POLLUTION PREVENTION PROGRAM

Transcription

1 DEVELOPING AND IMPLEMENTING A WASTE REDUCTION PROGRAM The development and implementation of a waste reduction program is a key element in any environmental management program. An effective reduction program must be based on accurate and current information on waste stream generation, and economical and technically-effective waste reduction techniques. This can be accomplished by establishing procedures to collect information, evaluate options, and identify cost-effective reduction techniques. Once identified, the techniques can then be implemented and become an established part of the facilities management and operation. An approach to developing and implementing a waste reduction program is summarized in Figure 1. This approach can be used by all types and sizes of companies. The first step in developing a program is to establish clear corporate policy. The full commitment from management of time, personnel, and financing, is an extremely important requirement. Lack of this commitment is often one of the most formidable obstacles to waste reduction. 1.0 Facility Assessment A facility assessment, or audit, provides a basis to collect the technical and economic information necessary to select appropriate waste reduction techniques. Depending on the size of the facility, an audit can be done by a single person or a team. The team approach is the best as the team as a whole will contain a wider range of experience, knowledge, and problem perception. An in-house team can include management and plant personnel from facilities engineering, environmental engineering, safety and health, purchasing, materials and inventory control, finance, and product quality control. The team should be selected and led by a technically competent person with sufficient authority to do the job. Once the appropriate personnel have been selected, the next step is to conduct the facility assessment. Information should be collected on the types, quantities, compositions, and sources of all air, solid, hazardous, and wastewater waste streams. This information is obtained through a search of available background data and supplemented with detailed data from a plant survey (1,2). Background Information All available background information must be collected first. This includes information on the production process, facility layout, waste stream generation and waste management costs. Some sources of this information are listed in Table 1. POLLUTION PREVENTION PROGRAM NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES

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3 -4- Based on the collected information, a general flow diagram or material balance for each process step can be developed. The diagram should clearly identify the source, type, quantity, and concentration of each identified waste stream (see Figure 2). The background information can be used to develop and organize the plant survey and help identify data gaps, sampling points, problem areas, and data conflicts. Plant Survey After reviewing the background information and identifying additional data requirements, a survey can be conducted: (1) to verify background data and fill gaps; (2) to identify additional waste streams, and (3) to observe and collect data on actual operation and management practices. Each step in the manufacturing process from the material delivery area to final product storage must be examined. Table 2 lists some of the types of waste that can be generated in each production area. Examples of specific process information which can be collected by a survey are listed in Table 3. If detailed or specific data on waste stream quantity and composition are not available or cannot be calculated, then a sampling program should be included as part of the survey. Sampling points should be identified before the survey begins based on the waste flow diagram. However, additional samples may have to be taken as new waste streams are identified during the survey. Sampling of the waste streams should be done over a period of time to account for variations in production scheduling. Sampling may also have to be carried out over an extended length of time if products are produced on an irregular or seasonal basis. However, in many cases only qualitative information is needed. This usually can be calculated from the process input composition and simple flow measurements or historical records on waste generation. A preliminary review of the data should be performed during or just after the survey. This can help identify missing or inaccurate information. Additions and corrections should be made to the waste flow diagram and the overall data reviewed for completeness. For each waste stream the following information should be available: 0 Point of origin o Subsequent handling/treatment/disposal o Physical and chemical characteristics o Quantity o Rate of generation (i.e. lbs/unit of product) 0 Variations in generation rate 0 Potential for contamination or upset o Cost to manage/dispose

4 TABLE 2 Possible Sources of Waste Plant Category Area Possible Waste Material Material receiving Loading docks, Packaging materials, off-spec materials, incoming pipelines, receiving areas damaged containers, spill residue, transfer line leaking/dumping Tank bottoms, off-spec and excess materials, Raw material storage/ Tanks, silos, warefinal product houses, drum storage spill residue, leaking pumps, valves, and pipes, storage yards, storerooms damaged containers, empty containers Production Melting, curing, baking, distilling, washing, coating machinery, formulating Washwater, solvents, still bottoms, off-spec product, catalysts, empty containers, sweepings, duct work clean-out, additives, oil, process solution dumps, rinsewater, excess materials, filters, leaking process tanks, spill residue, pumps, pipes, valves, hoses

