the plant, assistance providers noticed relatively small inefficiencies that company managers had simply overlooked because of the everyday press of production. For example, a hose left on continuously was used to push processing waste out of a trench. An obvious alternative was removing it with a shovel. Relatively small efficiency measures cut consumption by 80,000 gallons per day. While employees may resist new work procedures designed to improve efficiency, it’s up to the companies to require that they be carried out.

Basin Frozen Foods’ attitude was helpful. Company managers saw Ecology as helpers, not enforcers, and were cooperative. Furthermore, the company was highly motivated to free up more water through efficiency, because it had a contract with a major food producer to supply the french fries and a building to house the new french fry line had already been constructed.

Other companies that have received TREE services have achieved cost reductions. For example, Industrial Plating in Seattle, a job shop metal finisher, saved $80,000 per year on hazardous waste generation costs by implementing efficiency measures. Additionally, the company reduced its process chemical costs. A problem that can arise is that electroplaters which reduce their water consumption may violate discharge standards based on concentrations, because pollution is more concentrated in a lower volume of wastewater. The way Industrial Plating resolved this issue was to reduce the frequency with which it treated its final discharge and to increase treatment duration, so the treatment results were improved.

Discussion
Issues that arose in discussion included the costs of production downtime to install efficiency measures, discharge limits, salmon implications, analysis tools, and tapping employees for efficiency ideas.

Downtime: A barrier to efficiency measures is that companies in high production mode may not want to take the time to install efficiency measures, even when they realize they will achieve cost savings. An Oregon bakery, for example, was unwilling to take time even to plug up leaks, even though they were costing the company $1,000 per month. Colouzis said that making sure companies know the costs of waste and are familiar with the efficiency measures that can minimize waste is still beneficial. When the time comes that they really need to cut costs, they’ll know what to do. Plus, it helps to point out the savings that competitors are enjoying through efficiency.

Discharge Limits: One way to resolve the potential for violating discharge standards based on pollutant concentrations, such as milligrams per liter, is to impose a mass-based standard instead, such as pounds per day. Or, mass-based limits can be imposed in addition to concentration-based limits.

The city of Everett required an electroplater to perform a P2 survey. The company had been in significant non-compliance with a discharge standard for two years. As a result, the company replaced a chemical that contained zinc. The city’s sewer ordinance gave the POTW the authority to require the survey and get the company back into compliance.

If a POTW doesn’t have local discharge limits, a state discharge permit writer has more freedom to formulate water quality requirements. If a judgment is made, for example, that a certain concentration based on a certain flow will not harm the POTW, a mass-based limit can be imposed.

Salmon Implications: In the context of a watershed, cumulative impacts of discharges on a river have implications for threatened and endangered salmon runs. Many states, including Oregon and Washington, are under court orders to prepare Total Maximum Daily Loads (TMDL) cleanup plans for bodies of water that do not meet federal water quality standards. (For more information about TMDLs, visit http://www.epa.gov/OWOW/TMDL.)

Analysis Tools: Basic cost accounting for water, energy and labor are part of the TREE service. Ecology has developed the PEAKART tool to help permit writers incorporate P2 into discharge permits for industries with rinsing operations. (To learn more about PEAKART, visit http://www.ecy.wa.gov/programs/hwtrpeakart)

Employee Ideas: Colouzis said employees often have good ideas for eliminating inefficiencies. A safe environment for workers to step forward with their ideas is essential, so workers are not afraid to speak up.

Four TREE projects are being carried out this year. They include two metal finishers, a parts plater and a circuit board manufacturer. The other two are a dairy products company discharging to a salmon-bearing creek and a seafood processor with fecal coliform in its discharge water.

Water Efficiency Resources:

 

dot WATER EFFICIENCY PART 2: WATER REUSE

Facilitator:
  Tom Fox
    King County Department of Natural Resources
    206-296-5279,
tom.fox@metrokc.gov
    Web: http://splash.metrokc.gov

The Bottom Line
Water reuse is not a universal solution, but can be used in place of fresh water for some uses, conserving fresh water for environmental needs.

Presentation Tom Fox: Per-capita water withdrawals have declined in the U.S. since 1980 as a result of increased efficiency and water reuse. (Between 1950 and 1980, per-capita withdrawals rose from 1,185 to 1,953 gallons per day. Between 1980 and 1995, per-capital withdrawals fell to 1,500 gallons per day, according to the 1998 Statistical Abstract of the United States.)

There is a difference between reclaimed water and "grey" water. Reclaimed water is wastewater that has been treated to a level at which it’s suitable for beneficial uses. Grey water is residential wastewater from washing activities such as sinks and showers. Grey water does not include wastewater from toilets.

Seasonal distribution of precipitation influences timing and quantity of water demand. Rainfall patterns differ widely depending on regional climates. On westside Northwest cities, rain falls mainly in the autumn, winter and spring, but demand peaks in the summer. This is significant because reclaimed water could be substituted for fresh water for some uses during peak demand periods.

Reclaimed water is commonly used in Arizona, California, Texas, Florida and Maryland for irrigation and for industrial processes.

What lessons can the Northwest learn from other areas? Reclaimed water is not a universal solution for meeting water supply needs, but it can replace fresh water in some cases. By substituting reclaimed water for uses such as irrigation, stream flows and wetlands can be conserved, benefiting fish and wildlife.

Discussion
Issues that came up in discussion included water rights, delivery infrastructure, and incentives.

Water Rights: A number of questions came up in regard to water rights. By using reclaimed water instead of returning it to rivers, are downstream water rights being infringed? The same question could apply to water efficiency. State laws differ. In Washington, water users may not have any legal obligation to discharge. In Texas, however, water users have discharge obligations. Are water rights needed to use reclaimed water? Under Washington law, POTWs are "producers" of reclaimed water, and have the exclusive right to distribute reclaimed water as they choose.

Delivery Infrastructure: Washington law allows the use of streams to convey reclaimed water. Reclaimed water also can be delivered by pipe.

Incentives: One incentive to using reclaimed water for non-potable uses is inability to obtain rights to withdraw fresh water for those uses. A related incentive would be the ability to sell a fresh water right if reclaimed water is available.

Water Reuse Resources

 

dot WATER EFFICIENCY PART 3: TOOLS YOU CAN USE

Discussion Participant:
  Al Dietemann
    Seattle Public Utilities
    206-684-5888,
al.dietemann@ci.seattle.wa.us
    Web: http://www.ci.seattle.wa.us/util/RESCONS/default.htm

Handouts Available

The Bottom Line
Since 1989, per-capita water use in the Seattle Public Utilities’ service area has declined, on both a peak and an annual average basis. There are significant opportunities for using water more efficiently in Seattle. Four strategies are being used: pricing, plumbing codes, incentives and leak repair.

