US EPA - Environmental Protection Agency

Pollution Prevention Solutions During Permitting, Inspection and Enforcement Activities


Courtesy of US EPA - Environmental Protection Agency

Executive Summary

In 1995, the nation’s largest industrial users of toxic chemicals released 2.2 billion pounds of toxic chemicals into the environment (U.S. EPA, 1995 Toxic Release Inventory) and spent billions of dollars managing pollution control technology systems to prevent that number from being higher. If one were to add in the purchase price of the raw materials that eventually escaped as 2.2 billion pounds of chemical waste (instead of product), the price tag grows even larger. Many companies have made progress reducing waste generation, improving compliance, and increasing profits. However, these figures suggest there is still a long way to go. Why are these figures so high?

There are many economic, technological, and political reasons that make environmental compliance costs so high—most government agencies and companies are familiar with these. The purpose of this manual is not to review all of those reasons, but to focus on how to get to the root of the problem. How-ever, one reason that does deserve discussion is the way our environmental compliance system is designed. Compliance standards have historically been based on the performance of costly end-of-pipe pollution controls.

Consequently, government permitting, inspection, and enforcement procedures often focus on achieving compliance through end of pipe control methods, which in turn causes companies to install costly end of pipe controls rather than look for more cost effective site specific solutions that may reduce the amount of waste generated, managed, and released.

This handbook summarizes a menu of approaches developed by environmental agencies and companies working together to incorporate cost-effective pollution prevention solutions into permitting, inspection, and enforcement. Many of the approaches are designed to: (1) explore pollution prevention solutions that may reduce the amount of pollution generated, (2) reduce the cost of environmental controls, and (3) meet or go beyond environmental standards.

This Executive Summary provides a “quick glance” at these approaches. Section 1 defines pollution prevention and waste minimization and summarizes EPA policy. Sections 2 through 4 provide examples of approaches used to incorporate pollution prevention in permitting, inspection, and enforcement activities under the air, water, and RCRA programs. Appendix A provides a list of pollution prevention resources.

This quick-glance digest summarizes 17 categories of examples of the use of pollution prevention during permitting, inspection, and enforcement activities in several dozen states and EPA Regional offices. These categories are summarized in Tables ES-1, ES-2, and ES-3, corresponding to permitting, inspection, and enforcement, respectively.

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