5 -3- TABLE 1 Background Information Production Process Information Process flow diagrams and plant layout Sewer layout diagrams Purchasing records Material Safety Data Sheets Operating Manuals Water usage rates Plant operating schedule Production records Waste Stream Information Manifests, annual reports and related RCRA information Environmental monitoring reports Environmental permits (solid waste, hazardous waste, NPDES, pre-treatment, air emissions) Information on any regulatory violations Location of all solid and hazardous waste collection/storage points Diagram of air, wastewater and/or hazardous waste treatment units Operating manuals for treatment units Economic Information Water and sewer costs Solid and hazardous waste management costs Cost of operating on-site treatment units Waste management contracts and billings General Information Current waste minimization practices Copies of previous environmental audits Vendor information

6 -8- TABLE 3 Examples of Information from In-Plant Survey Area Information Material delivery and storage Material transfer and handling procedures Storage procedures Evidence of leaks or spills Inventory of materials Condition of pipes, pumps, tanks, valves, and storage/delivery area Production process Exact sources of all 'process waste Waste flow/quantity and concentration Operational procedures Source, quantity and concentration of intermittent waste streams (i.e. cleaning, batch dumps, etc.) Condition of all process equipment including tanks,,pumps, pipes, valves, etc. Evidence of leaks or spills Maintenance procedures and schedule Potential sources of leaks and spills Waste management Operational procedures for waste treatment units Quantity and concentration of all treated wastes and residues Waste handling procedures Efficiency of waste treatment units Waste stream mixing

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10 -12- Companies have taken a number of simple approaches to insure the initial and continued success of a waste minimization program. Many have established, at the corporate level, a waste reduction engineering group that can provide technical assistance to all plants. Awards and financial incentives have been used to foster new ideas and innovations. Some firms also conduct annual audits of their plants to review and update existing waste reduction programs and to identify applicable new waste reduction methods. The establishment of a company-wide information exchange program using newsletters, fact sheets, publications, and/or internal conferences to transfer ideas has been successfully used. Other companies have instituted separate capital expenditure review procedures for waste minimization projects that require less paperwork and have a quicker review process. 4.0 SOURCES OF ADDITIONAL INFORMATION Information on waste assessment techniques and applicable waste reduction methods can be obtained from the North Carolina Pollution Prevention Pays Program. The Program provides free technical assistance to North Carolina industries and municipalities on ways to reduce, recycle and prevent wastes before they become pollutants. This non-regulatory program, located in the Division of Environmental Management, addresses water and air quality, toxic materials, and solid and hazardous waste. Designated as the lead agency in waste reduction, the Program works in cooperation with the Solid and Hazardous Waste Management Branch and the Governor's Waste Management Board. The services and assistance available fall into the following categories: Information Clearinghouse. An information data base provides access to literature sources, contacts, and case studies on waste reduction techniques for specific industries or waste streams. Information is also available through customized computer literature searches. Waste reduction reports published by the Program are also available. Specific Information Packages. The staff can prepare facility or waste-stream-specific waste reduction reports for industries and communities. Information provided by the facility is used to identify cost-effective waste reduction options. A short report detailing these options is provided along with references, case studies, and contacts. On-site Technical Assistance. The staff can provide comprehensive technical assistance through facility visits. During an on-site visit, detailed process and waste stream information is collected. The information is analyzed, and a series of waste reduction options are identified. A report is prepared detailing these options and includes literature, contacts, case studies, and vendor information. Outreach. The staff can give presentations on pollution prevention to industries, trade associations, professional organizations, and citizen groups. Depending on the audience, these programs range from an overview of the State's Pollution Prevention Program to in-depth discussions of technologies for specific industries.