Presentation
Al Dietemann: Reducing summer demand peaks through water conservation is important for providing cost-effective water supplies. One element of promoting conservation is to get people to stop thinking of conservation as deprivation, and to view it as long-term efficiency.

Seattle Public Utilities provides water to 1.3 million people within the city and in surrounding communities. Per-capita annual demand and per-capita peak demand have been reduced, mainly through residential water efficiency. Since 1989, annual average consumption has fallen 30 million gallons per day (MGD). Per-capita consumption has fallen 20 percent since 1989.

Residential use accounts for the bulk of water use in Seattle Public Utilities’ service area. Of the average annual consumption of 151 MGD, single-family residential accounts for 44 percent, multi-family residential 16 percent, non-residential 31 percent, and non-revenue usage 9 percent. (For details on water usage in Seattle Public Utilities’ service area, visit http://www.ci.seattle.wa.us/util/services/water/average_use.htm.)

Many people believe that bathing is the largest use of water in and around the home. Flow recorders placed on 110 customers found that wasn’t the case, however. During the summer, the data from the recorders showed that 58 percent of water consumed was for landscape irrigation.

Seattle’s goal is to save 35 MGD by 2005. Four strategies will be employed:

Measures that have worked most effectively in cutting demand have been pricing structures and leak repairs.

Seattle is one of the largest water utilities in the U.S. that offers financial incentives for installing commercial and industrial water efficiency measures. Businesses can receive rebates for as much as 50 percent of the cost of an approved conservation measure. Incentives are offered for cost-effective efficiency measures for cooling, cleaning, toilets, irrigation, laundry, and water recycling applications. It’s worth the ratepayers’ while to pay businesses to install efficiency measures if the cost of saving water needed in a growing community is less than the cost of developing new supplies. Saved water is a resource which can defer costly investment in new supplies for 15 years.

The current price of cost-effective conservation for peak supplies is $2.41 per ccf. Conservation measures purchased at that price or below would free up 31 MGD of wasted water for other uses.

The utility employs extensive market transformation, education and outreach programs. For many businesses, water is a small cost of doing business, so the costs of wasteful water use often go unnoticed. An example of market transformation is the WashWise program, which provides buyers of efficient clothes washers with mail-in rebates. (To find out more about WashWise, visit http://www.ci.seattle.wa.us/util/RESCONS/washwise/default.htm.)

Pricing is a tool that can induce water efficiency. Most POTWs charge a flat rate for sewer service, which does not communicate a clear price signal about the costs of wasteful water use. A better approach would be to tie sewer service charges to water consumption.

Design of Seattle’s efficiency programs has been informed by surveys and focus groups that identify motivators for saving water. The kinds of help businesses want include information, financial assistance, technical assistance, and employee education.

The utility plans to market the use of reclaimed water in the Duwamish industrial area. Reclaimed water would need to be oxidized, coagulated and filtered before it could be delivered to customers. The West Point Treatment Plant produces more than 500,000 gallons per day of reclaimed water usable for irrigation or industrial processes.


 

Thursday, June 17, 1999

dot WELCOME and INTRODUCTIONS

Catherine Dickerson of PPRC asked participants to develop creative marketing slogans for their programs. Among the offerings were:
  • You Too Can Do P2
  • Walk Softly Because We Carry a Big Stick
  • It’s Efficiency, Stupid
  • Just Don’t Do It
  • Give a Hoot, Don’t Pollute
  • Do No Harm
  • I’m From the Government and I’m Here to Help

 

dot PRELIMINARY DISCUSSION

Participants engaged in brief preliminary discussions about marketing and energy.

Marketing: Judy Kennedy said Ecology plans to revamp its web site so that it’s a useful tool for two-way information exchange. Electronic materials are more cost-effective than printed materials. David Kunz said Oregon DEQ is updating its web site.

Energy: Lawrence Berkeley Laboratory has a "home energy saver" web site that allows homeowners to see how much efficiency measures will reduce their annual energy bills. Users enter their ZIP codes and are shown their current estimated annual energy bills and cost reductions they can achieve through heating and cooling, water heating, lighting and appliance efficiency measures. (Visit Home Energy Saver at http://hes.lbl.gov.)

The Union of Concerned Scientists (UCS) has published a book, "The Consumers Guide to Effective Environmental Choices," that helps consumers set priorities when weighing environmental impacts of their purchasing decisions. The book analyzes the relative impacts of common purchases. For example, transportation choices have far greater impact than choosing between paper and plastic grocery bags. (To find out more about the book, visit UCS at http://www.ucsusa.org/less/index.html.)

Energy Star: Energy Star televisions and video cassette recorders are becoming the industry standard. A key feature of Energy Star TV’s and VCR’s is that they reduce electricity "leakage" by 70 to 75 percent. Leakage is the phenomenon of electronic appliances consuming electricity when switched off. Lawrence Berkeley National Laboratory estimates that electricity leakage from homes consumes 60 million megawatt-hours of energy annually in the U.S., accounting for 7 percent of all residential electrical energy use and resulting in emission of 30 million tons of carbon dioxide per year. (To find out more about leaking electricity, visit Lawrence Berkeley Lab at http://eetd.lbl.gov/leaking.)

 

dot EPA HEADQUARTERS UPDATE

Discussion Participant:
  Dave Kling
    Office of Prevention, Pesticides and Toxic Substances
    202-260-3755,
kling.dave@epa.gov
    Web: http://www.epa.gov/p2

The Bottom Line
Numerous activities are underway at EPA Headquarters, including the PBT initiative, children’s health protection programs, a new information office, and a chemical right-to-know initiative.

Presentation
Dave Kling: The presentation covered numerous topics on programs and projects under way at headquarters.
Recommended Readings: "Natural Capitalism: Creating the Next Industrial Revolution" is a new book written by Paul Hawken, author of "The Ecology of Commerce;" Hunter Lovins, president of the Rocky Mountain Institute; and Amory Lovins, research director of the Rocky Mountain Institute. The premise of regulation today is to stop bad actions from occurring. The book discusses how to promote good actions, and encourage products and services that restore rather than damage the environment.

The Wall Street Journal published an article on June 9, 1999, entitled "When Business Plans and Real Worlds Clash." The article discusses the value of one-on-one assistance. Businesses want more than information. They want to interact with assistance providers. The jury is still out on whether the web can fully replace direct personal service.

"Aiming for Excellence:" EPA Administrator Carol Browner has asked the agency to promote innovative approaches to achieving excellent environmental results. "Aiming for Excellence," a report due out this summer, will benchmark 25 to 40 facilities.

