Source reduction reviews

The Agency had three requirements for setting up a source reduction review sufficient information for the review, a workable assessment methodology and the ability to propose practical solutions to waste problems. 

Other Requirements. Success of source reduction reviews depended upon a reasonable assessment methodology that would identify the most wasteful processes and develop suggestions to improve them without requiring large resource expenditures on the Agency s part. A basic premise was that chemists could identify quickly those PMN cases with the greatest waste so that intensive review and development of options for reducing the wastes would only be done on the most appropriate cases. 

In February 1991, EPA chemists initiated a pilot study to test the assessment process and to determine whether source reduction reviews were feasible. EPA chemists designed a process to concentrate resources on those cases most likely to yield significant source reduction opportunities. The process began with a quick sort to determine which PMN cases had sufficient potential for further study. This was followed by a preliminary assessment to identify those cases with the highest pollution prevention potential and then a detailed assessment during which pollution prevention options were developed and analyzed. Finally, the Agency determined whether there were source reduction suggestions of sufficient merit to justify a letter to the PMN submitter. 

U.S. Environmental Protection Agency, Source Reduction Review Project, EPA-lOO/R-92/002, Office of Pollution Prevention and Toxics, Washington, DC, August 1992. 

Assessment Phase The assessment phase aims to collect data needed to identify and analyze pollution-prevention opportunities. Assessment of the facility s waste-reduction needs includes the examination of hazardous waste streams, process operations, and the identification of techniques that often promise the reduction of waste generation. Information is often derived from obsei vations made during a facihty walk-through, interviews with employees (e.g., operators, line workers), and review of site or regulatory records. One professional organization suggests the following information sources be reviewed, as available (Ref. 7) ... 

Review regulations to determine their effect on source reduction... 

Pollution prevention mode. One or more of the pollution prevention modes in the pollution prevention hierarchy (source reduction, recycle, reuse, treatment, and disposal) was assigned based on review, discussion, and consensus among study team members. These classifications were not obvious in several cases and required extended debate. 

In three states, Oregon, California, and Wisconsin, iaws have been enacted to require plastic containers to meet certain criteria invoiving recycling rate, recycled content, reuse, or source reduction. A brief review of the iegislation is presented next. 

The pilot study included 418 consecutive PMN submissions. Of those cases, 11% received preliminary assessments. Of these cases. Agency chemists were able to identify source reduction opportunities for 13% of the cases that went into preliminary review. It is likely that this percentage will increase in the future as a greater number of new pollution technologies become available. In addition, the Agency determined that the resources to perform these assessments were not particularly great, so the program appeared to be feasible from an economic standpoint. 

EPA staff currently perform source reduction assessments on all new PMN cases in a process called nthetic Methodology Assessment for Reduction Technologies (SMART). Although minor changes in the review process and criteria have been instituted since the pilot study, the following process description reflects the Agency s current process and criteria. 

Selection for Detailed Assessment. A PMN case meeting one or more of the five criteria below is given a detailed Agency assessment for source reduction. PMN cases that do not meet any of the criteria are dropped from further pollution prevention review. A detailed assessment is performed if ... 

The properties of purified sulfite reductase from spinach have been investigated in detail using methyl viologen as an artificial electron donor (Asada, 1967 Asada e/ al., 1969). In summary the enzyme can be resolved into two fractions both of which are essential for activity. One fraction can be replaced by bovine serum albumin while the other (sulfite reductase) exhibits the characteristics of a hemoprotein, containing 0.76 g atoms of Fe per molecular weight of 84,000. Unlike the sulfite reductase from other sources (see review by Roy and Trudinger, 1970), the purified spinach enzyme contains negligible amounts of flavin and catalyzes the reduction of hy-droxylamine, but not nitrite. The sulfite reductase from Allium exhibits similar... 

Does source reduction evaluation review and plan... 

The original commercial source of E was extraction from bovine adrenal glands (5). This was replaced by a synthetic route for E and NE (Eig. 1) similar to the original pubHshed route of synthesis (6). Eriedel-Crafts acylation of catechol [120-80-9] with chloroacetyl chloride yields chloroacetocatechol [99-40-1]. Displacement of the chlorine by methylamine yields the methylamine derivative, adrenalone [99-45-6] which on catalytic reduction yields (+)-epinephrine [329-65-7]. Substitution of ammonia for methylamine in the sequence yields the amino derivative noradrenalone [499-61-6] which on reduction yields (+)-norepinephrine [138-65-8]. The racemic compounds were resolved with (+)-tartaric acid to give the physiologically active (—)-enantiomers. The commercial synthesis of E and related compounds has been reviewed (27). The synthetic route for L-3,4-dihydroxyphenylalanine [59-92-7] (l-DOPA) has been described (28). 

Now you can reconsider the material balance equations by adding those additional factors identified in the previous step. If necessary, estimates of unaccountable losses will have to be calculated. Note that, in the case of a relatively simple manufacturing plant, preparation of a preliminary material-balance system and its refinement (Steps 14 and 15) can usefully be combined. For more-complex P2 assessments, however, two separate steps are likely to be more appropriate. An important rule to remember is that the inputs should ideally equal the outputs - but in practice this will rarely be the case. Some judgment will be required to determine what level of accuracy is acceptable, and we should have an idea as to what the unlikely sources of errors are (e.g., evaporative losses from outside holding ponds may be a materials loss we cannot accurately account for). In the case of high concentrations of hazardous wastes, accurate measurements are needed to develop cost-effective waste-reduction options. It is possible that the material balance for a number of unit operations will need to be repeated. Again, continue to review, refine, and, where necessary, expand your database. The compilation of accurate and comprehensive data is essential for a successful P2 audit and subsequent waste-reduction action plan. Remember - you can t reduce what you don t know is therel... 

Emission reduction credits can also be used to offset emissions increases under New Source Review, Prevention of Significant Deterioration, and Base Realignment and Closure. 

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