11 Evaluation and Selection of Waste Reduction Techniques Procedures used to identify, evaluate and select applicable waste reduction techniques will depend on the complexity of the manufacturing process, and the quantity and variety of waste generated. Successful approaches range from simple group discussions to complex computer modeling techniques (1, 2, 4). However, all approaches will contain the same basic steps: (1) list waste streams; (2) identify potential waste reduction techniques for each waste stream; (3) evaluate the technical and economic aspects of each technique; (4) select the most cost-effective waste reduction technique(s) for each waste stream. In addition to addressing specific waste streams, general recommendations on facility-wide reduction methods should also be made. These could include such areas as material handling, maintenance, and operating procedures. Once the techniques for each waste stream have been identified, the technical feasibility of each technique should be evaluated. An engineering evaluation should take into account such factors as applicability, waste reduction potential, operation and maintenance requirements, safety and health, ease of implementation, reliability, and any special design considerations. Not all of these factors are equally important for each technique. For example, an evaluation of a change in inventory management may only have,to consider ease of implementation and reduction potential. At this point an engineering consultant may be employed to provide additional expertise in evaluating technical feasibility. As part of the technical evaluation, each technique should be evaluated according to the hierarchy shown in Figure 3. The liability associated with each step in the hierarchy increases as one goes down it. This will help during the selection process to bring the risks and liabilities associated with managing a waste into the evaluation process. As indicated, the best techniques for waste minimization is the elimination or reduction of the waste at its source. This will eliminate the risks and costs associated with management of the waste. In addition to the technical evaluations, an economic analysis of each reduction technique should be done. Cost factors to consider include implementation costs (capital, installation, operating and maintenance) as well as cost savings due to lower production costs and waste management/disposal costs. Based on this information, a return on investment analysis can then be done to estimate the payback period. The current waste management cost is a very important factor which is often overlooked. These costs include not only the cost of shipping a waste off-site, but also includes the on-site expense of labor and time required to handle, manage, track, store, treat, and manifest the waste. Other considerations are harder to quantify but are very important and include liability insurance premiums, long-term liability and legal costs, worker health and safety, community relations, and regulatory compliance (1,2). The completed technical and economic analyses will enable the best waste minimization options for each waste stream to be selected. Techniques may be short term such as inventory control or longer term such as process modifications. This selection process is rather subjective and is usually based on the experience of several people who are in the decision-making

12 DEVELOPING AND IMPLEMENTING A WASTE REDUCTION PROGRAM by Gary E. Hunt, Environmental Engineer North Carolina Pollution Prevention Pays Program Raleigh, North Carolina The development and implementation of a waste reduction program is a key element in any environmental management program. An effective reduction program must be based on accurate and current information on waste stream generation, and economical and technically-effective waste reduction techniques. This can be accomplished by establishing procedures to collect information, evaluate options, and identify cost-effective reduction techniques. Once identified, the techniques can then be implemented and become an established part of the facilities management and operation. An approach to developing and implementing a waste reduction program is summarized in Figure 1. This approach can be used by all types and sizes of companies. The first step in developing a program is to establish clear corporate policy. The full commitment from management of time, personnel, and financing is an extremely important requirement. Lack of this commitment is often one of the most formidable obstacles to waste reduction. 1.0 Facility Assessment A facility assessment, or audit, provides a basis to collect the technical and economic information necessary to select appropriate waste reduction techniques. a single person or a team. Depending on the size of the facility, an audit can be done by The team approach is the best as the team as a whole will contain a wider range of experience, knowledge, and problem perception. An in-house team can include management and plant personnel from facilities engineering, environmental engineering, safety and health, purchasing, materials and inventory control, finance, and product quality control. The team should be selected and led by a technically competent person with sufficient authority to do the job. 24.1

13 -llprocess. In many cases there are just one or two technically-feasible and cost-effective alternatives. In some cases several techniques may be effectively used together to reduce the waste. For example, the first technique may be a segregation of a waste stream which enables recovery and reuse on-site. Once the reduction techniques are identified, an implementation plan should be developed for each waste stream. This should include information on the implementation schedule, equipment needs, conceptual design, implementation requirements, management requirements, and cost estimates. 3.0 Waste Minimization Program Implementation and Monitoring The waste stream reduction plans along with any general facility recommendations will form the basis of the waste minimization program. To insure continued program effectiveness, procedures must be established for monitoring and evaluating the techniques once in place. The program should address review and updating procedures as well as how the program will be integrated into the management structure. In addition, the program should be dynamic in nature to allow for production change and development of new waste reduction techniques. The implementation of a waste reduction program can be done in a phased manner. Waste streams which present management problems and/or where the investment will have a rapid payback period, can be addressed first. Simple and low-cost techniques can also be put in quickly. In many cases this just involves improvements in inventory control, operation, and maintenance. One important factor is to keep the employees informed and involved at all steps in the development and implementation of a program. Employees will also be extremely valuable in evaluating a minimization program and in identifying ways to improve program performance. A record-keeping system should be established to track the effectiveness of each segment of the program. Waste generation and reduction data should be calculated in terms of product production rates (i.e. pounds of waste per pound of product, pounds of waste per area of product, etc.). This would allow accurate comparison of waste generation and reduction data over time. Associated economic data as discussed above should also be tabulated to evaluate the efficiency of the waste stream reduction techniques. Based on the collected information, the program should undergo regular review and updating. As discussed earlier, corporate commitment is a most important factor in the initial and continuing success of a waste reduction program. The program must become an integral part of a firm's corporate policy, product development procedures, operational procedures, and training program. A senior manager or executive committee could be given the authority and resources to develop, operate, and monitor the program throughout the company. If a firm is large enough, a small staff may be needed to evaluate the success of the program and develop new waste minimization approaches. Such a high level management commitment will help to keep the waste minimization program active in all parts and levels of the company, from new product development to the maintenance staff.