P2 Gains: In both the public and private sectors, the preventive approach to environmental management appears to be gaining ground. EPA program managers are seeing the need to incorporate prevention into programs. More policy documents are pointing out the value of prevention for achieving environmental results. An example is the Enterprise for the Environment report released in 1998 (full text of the report is available at http://www.csis.org/e4e). The Global Environmental Management Initiative (http://www.gemi.org) has issued a report, "Environmental Improvement Through Business Incentives."

EPA’s initiative to reduce pollution from persistent, bioaccumulative toxins (PBTs) is the largest non-legislated, cross-media project the agency has ever undertaken. A number of large manufacturers, including Dow Chemical, BP Amoco, Monsanto and Rayonier are working with the Natural Resources Defense Council on a P2 pilot project.

Compliance: EPA is focusing more resources on enforcement. One desired outcome is building P2 into supplemental environmental projects that result from enforcement actions.

Protecting Kids: EPA has opened a children’s health protection office. In January 1999, EPA and the U.S. Department of Health and Human Services began an initiative to fight childhood asthma. (To find out more, visit http://www.epa.gov/children.)

Information Office: EPA has undertaken an information initiative, intended to make it easier for the public to obtain data, in both raw and interpreted form. There will be offices of information services, information access, and information planning and resources. (To find out more, visit http://www.epa.gov/itop.)

Chemical Right-to-Know: The goal of the Chemical Right-to-Know program is to expand the availability of basic toxicity data for high production volume chemicals. Under this initiative, chemical manufacturers have been invited to voluntarily provide basic toxicity data of their high production volume products. Testing will be initiated for chemicals for which information is not provided voluntarily. Additional reporting will be pursued for PBT’s and chemicals of special concern to children’s health. (To find out more, visit http://www.epa.gov/chemrtk.)

Urban Sprawl: Under the Better America Bonds proposal, $700 million in tax credits would support $9.5 billion in bonds for state, local and tribal governments to buy open space, protect water quality, and clean up brownfields.

Technical Assistance: Questions have been raised about the value of providing businesses with technical assistance and duplication of programs. Small Business Development Centers have asserted that they can provide better environmental technical assistance to business than EPA. The National Small Business Regulatory Assistance Act was introduced in Congress in January 1999. The legislation would direct Small Business Development Centers to carry out voluntary compliance and technical assistance services. The legislation is numbered HR 296 and is sponsored by Rep. John E. Sweeney of New York. (To view the text of HR 296, visit Thomas at http://thomas.loc.gov and type the bill number in the search function.)

The Pollution Prevention Resource Exchange (P2Rx) is demonstrating that programs can work together and share information. While a national P2 information network is still a ways off, progress is being made. (To find out more about P2Rx, visit http://www.epa.gov/p2/p2rxdir.htm.)

PBT Initiative: The initiative takes a holistic approach to reducing health and environmental risks from PBT’s. Each of EPA’s media programs will be responsible for preparing and carrying out action plans to address PBT’s.

The initial list of PBT chemicals are the 12 Level 1 substances in the U.S.-Canada Binational Toxics Strategy developed for the Great Lakes. Comments will be sought in the next few months on proposed additions to the PBT list. In a related initiative, EPA is seeking reduction of 53 PBT’s discharged in regulated hazardous waste.

This year, congressional set-asides reduced PBT funding from $9.2 million to $5.5 million, most of which was allocated to EPA Headquarters. A total of $9.2 million has been proposed for the fiscal year 2000 budget. There is talk of shifting more PBT funding to the regions and states. (To find out more about the PBT initiative, visit http://www.epa.gov/pbt.)

Kling said the need for more cross-media activities can build interest in P2 among federal and state media programs.

Environmental Justice: EPA is reviewing accomplishments of its environmental justice program for the last three years. A total of $4.2 million has been proposed for fiscal year 2000. EPA wants to link environmental justice funding to economic development.

Environmental Accounting: EPA will select one of the Big Five accounting firms to evaluate environmental cost accounting from a business value standpoint over the next year.

 

dot NATIONAL POLLUTION PREVENTION ROUNDTABLE (NPPR) UPDATE AND DISCUSSION

Discussion Participants:
  David Wigglesworth
    Alaska DEC and at-large NPPR board member
    907-269-7582,
dwiggles@envircon.state.ak.us
  Marianne Fitzgerald
    Oregon DEQ and Region 10 representative on NPPR board
    503-229-5946, fitzgerald.marianne@deq.state.or.us

The Bottom Line
NPPR is an opportunity for P2 programs to work together on issues of mutual interest. NPPR workgroups are valuable for working with people sharing common interests.

Presentation
David Wigglesworth & Marianne Fitzgerald: The National Pollution Prevention Roundtable (NPPR) was started in1985. The organization brings together organizations, constituents and individuals to collaborate on pollution prevention, resource efficiency and environmental management.

NPPR has workgroups that produce reports and organize sessions at NPPR conferences. Fitzgerald said the most value she has received from NPPR has come from participating in workgroups. Workgroups are an opportunity for P2 practitioners to work with others who share their interests. Fitzgerald said she is on the regulatory integration workgroup. An example of this workgroup’s activities is its work with the State and Territorial Air Pollution Program Administrators and the Association of Local Air Pollution Control Officials on MACT standards. The education and the local government workgroups have produced training compendia.

Fitzgerald said NPPR needs input from agencies in Region 10, and urged local governments to get involved in the local government workgroup. (To find out more about the local government workgroup, contact Margaret Nover at the Portland Bureau of Environmental Services, 503-823-5565, margaret@bes.ci.portland.or.us.)

About a year ago, NPPR started focusing more on international activities, causing state government members to raise questions about the benefits of membership. NPPR is preparing a strategic plan. Four values informing the process are: 1) Supporting membership, 2) Expanding P2’s influence, 3) Defining new paths for P2, and 4) Supporting activities with stable funding and staff. One of the issues the strategic plan will address is lack of communication between workgroups. By setting out a vision, the plan could get all the workgroups on the same page.

A "scrapbook" promoting the benefits of P2 programs is being prepared. NPPR is looking for contributions that will document how P2 programs have reduced pollution and costs.

Other NPPR activities underway include:

  • An advocacy effort seeking an increase in Pollution Prevention Incentives for States grants from $5 million to $20 million annually.
  • Cultivation of an advisory board for fund-raising, so that activities are not driven by grant funders.
  • Building relationships with media associations, in part to work with them to incorporate P2 into media programs.
  • An advocacy effort seeking revision of the Pollution Prevention Act of 1990.
  • Expanding membership. An issue under discussion is giving voting membership to individuals and non-profit organizations. A question framing the discussion over expanding membership is NPPR’s identity. Is it a technically-oriented or policy-oriented organization?

The next two NPPR conferences will be held Nov. 17-19, 1999 in Santa Fe, N.M., and March 21-24, 2000 in Boston.

Discussion Issues raised in discussion included the value of NPPR membership and legal problems that could be caused by NPPR’s advocacy activities. Freda Tepfer of Snohomish County said her office dropped its membership because it didn’t see any value to it. Tepfer expressed concerns about advocacy activities, because of the legal questions that could be raised if agency employees are perceived as speaking for their employers.

To find out more about NPPR, visit http://www.p2.org.

 

dot USING MARKET TOOLS TO ACHIEVE P2: OVERVIEW OF OPPORTUNITIES

Facilitator:
  Rob Greenwood
    Ross & Associates
    206-447-1805,
rob.greenwood@ross-assoc.com
    http://www.ross-assoc.com

Handout Available

  • "Beating the Competition: Utilizing Market-Based Instruments in a Competitive World," outline of Rob Greenwood’s presentation.

The Bottom Line

Globalization has greatly increased the fluidity and power of markets. In this new environment, agencies should update their approach for obtaining environmental outcomes by using market-based instruments. Agencies must think strategically and broadly in using these instruments, and consider carefully the needs and drivers of the audiences they’re trying to influence.

Presentation

Rob Greenwood: "The Lexus and the Olive Tree," a book by New York Times foreign affairs columnist Thomas Friedman, describes how globalization has become the dominant economic paradigm. (To find out more about Friedman’s book, visit http://www.lexusandtheolivetree.com/index.html.)

This shift is relevant to the work of P2 practitioners. A paraphrased excerpt from the book illustrates the relevance: If the Cold War were a sport, it would be a sumo wrestling match – a lot of ritualistic posturing, but little contact until the end of the match is near. If globalization were a sport, it would be a 100-meter dash, run over and over again. As a result of globalization, barriers to trade and money flows have fallen, markets are becoming predominant, and the process of commoditization has accelerated tremendously. Innovations quickly become commodities distinguished only by price. Businesses must sell their commoditized products and services at competitive prices or close their doors.

The nation’s environmental regulatory system is stuck in a Cold War paradigm of hierarchies and barriers that color relationships between state and federal agencies, between agencies and non-government organizations, and between agencies and industries.

It’s critical for agencies to step out of the sumo wrestling ring and consider market-based instruments for achieving environmental objectives. Just remember: once you’re out of the ring, you’ll be running 100-meter dashes repeatedly. The use of market-based instruments will put agencies in a different environment.

What are market-based instruments? They are tools that harness market motivators to improve environmental outcomes. Lower costs and improved product quality are examples of market motivators. Don’t just think of profits as the only market driver, however. Think more broadly of what drives business audiences.

Environmental management intervention strategies take several forms, including:

  • Command and control – The conventional method of compelling environmental performance through standards and prohibitions.
  • Economic – The use of taxes, fees and subsidies to discourage or reward behavior. The use of fees to fund environmental programs can result in a paradox, however: the more pollution is reduced, the lower the amount of fees collected by agencies to support programs aimed at reducing pollution. Technical assistance is a subsidized service designed to fix market failures such as lack of information.
  • Creating Markets – Reducing pollution by creating markets in pollution. Examples of this approach are the sulfur dioxide emissions trading system set up under the Clean Air Act, and effluent trading, which will be piloted in the Boise River watershed. Such programs have potential but their application may be narrow.
  • Demand Intervention – Influencing purchasing decisions through tools such as labeling, education, disclosure requirements, and certifications. An example of certification is the "green milk" certification program for dairy farms in the Chesapeake Bay watershed. A 5-cent premium on each half-gallon of certified milk funds water pollution prevention projects on participating dairy farms. Sales of "green milk" have increased significantly. (To find out more about Chesapeake Milk, visit http://www.eqinitiative.com.) Another example is public agencies building demand for green products by buying them.
  • Liability – Increasing the risks of environmentally harmful behavior through legal and financial means such as torts, Superfund liability, and performance bonds. Permits implicitly have performance bond elements.

For market-based instruments to succeed, the advantages of using them must exceed the costs of implementing desired behavior and associated transaction costs. The advantages that market-based instruments can bring include:

  • Time – Businesses running the 100-meter dash to stay competitive will value a regulatory approach that accommodates their need to change products and processes quickly in order to keep up with quickly changing markets
  • Predictability – Likewise, knowing what is expected in environmental performance helps businesses plan more effectively and reduces risks of losing out in the market.
  • Profit – Higher margins are garnered by selling more products, increasing prices, and/or cutting costs.
  • Image – Good will has value for attracting customers.

The four key audiences that businesses must play to in implementing market-based instruments are:

  • Consumers
  • Communities
  • Regulators
  • Financial Institutions

Costs of changing behavior must be considered carefully. Net present value and payback are two methods that businesses use to assess the value of environmental and other investments. Don’t forget opportunity costs. While P2 may yield a high return, other investments may yield higher returns. Industries have varying hurdle rates, the minimum required return for a capital investment to be considered. Even if a P2 investment will yield an attractive return, odds are against it being considered if the projected return is below the hurdle rate. Transaction costs of environmental initiatives are an important consideration. Some, such as registering an environmental management system to the ISO 14001 standard, can be quite high.

Think broadly of audiences and drivers when promoting market-based instruments. Think clearly about whom you’re trying to influence.

 

dot USING MARKET TOOLS PART 1: PROCUREMENT FOR P2

Discussion Participants:
  Shirli Axelrod
    Seattle Public Utilities
    206-684-7804,
shirli.axelrod@ci.seattle.wa.us
    http://www.ci.seattle.wa.us/util
  Karen Hamilton
    King County Procurement Services Division
    206-296-4317, karen.hamilton@metrokc.gov
    http://www.metrokc.gov/procure/green

The Bottom Line

  • Take practical steps when implementing an environmentally responsible purchasing program. Work directly with people willing to implement changes rather than relying solely on written policies. Use resources already available. Pre-qualify vendors that supply green products.
  • Mandates won’t bring lasting change. Work cooperatively with key personnel in agency departments to get them to test well researched green products, and share information.

Seattle’s Environmental Purchasing Program
Shirli Axelrod: The city of Seattle is developing an environmental purchasing program. The decision to do so is the product of an evolutionary series of steps. Like many communities, the city has a recycling program. A municipal ordinance passed a decade ago calls for the purchase of reusable, recyclable and recycled-content products. Since then, the city has advanced to buying products that are more durable and less toxic. In January 1999, the Seattle City Council adopted an environmental management program addressing energy, water, waste reduction, fleets, grounds maintenance, and environmentally responsible purchasing.