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15 -13- Challenge Grants. A matching grant program provides funds for the cost of personnel, materials, or consultants needed to undertake pollution prevention projects. Projects eligible for grant funds range from characterizing waste streams in order to identify pollution reduction techniques to conducting in-plant and pilot-scale studies of reduction technologies. For further information contact the Pollution Prevention Program, Division of Environmental Management, P. 0. Box 27687, Raleigh, NC Telephone: 919/ References 1. USEPA, Manual for Waste Minimization Opportunity Assessment, Office of Research and Development, Cincinnati, Ohio, Ontario Waste Management Corporation, Industrial Waste Audit and Reduction Manual, Toronto, Ontario, Canada, H. William Blakeslee and Theodore M. Grabowski, A Practical Guide to Plant Environmental Audits, Van Nostrand Reinhold Company, New York, NY, Carl H. Fromm and Michael S. Callahan, "Waste Reduction Audit Procedure--A Methodology for Identification, Assessment and Screening of Waste Minimization Options" in Proceedings of the National Conference on Hazardous Wastes and Hazardous Materials, Hazardous Materials Control Research Institute, Silver Springs, MD, COPYRIGHT: March 1988 Pollution Prevention Pays Program N. C. Department of Natural Resources and Community Development Reprint with Permission

16 TABLE 1 Background Information Production Process Information Process flow diagrams and plant layout Sewer layout diagrams Purchasing 'records Material Safety Data Sheets Operating Manuals Water usage rates Plant operating schedule Production records Waste Stream Information Manifests, annual reports and related RCRA information Environmental monitoring reports Environmental permits (solid waste, hazardous waste, NPDES, pre-treatment, air emissions) Information on any regulatory violations o Location of all solid and hazardous waste collection/storage points o Diagram of air, wastewater and/or hazardous waste treatment units o Operating manuals for treatment units Economic Information Water and sewer costs Solid and hazardous waste management costs Cost of operating on-site treatment units Waste management contracts and billings General Information Current waste minimization practices Copies of previous environmental audits Vendor information 24.5

17 Once the appropriate personnel have been selected, the next step is to conduct the facility assessment. Information should be collected on the types, quantities, compositions, and sources of all air, solid, hazardous, and wastewater waste streams. This information is obtained through a search of available background data and supplemented with detailed data from a plant survey (1,2). Background Information All available background information must be collected first. This includes information on the production process, facility layout, waste stream generation and waste management costs. Some sources of this information are listed in Table 1. Based on the collected information, a general flow diagram or material balance for each process step can be developed. The diagram should clearly identify the source, type, quantity, and concentration of each identified waste stream (see Figure 2). The background information can be used to develop and organize the plant survey and help identify data gaps, sampling points, problem areas, and data conflicts, Plant Survey After reviewing the background information and identifying additional data requirements, a survey can be conducted: (1) to verify background data and fill gaps; (2) to identify additional waste streams, and (3) to observe and collect data on actual operation and management practices. Each step in the manufacturing process from the material delivery area to final product storage must be examined. Table 2 lists some of the types of waste that can be generated in each production area. Examples of specific process information which can be collected by a survey are listed in Table 3. If detailed or specific data on waste stream quantity and composition are not available or cannot be calculated, then a sampling program should be included as part of the survey. Sampling points should be identified before the survey begins based on the waste flow diagram. However, additional 24.2

18 TABLE 2 Possible Sources of Waste (continued) Plant Category Area Possible Waste Material Support services Laboratories Reagents, off-spec chemicals, samples, sample containers Maintenance, shops Solvents, cleaning agents, degreasing sludges, sand-blasting waste, lubes, oils, greases, scrap metal, caustics Garages Oils, filters, solvents, acids, caustics, cleaning bath sludges, batteries Powerhouse/boilers Fly ash, slag, additives, oil, tube clean-out material, chemical empty containers Cooling towers Chemical additives, empty containers, cooling tower bottom sediment Source: After 3