An example of how the purchasing element is being implemented is lubricating city vehicles. The city does not buy oil directly, it buys a lubrication service from a vendor. In selling a service for a set price, the vendor has an incentive to reduce waste and thereby increase financial return.

Below are tips for carrying out an environmentally responsible purchasing program:

  • Tip: Work with people who are willing to implement changes. That works faster than relying solely on written policies that few people read.
  • Tip: Don’t reinvent the wheel. Take advantage of resources that are already out there. For example, the TerraChoice Environmental Choice Program has a catalogue of products certified as meeting environmental criteria. (To find out more about TerraChoice, visit http://www.environmentalchoice.com.) There is a listserve for environmentally preferred purchasing, called EPPNET. (To find out more about EPPNET, visit the Northeast Recycling Council at http://www.nerc.org. The listserve is not open to vendors.)
  • Tip: Contractors commonly develop pre-qualified lists of subcontractors that meet desired criteria. This approach can be applied to green procurement, by identifying and pre-qualifying vendors that will supply green products.
  • Tip: Be sure to deal up front with the "grave" issues in "cradle to grave" product cycles. For example, a supplier offered to take back aerosol spray cans after the city was done with them. On later investigation, however, the city found that the company was poking holes in the cans and emptying the contents into mixed waste drums. Today, the city manages the cans itself as hazardous waste.
  • Tip: Talk to building managers and maintenance crews. Ask them what cleaning products they use. Spread the word when good changes are made.

Discussion
Issues brought up in discussion included drivers for public agencies to institute green purchasing and alternatives to aerosol spray cans.

Drivers: The city is not under pressure by regulatory agencies to clean up its own house. However, it’s important for the public to see that public agencies are adopting behaviors that they are urging citizens to adopt. Engaging in behavior that is inconsistent with messages going out to the public is asking for bad publicity in the media and loss of credibility.

Aerosol Can Alternatives: The Unified Sewerage Agency in Washington County, Oregon buys spray lubricants in bulk, then charges sprayers in house. There is a hotel chain in Oregon that uses pump spray bottles for cleaners.

King County’s Environmental Purchasing Program
Karen Hamilton: In 1989, the King County Council enacted an ordinance requiring county departments to buy products with recycled content when practical. In 1994, the focus was broadened to environmentally preferred purchasing. What does that mean? Environmentally preferred products are those which have reduced impact on the environment and public health throughout the product’s life cycle, compared to competing products serving the same purpose.

The benefits of buying green products include cost savings, reduced energy consumption, improved worker safety, increased credibility with business, and building markets for preferred products. Below are tips for carrying out environmentally preferred purchasing:

  • Tip: Write a statement of intent.
  • Tip: Work cooperatively with departments to get them to try new products. Look for savings. Sending out used toner cartridges for remanufacturing saves the county $200,000 per year and the remanufactured cartridges last just as long as new cartridges.
  • Tip: Green procurement works best when purchasing offices work cooperatively with line departments. Actions put into effect solely through mandates won’t last long.
  • Tip: Share information among departments. Use e-mail. The county environmental purchasing program sends out a periodic Environmental Purchasing Bulletin describing recycled products and materials. (To find out more about the bulletin, visit http://www.metrokc.gov/procure/green/bulindex.htm.) Take department personnel out on field trips. Get different departments to communicate with each other.
  • Tip: Collect data to document outcomes.

Environmentally preferred products that the county uses include the following:

  • Recycled paper. Nearly 100 percent of purchased copy paper meets or exceeds county standards for recycled content. The predominant paper types that are purchased contain 20 percent to 30 percent post-consumer content.
  • Re-refined motor oil. Since 1992, re-refined motor oil has been used at the county’s Renton maintenance facility and in its solid waste operations. These agencies purchased nearly 10,000 gallons last year. Re-refined oil is being tested at the Ryerson transit bus support base. If the test is successful, all the transit support bases will start using re-refined oil.
  • Recycled anti-freeze
  • Compost
  • Lumber made of recycled plastic
  • Shredded wood mulch

In 1998, the county spent $1.6 million on paper products with recycled content and nearly $750,000 on non-paper products with recycled content. A total of $600,000 was saved through measures such as sending out toner cartridges for remanufacturing and recapping tires. The county has joined the Green Lights program and retrofitted the county administration building and court house with efficient lighting. The county is saving $18,000 on energy bills, plus it received a rebate from Seattle City Light.

The King Street Center, which houses the county’s transportation and natural resources departments, was built using green building criteria. Efficient lighting fixtures use get more work out of electricity. Collected rainwater will be used to flush toilets, reducing delivered water demand by an estimated 1.4 million gallons per year. The building has 32,000 square yards of carpeting remanufactured from old carpet tiles that were cleaned and repatterned. The cost of reused carpet was about half the cost of newly manufactured carpet. Walls were coated with low-VOC paint.

Costs must be considered across the life-cycle of a product. For example, lumber fabricated from recycled plastic works better than chemically treated wooden lumber in certain applications, such as fence posts. Plastic lumber costs more up front, but is more durable, thus reducing maintenance costs. (To find out more about King County’s experience with plastic lumber, visit http://www.metrokc.gov/procure/green/plastic.htm.)

Discussion Issues brought up in discussion included tradeoffs between capital purchase and maintenance budgets, various preferred products, how the county maintains a green purchasing ethic, links between green purchasing and salmon recovery, employee education, pressure from vendors selling non-preferred products, and life-cycle costs.

Budget Tradeoffs: In King County, line departments make the final decision on whether it makes sense, from a budget perspective, to buy an environmentally preferred product.

Various Products: Re-refined oil is produced by Evergreen Oil. King County sells off surplus computers. Washington state government has set up a computers for kids program in which surplus computers are refurbished in state prisons, then donated to schools.

Keeping the Ethic: The county sustains the green purchasing ethic by providing a service to line departments. The green purchasing staff has built relationships with key personnel within the departments, and provides education about preferred products backed up by thorough research.

Salmon Link: The county’s procurement division is included in discussions about internal practices affecting endangered salmon, such as landscape maintenance.

Employee Education: The procurement division participates in new employee orientations.

Pressure from Vendors: When King County began buying re-refined oil, vendors of newly refined oil were upset. They put pressure on department managers to continue buying their products, but there were no major political problems. Axelrod said ordinances backed up the city’s switch to preferred products.

Life-Cycle Costs: The county hasn’t performed a county-wide life-cycle cost analysis of environmentally preferred purchases, but individual departments have done the analyses for energy efficiency measures.