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20 samples may have to be taken as new waste streams are identified during the survey. Sampling of the waste streams should be done over a period of time to account for variations in production scheduling. Sampling may also have to be carried out over an extended length of time if products are produced on an irregular or seasonal basis. However, in many cases only qualitative information is needed. This usually can be calculated from the process input composition and simple flow measurements or historical records on waste generation. A preliminary review of the data should be performed during or just after the survey. This can help identify missing or inaccurate information. Additions and corrections should be made to the waste flow diagram and the overall data reviewed for completeness. For each waste stream the following information should be available: Point of origin o Subsequent handling/treatment/disposal o Physical and chemical characteristics o Quantity o Rate of generation (i.e. lbs/unit of product) 0 Variations in generation rate 0 Potential for contamination or upset o Cost to manage/dispose 2.0 Evaluation and Selection of Waste Reduction Techniques Procedures used to identify, evaluate and select applicable waste reduction techniques will depend on the complexity of the manufacturing process, and the quantity and variety of waste generated. Successful approaches range from simple group discussions to complex computer modeling techniques (1, 2, 4). However, all approaches will contain the same basic steps: (1) list waste streams; (2) identify potential waste reduction techniques for each waste stream; (3) evaluate the technical and economic aspects of each technique; (4) select the most cost-effective waste reduction technique(s) for each waste stream. In addition to addressing specific waste streams, general recommendations on facility-wide reduction methods should also be 24.9

21 made. These could include such areas as material handling, maintenance, and operating procedures. Once the techniques for each waste stream have been identified, the technical feasibility of each technique should be evaluated. An engineering evaluation should take into account such factors as applicability, waste reduction potential, operation and maintenance requirements, safety and health, ease of implementation, reliability, and any special design considerations. Not all of these factors are equally important for each technique. For example, an evaluation of a change in inventory management may only have to consider ease of implementation and reduction potential. At this point an engineering consultant may be employed to provide additional expertise in evaluating technical feasibility. As part of the technical evaluation, each technique should be evaluated according to the hierarchy shown in Figure 3. The liability associated with each step in the hierarchy increases as one goes down it. This will help during the selection process to bring the risks and liabilities associated with managing a waste into the evaluation process. As indicated, the best techniques for waste minimization is the elimination or reduction of the waste at its source. This will eliminate the risks and costs associated with management of the waste. In addition to the technical evaluations, an economic analysis of each reduction technique should be done. Cost factors to consider include implementation costs (capital, installation, operating and maintenance) as well as cost savings due to lower production costs and waste management/disposal costs. Based on this information, a return on investment analysis can then be done to estimate the payback period. The current waste management cost is a very important factor which is often overlooked. These costs include not only the cost of shipping a waste off-site, but also includes the on-site expense of labor and time required to handle, manage, track, store, treat, and manifest the waste. Other considerations are harder to quantify but are very important and include liability insurance premiums, long-term liability and legal costs, worker health and safety, community relations, and regulatory compliance (1,2)

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23 The completed technical and economic analyses will enable the best waste minimization options for each waste stream to be selected. Techniques may be short term such as inventory control or longer term such as process modifications. This selection process is rather subjective and is usually based on the experience of several people who are in the decision-making process. In many cases there are just one or two technically-feasible and cost-effective alternatives. In some cases several techniques may be effectively used together to reduce the waste. For example, the first technique may be a segregation of a waste stream which enables recovery and reuse on-site. Once the reduction techniques are identified, an implementation plan should be developed for each waste stream. This should include information on the implementation schedule, equipment needs, conceptual design, implementation requirements, management requirements, and cost estimates. 3.0 Waste Minimization Program Implementation and Monitoring The waste stream reduction plans along with any general facility recommendations will form the basis of the waste minimization program. To insure continued program effectiveness, procedures must be established for monitoring and evaluating the techniques once in place. The program should address review and updating procedures as well as how the program will be integrated into the management structure. In addition, the program should be dynamic in nature to allow for production change and development of new waste reduction techniques. The implementation of a waste reduction program can be done in a phased manner. Waste streams which present management problems and/or where the investment will have a rapid payback period, can be addressed first. Simple and low-cost techniques can also be put in quickly. In many cases this just involves improvements in inventory control, operation, and maintenance. One important factor is to keep the employees informed and involved at all steps in the development and implementation of a program. Employees will also be extremely valuable in evaluating a minimization program and in identifying ways to improve program performance