Environmentally Preferred Purchasing Resources

 

dot USING MARKET TOOLS PART 2: CERTIFICATION OR ECO-LABEL PROGRAMS

Discussion Participants:
  Carole Skeeters
    The Food Alliance
    503-493-1066,
skeeters@teleport.com
    http://www.thefoodalliance.org
  Larry Nussbaum
    Northwest Natural Resources Group (SmartWood affiliate)
    360-379-9421, larry@nnrg.org
    http://www.smartwood.org

Handout Available

  • The Food Alliance information packet

The Bottom Line

  • The Food Alliance supports sustainable agriculture through labeling that helps consumers find foods produced sustainably. The Food Alliance provides third-party certification and consumer education services.
  • SmartWood supports sustainable forestry through labeling that helps consumers find wood products produced sustainably. SmartWood provides third-party forest management and forest products chain-of-custody certification services.
  • A key issue for certification programs is credibility – standards that labels signify, independent verification of performance, and the potential for consumers being led astray by misleading claims.

The Food Alliance
Carole Skeeters: The Food Alliance (TFA) was started in 1994, and is a coalition of farmers, consumers, scientists, environmental advocates, and food distributors. The Food Alliance promotes sustainable agriculture in the Northwest by helping consumers find food products that meet sustainability standards. TFA conducts independent evaluation of farms seeking certification and TFA labels on their products.

For farm products to be certified and labeled, farm practices must comply with TFA standards in three areas:

  • Pest and disease management
  • Soil and water conservation
  • Safe and fair working conditions for farm employees

So far, food from 20 farms have received the TFA label. Certified products include both fresh and frozen fruits and vegetables. In the coming year, sustainably produced dairy and beef products may be certified. The Food Alliance operates a retailers program that provides point-of-sale information about certified foods at supermarkets, food stands and restaurants.

The Food Alliance’s work is informed by market research showing that a majority of consumers are willing to support sustainable agriculture by buying sustainably produced food. The research found that consumers fall into several categories in their attitudes toward sustainable agriculture. Seven percent were called the "true naturalists," people who buy only organic food and are willing to pay a premium for it. The "overwhelmed and unconcerned" make up 48 percent. In the middle are 45 percent, who believe their purchases make a difference and will support sustainable agriculture, if buying the products is convenient.

The Food Alliance is one of several organizations that provide food eco-labeling services, including standard-setting, compliance assurance, and education. Certification standards differ among the organizations. The Conservation Agriculture Network operates a Better Banana Project (http://www.rainforest-alliance.org/programs/cap/program-description2.html) under its Eco-OK program for tropical agriculture. California Clean is a certification project of the California Clean Growers Association for small family farms (http://www.californiaclean.com) meeting standards for pest management, agronomic practices, irrigation, and other farm operations. Core Values Northeast (http://www.corevalues.org) is a labeling program for Northeast apple growers using biologically intensive integrated pest management techniques.

In assessing farms for certification, The Food Alliance examines issues such as the following: Do they employ integrated pest management techniques such as cover crops, biological controls, and intercropping that encourages pest predators? If pesticides are used, are they used responsibly? Do farms have riparian buffers to protect streams? Do they take steps to prevent erosion of soils and nutrients into surface water, or leaching of contaminants into groundwater? Are workers provided training and good housing?

Discussion
Issues that arose in discussion included the potential for consumer confusion, price sensitivity, and benefits to farmers.

Consumer Confusion: The Food Alliance emphasizes education because there are many food labels, all of which signify different standards. For example, some food labeling programs cover only pest management issues. Food labeled as "sustainable" may not necessarily meet the definition of "organic." Education helps consumers understand what the label is telling them and exactly what they’re getting when they buy certified products.

Price Sensitivity: While many consumers may be willing to pay a premium for certified food, they may not be willing to pay a large premium.

Payback for Farmers: Farmers may not see financial benefits to participating in The Food Alliance program, but may see intangible benefits, such as consumer goodwill, networking with other growers using sustainable practices, and marketing assistance.

Sustainable Agriculture Resources

SmartWood
Larry Nussbaum: The SmartWood network is dedicated to reducing environmental damage caused by commercial forestry and supporting the positive impact of commercial forestry on local communities. SmartWood is a network of 13 non-government organizations that conduct independent evaluation of timberlands seeking certification and SmartWood labels on their products. The SmartWood seal of approval helps consumers find wood products that have originated in sustainably managed timberlands.

SmartWood started about 10 years ago by certifying tropical timberlands, then expanded to temperate and boreal timberlands. In 1993, the Forest Stewardship Council (http://www.fscoax.org) was founded as an independent accreditation agency for forest products certification programs worldwide. SmartWood and Scientific Certification Systems (http://www.scs1.com/forests.html) are the two U.S.-based forest products certification programs that have been accredited by the Forest Stewardship Council.

Forest certification is growing. Forests certified to Forest Stewardship Council standards total 15.8 million hectares (39 million acres) worldwide. Certified forests in the U.S. total 1.5 million hectares (3.7 million acres).

Other approaches are being taken to forest practices certification. For example, timberlands may seek certification that their environmental management systems meet the ISO 14001 standard. Certification audits are carried out by accredited registrars. The American Forestry and Paper Association has adopted a Sustainable Forestry Initiative, a set of forest practices guidelines for association members. Members are required to adhere to the guidelines as a condition of membership. Companies have the option of self-certifying their compliance or seeking independent certification. (To find out more about this initiative, visit http://205.197.9.134/forestry/sfi_frame.html.)

There are two types of forest products certification:

  • Forest Management – Timberland owners that meet certification standards can use the SmartWood label on their products
  • Chain of Custody – Chain of custody labels track certified products as they move "downstream" in the market from production forest to end-use consumer. A chain of custody label is an assurance that products advertised as certified by "middlemen" such as manufacturers, processors, distributors or retailers actually originated from certified sources.

For a timber producer to win SmartWood certification, the operation must be environmentally appropriate, socially beneficial, and economically viable. Certified forests must maintain ecological functions, including watershed processes, wildlife habitat, and conservation of biological resources. There must be assurances that the forest will not be converted to non-forest uses in the foreseeable future, production is on a sustained yield basis, and there is a long-term forest management plan. SmartWood does not endorse conversion of natural forests to tree farms, but tree farms that have been developed on previously deforested land can be considered for certification.

An interdisciplinary team assesses timberlands applying for certification. The teams include a forester, ecologist, fish and wildlife biologist, social scientist and economist. The team’s report is independently reviewed, and the final certification decision is made by SmartWood’s headquarters office. The process may take anywhere from three to six months, depending on the size of the operation undergoing review.

Guidelines cover issues such as management and landscape planning, silviculture, sustained yield management, felling and bucking, skidding, logging roads, wildlife habitat, forest chemical usage, riparian areas and wetlands, social impacts, and effects on indigeneous peoples.

There are three types of SmartWood certification conditions. Pre-conditions must be met before a forest can be certified. Conditions can be met during the certification period, while non-binding recommendations are optional.

Issues relevant to forest certification are certifying forestry on public lands, consumer awareness, environmentalists’ attitudes, supply and demand for certified products, and varying approaches to certification. In some cases, retailers are exerting pressure on product suppliers to get certified if they want to sell their wares through the retail outlets. For example, two of British Columbia’s large forest products companies announced last year they would seek certification, after retailers canceled orders of products from BC forests. B&Q, a British "big box" do-it-yourself store, has announced that by years’ end, it will only buy wood products from forests certified to Forest Stewardship Council standards.

Discussion
Issues raised in discussion included the quality of certified wood products, price differences, certifying timberlands where old-growth trees are cut, and the related issues of label credibility and consumer awareness.

Quality: There is no difference in quality between wood products from certified and non-certified forests.

Price: There can be price differences between certified and non-certified products, but pricing is unpredictable depending on the product, the market and the tree species the product came from.

Old Growth: Cutting old-growth trees has been a very difficult issue for development of SmartWood guidelines.

Consumer Awareness: SmartWood is doing more work with consumer awareness, to help wood product buyers compare labels and rate their credibility. Skeeters from The Food Alliance said there are labels in the marketplace that aren’t backed by strong standards. Checks and balances are needed to assure consumers that labels are credible. There are concerns that in some cases, environmental claims are misleading or examples of "greenwashing" that exploit consumers’ support for environmental protection. (To find out more about this issue, visit Scientific Certification Systems’ environmental claims certification program at http://www.scs1.com/claims.html.)

 

dot USING MARKET TOOLS PART 3: EXTENDED PRODUCT RESPONSIBILITY (EPR)

Discussion Participants:
  David Stitzhal
    Full Circle Environmental
    206-723-0528,
fullcircle@nwnexus.com
  Viccy Salazar
    EPA Region 10
    206-553-1060, salazar.viccy@epa.gov
    http://www.epa.gov/epr (under construction)

The Bottom Line
Extended product responsibility’s (EPR) ultimate goal is to reduce the environmental impacts of products throughout their life cycles. Providing a service instead of providing a product carries built-in incentives to reduce waste. A number of regional EPR initiatives are underway.

Presentation

David Stitzhal and Viccy Salazar: The term "extended product responsibility" means different things to different people. It may mean manufacturers taking back products for remanufacturing or recycling, consumers buying services instead of products, or building life-cycle costs into design.

Environmental impacts occur at every stage of product life cycles, from the extraction of raw materials to final disposal. Extended product responsibility (EPR) gets at minimizing impacts throughout the life cycle. Product design is critically important for EPR, because design can determine a product’s impacts throughout the life cycle. EPR is a matter of "internalizing externalities"—accounting for and reducing environmental costs of a product rather than simply shifting the costs onto society at large.

In Europe, EPR is being carried out through government action, such as takeback mandates. In the U.S., EPR is a cluster of principles being carried out through a mix of private and public action. An example of a private action was the Golden Carrot program for refrigerators. Early in the 1990s, a group of 25 electric utilities offered a $31 million prize to any appliance manufacturer that could produce a refrigerator 25 to 50 percent more energy-efficient than federal appliance standards in effect in 1993. Also, the winning model could not use refrigerants that deplete the protective stratospheric ozone layer. The prize was awarded to Whirlpool.

Another example is that BMW reduced the number of plastic types in its vehicles from 30 to half a dozen. The manufacturing process was changed so that resins could be used for more than one function, and could be extracted from vehicles for recycling at the end of the vehicle’s life.

A tenet of EPR is shifting the point at which disposal costs are paid. Instead of deferring payment of disposal costs until the end of the product’s life, disposal costs are paid ahead of time. By shifting the point of payment, products with less packaging, for example, will have a leg up in the marketplace.

Another tenet of EPR is changing the nature of transactions from providing a product to providing a service. When buying a service instead of a product, there are built-in incentives to reduce waste. For example, Ford pays DuPont for vehicle painting services instead of vehicle paint. By selling a painting service instead of paint product, DuPont has an incentive to reduce paint waste and the toxicity of coatings used to provide the service.

EPR initiatives under way include:

  • Medical waste roundtable sponsored by the King County Solid Waste Division. The American Hospital Association and EPA have announced a partnership to cut hospital waste in half by 2010 and eliminate mercury from the waste stream by 2005. (Find out more about this partnership by visiting http://www.epa.gov/opptintr/pbt/ahafact.htm.)
  • Package reduction technical assistance program in King County
  • Computer packaging roundtable
  • Northwest Council on EPR, which may hold an EPR event in March 2000.
  • King County Commission for Marketing Recyclable Materials (http://www.metrokc.gov/market).

EPA is working with the Northwest Council on EPR. The agency has provided grants to a few EPR programs and may fund the medical waste roundtable. Nationally, EPA is looking at EPR programs for tire manufacturing and plastics design.

Discussion
Issues that came up in discussion included Northwest manufacturers practicing EPR, definitions of EPR, barriers, and building demand for sustainable products.

Northwest Manufacturers: European EPR policies have resulted in Northwest firms that sell products in Europe, such as Fluke and Starbucks, to adopt EPR practices. Starbucks, for example, redesigned a bag.

EPR Definitions: Sustainable development and design for environment are variations on the EPR theme. Catherine Dickerson of PPRC said it’s important not to get hung up on semantics, but to be sure that P2 is incorporated into all of the various approaches that may fall under the EPR umbrella. Stitzhal said the grand vision of EPR is to speak of product life cycles as cradle to cradle rather than cradle to grave.

Building Demand: Rob Greenwood said a key to building demand for sustainable products is procurement—building green criteria into product purchase policies and contracts. Consumer behavior can be influenced, but it’s a tricky process. Credible certification programs allow informed choices to be made. Another opportunity is supply chain management. Manufacturers can help their vendors manage both their costs and environmental issues, thereby "greening" the supply chain and building sustainability into the production system throughout product life cycles.

Mike Ruby of Envirometrics said environmental quality should be bundled into products people buy. People won’t pay a premium for "greenwashing," but if consumers are given credible information about the environmental characteristics of products, they will buy environmental quality.