24 A record-keeping system should be established to track the effectiveness of each segment of the program. Waste generation and reduction data should be calculated in terms of product production rates (i.e. pounds of waste per pound of product, pounds of waste per area of product, etc.). This would allow accurate comparison of waste generation and reduction data over time. Associated economic data as discussed above should also be tabulated to evaluate the efficiency of the waste stream reduction techniques. Based on the collected information, the program should undergo regular review and updating. As discussed earlier, corporate commitment is a most important factor in the initial and continuing success of a waste reduction program. The program must become an integral part of a firm's corporate policy, product development procedures, operational procedures, and training program. A senior manager or executive committee could be given the authority and resources to develop, operate, and monitor the program throughout the company. If a firm is large enough, a small staff may be needed to evaluate the success of the program and develop new waste minimization approaches. Such a high level management commitment will help to keep the waste minimization program active in all parts and levels of the company, from new product development to the maintenance staff. Companies have taken a number of simple approaches to insure the initial and continued success of a waste minimization program. Many have established, at the corporate level, a waste reduction engineering group that can provide technical assistance to all plants. Awards and financial incentives have been used to foster new ideas and innovations. Some firms also conduct annual audits of their plants to review and update existing waste reduction programs and to identify applicable new waste reduction methods. The establishment of a company-wide information exchange program using newsletters, fact sheets, publications, and/or internal conferences to transfer ideas has been successfully used. other companies have instituted separate capital expenditure review procedures for waste minimization projects that require less paperwork and have a quicker review process

25 4.0 SOURCES OF ADDITIONAL INFORMATION Information on waste assessment techniques and applicable waste reduction methods can be obtained from the North Carolina Pollution Prevention Pays Program. The Program provides free technical-assistance to North Carolina industries and municipalities on ways to reduce, recycle and prevent wastes before they become pollutants. This non-regulatory program, located in the Division of Environmental Management, addresses water and air quality, toxic materials, and solid and hazardous waste. Designated as the lead agency in waste reduction, the Program works in cooperation with the Solid and Hazardous Waste Management Branch and the Governor's Waste Management Board. The services and assistance available fall into the following categories: Information Clearinghouse. An information data base provides access to literature sources, contacts, and case studies on waste reduction techniques for specific industries or waste streams. Information is also available through customized computer literature searches. Waste reduction reports published by the Program are also available. Specific Information Packages. The staff can prepare facility or waste-stream-specific waste reduction reports for industries and communities. Information provided by the facility is used to identify cost-effective waste reduction options. A short report detailing these options is provided along with references, case studies, and contacts. On-site Technical Assistance. The staff can provide comprehensive technical assistance through facility visits. During an on-site visit, detailed process and waste stream information is collected. The information is analyzed, and a series of waste reduction options are identified. A report is prepared detailing these options and includes literature, contacts, case studies, and vendor information

26 Outreach. The staff can give presentations on pollution prevention to industries, trade associations, professional organizations, and citizen groups. Depending on the audience, these programs range from an overview of the State's Pollution Prevention Program to in-depth discussions of technologies for specific industries. Challenge Grants. A matching grant program provides funds for the cost of personnel, materials, or consultants needed to undertake pollution prevention projects. Projects eligible for grant funds range from characterizing waste streams in order to identify pollution reduction techniques to conducting in-plant and pilot-scale studies of reduction technologies. For further information contact the Pollution Prevention Program, Division of Environmental Management, P. 0. Box 27687, Raleigh, NC Telephone: 919/ References 1. USEPA, Manual for Waste Minimization Opportunity Assessment, Office of Research and Development, Cincinnati, Ohio, Ontario Waste Management Corporation, Industrial Waste Audit and Reduction Manual, Toronto, Ontario, Canada, H. William Blakeslee and Theodore M. Grabowski, A Practical Guide to Plant Environmental Audits, Van Nostrand Reinhold Company, New York, NY, Carl H. Fromm and Michael S. Callahan, "Waste Reduction Audit Procedure --A Methodology for Identification, Assessment and Screening of Waste Minimization Options" in Proceedings of the National Conference on Hazardous Wastes and Hazardous Materials, Hazardous Materials Control Research Institute, Silver Springs, MD,