 

dot LIST OF ATTENDEES

NameOrganization TelephoneE-mail
Gary AndersonWA Dept. of Ecology360-407-6285gand461@ecy.wa.gov
Jacek AnuszewskiWA Dept. of Ecology 360-407-6286janu461@ecy.wa.gov
Shirli AxelrodSeattle Public Utilities 206-684-7804shirli.axelrod@ci.seattle.wa.us
Gary BarnesPortland BES 503-823-7383garyb@bes.ci.portland.or.us
Jeff BowmanKing County Industrial Waste Pretreatment 206-263-3071jeff.bowman@metrokc.gov
Gil BridgesOlympic Terrace Sewer District 425-355-6637otsdwwtp@cnet.com
Clayton BrownUnified Sewerage Agency 503-844-8923brownc@usa-cleanwater.org
Josh ChaitinKing County LHWMP 206-263-3076josh.chaitin@metrokc.gov
Christa ColouzisWA Dept. of Ecology 425-649-7143cboe461@ecy.wa.gov
Kathy CuppsWA Dept. of Ecology 360-407-6275kcup461@ecy.wa.gov
Diane Dent-WhiteWA Dept. of Ecology 360-407-6616dden461@ecy.wa.govs
Catherine Dickerson PPRC206-352-2050 cdickerson@pprc.org
Jim DiPesoPPRC 206-352-2050jdipeso@pprc.org
Al DietemannSeattle Public Utilities 206-684-5888al.dietemann@ci.seattle.wa.us
Daniel DunnCity of Monroe 360-794-6558 
Steve EberlWA Dept. of Ecology 360-407-6293sebe461@ecy.wa.gov
Chad FisherWA Dept. of Ecology 360-407-6859cfis461@ecy.wa.gov
Marianne Fitzgerald Oregon DEQ503-229-5946 fitzgerald.marianne@deq.state.or.us
Tom FoxKing County Dept. ofNatural Resources 206-296-5279tom.fox@metrokc.gov
Ying FuWA Dept. of Ecology 509-456-3073yifu461@ecy.wa.gov
Dave GalvinKing County LHWMP 206-263-3085dave.galvin@metrokc.gov
Carolyn GangmarkEPA Region 10 206-553-4072gangmark.carolyn@epa.gov
Keith GardnerCowlitz Water Pollution Control Plant 360-577-2040jkgardner@kalama.com
John GreeleyUnified Sewerage Agency 503-844-8922greeleyj@usa-cleanwater.org
Jennie GoldbergSeattle City Light 206-684-3167jennie.goldberg@ci.seattle.wa.us
Karen HamiltonKing County Procurement Services 206-296-4317karen.hamilton@metrokc.gov
James HanleyWA Dept. of Ecology 425-649-7090jaha461@ecy.wa.gov
Ron HebishCity of Raymond 360-942-3451rgfh@techline.com
Ray HoffmanSeattle Public Utilities 206-233-5008ray.hoffman@ci.seattle.wa.us
Richard HoilandCity of VancouverWastewater Division 360-696-8008richard.hoiland@ci.vancouver.wa.us
Robert HolmanCity of Olympia 360-753-8428 
Tim HonadelOregon DEQ 503-229-5316honadel.tim@deq.state.or.us
Chuck HopkinsOregon DEQ 503-229-6528hopkins.chuck@deq.state.or.us
Don HulgrenCowlitz Water Pollution Control Plant 360-577-2040 
Mike KaplanEnvirometrics, Inc. 206-633-4456mkaplan@envirometrics.com
Judy KennedyWA Dept. of Ecology 360-407-6744jken461@ecy.wa.gov
Dave KlingEPA P2 Division 202-260-3755kling.dave@epa.gov
David KunzOR DEQ 503-229-6237kunz.david@deq.state.or.us
Karen LewotskyOregon Environmental Council 503-222-1963 
Leslie MorrisWA Dept. of Ecology 360-407-6715lemo461@ecy.wa.gov
Linda MountCity of Monroe 360-794-6558 
Dennis MurrayWA Dept. of Ecology 509-454-4329demu461@ecy.wa.gov
Larry NussbaumNorthwest Natural Resource Group 360-379-9421larry@nnrg.org
Hugh O'NeillWA Dept. of Ecology 360-407-7354hone461@ecy.wa.gov
John PalmerEPA Region 10 206-553-6521palmer.john@epa.gov
Linda PangWA Dept. of Ecology 360-407-6859lpan461@ecy.wa.gov
Joanne PhillipsonWA Dept. of Ecology 360-407-6740joph461@ecy.wa.gov
Ray PickensCity of Mount Vernon 360-336-6219rayp@ci.mount-vernon.wa.us
Ray PiperKing County Dept. of Natural Resources 206-263-3018ray.piper@metrokc.gov
Shawn RedmondCity of Olympia 360-753-8428 
Martine Roberts-PillonOregon DEQ 503-229-6738roberts-pillon.martine@deq.state.or.us
Mike RubyEnvirometrics, Inc. 206-633-4456mruby@envirometrics.com
Dorinda RussellCity of Centralia Utilities 360-330-7512 
Viccy SalazarEPA Region 10 206-553-1060salazar.viccy@epa.gov
Gail SavinaKing County LHWMP 206-263-3062gail.savina@metrokc.gov
Roger ShirleyCity of Camas 360-834-3263 
Heidi SiegelbaumO’Neill & Siegelbaum 206-784-4265wastenot@speakeasy.org
Stacie SingletonWA Dept. of Ecology 360-407-6753ssin461@ecy.wa.gov
Carole SkeetersThe Food Alliance 503-493-1066skeeters@teleport.com
Madeline StenPPRC 206-352-2050msten@pprc.org
David StitzhalFull Circle Environmental, Inc. 206-723-0528fullcircle@nwnexus.com
Jayne StrommerCity of Wenatchee 509-664-3387jstrommer@cityofwenatchee.com
Bruce SutherlandOregon DEQ 503-229-5595sutherland.bruce@deq.state.or.us
Freda TepferSnohomish County Solid Waste Management 425-388-6473freda.tepfer@co.snohomish.wa.us
Linda ThomasCity of Leavenworth 509-548-5994 
Laurel TomchickKing County LHWMP 206-263-3063laurel.tomchick@metrokc.gov
Lucita ValiereEPA Region 10 206-553-2964valiere.lucita@epa.gov
Dave WaddellKing County LHWMP 206-689-3069dave.waddell@metrokc.gov
Jeff WebbPierce County Utilities 253-798-3005jwebb@co.pierce.wa.us
Dave WickWA Dept. of Ecology 425-649-7071dwic461@ecy.wa.gov
David WigglesworthAlaska DEC 907-269-7582dwiggles@envircon.state.ak.us
Chris WileyPPRC 206-352-2050cwiley@pprc.org
Sharon WilsonEPA Region 10 Pretreatment 206-553-0325wilson.sharon@epa.gov


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