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RE: Questioning the P2 Hierarchy



Oscar,

Why must segregation be added ?  Segregation is a "good operating practice"
that is a subset of "source control" that is a subset of "source reduction."
And energy recovery is a subset of recycling.  Your hierarchy is more
commonly known as a waste management hierarchy, not P2.  Some zealots even
take exception to the inclusion of recycling in a P2 hierarchy, let alone
treatment and disposal.

One big problem with all these definitions is that they come out of
different agencies with different views, intents, and constraints.  The EPA
tends to be more academic than the DOD/DOE.  The EPA can adopt a more pure
definition of P2 because they are not impacted by its adoption.  The DOD and
DOE, because of budget/funding cycles and the color of money, tends to call
anything that reduces a baseline waste volume or cost P2.  If Congress funds
DOD waste treatment under a P2 budget, then waste treatment is P2.  The
purists may scream, but its just the way it is.

Mike.callahan@jacobs.com

> ----------
> From: 	Oscar_J_Valero@rl.gov[SMTP:Oscar_J_Valero@rl.gov]
> Reply To: 	Oscar_J_Valero@rl.gov
> Sent: 	Friday, October 23, 1998 12:19 PM
> To: 	rec3@po.cwru.edu; Callahan, Mike; dick@unr.edu
> Cc: 	p2tech@great-lakes.net
> Subject: 	RE: Questioning the P2 Hierarchy
> 
> P2 hierarchy:
> Source Reduction
> Recycling
> Treatment
> Disposal
> How about Energy recovery, Oh, lets not forget the DOE most recent
> addition of SEGREGATION!
> complete isn't it?
> 
> Oscar Valero
> Waste Management Hanford
> 
> 
> 
> > -----Original Message-----
> > From:	Ralph Cooper [SMTP:rec3@po.cwru.edu]
> > Sent:	Thursday, October 22, 1998 6:57 AM
> > To:	Callahan, Mike; 'Kevin Dick'
> > Cc:	'P2Tech'
> > Subject:	Re: Questioning the P2 Hierarchy
> > 
> > I began working on P2 in 1985, shortly after helping write HSWA as a
> > representative of my employer and trade association.
> > 
> > There really is no P2 'hierarchy' except in the minds of some who
> > haven't
> > really thought through the issue.
> > 
> > The goal of the entire activity is to reduce the costs (to society,
> > the
> > world, the locality and the business entity) of the needs met by the
> > products produced by the business entity.
> > 
> > Sometimes a greater cost reduction, in all terms (including
> > environmental
> > effect) can be achieved by what is called treatment.  An example that
> > occasionally works that way is fuel substitution -- burning for fuel a
> > waste
> > and thereby NOT burning coal or oil.
> > 
> > Sometimes it is achieved by efficient use of the material in the first
> > place, so that there is little or no waste.
> > 
> > Sometimes it is achieved by changing the product (note the lack of
> > chrome
> > bumpers on automobiles -- that was an effective, if unintended,
> > pollution
> > prevention).
> > 
> > Sometimes it could be achieved (but rarely is) by changing the
> > perceived
> > needs of the clients or customers of the manufacturer.
> > 
> > A corollary problem is that we need to consider the reduction in the
> > risk of
> > spills and other accidental releases, the lifecycle effects of the
> > product
> > and associated costs, and so forth, when we determine the optimal
> > pollution
> > prevention in a particular circumstance.
> > 
> > By doing a complete analysis, sometimes we find that the best outcome
> > is
> > treatment, but not often.
> > 
> > The point is, there is no overall best solution.  Each specific
> > situation
> > requires a broad analysis that is open to a variety of solutions and
> > which
> > favors none but the one that results in the best outcomes for all of
> > the
> > interests involved -- the environment, the client/customer, the
> > manufacturer
> > or producer, the employees, and the locality/society, etc.
> > 
> > Ralph
> > Ralph E. Cooper, Ph.D.
> > J.D., Class of 1999
> > Case Western University School of Law
> > Cleveland, Ohio
> > 216-991-6837
> > 
> > Reply to rec3@po.cwru.edu
> > 
> > -----Original Message-----
> > From: Callahan, Mike <Mike.Callahan@jacobs.com>
> > To: 'Kevin Dick' <dick@unr.edu>
> > Cc: 'P2Tech' <p2tech@great-lakes.net>
> > Date: Wednesday, October 21, 1998 9:24 PM
> > Subject: RE: Questioning the P2 Hierarchy
> > 
> > 
> > >In the early days (@1984-86), there was much discussion over
> > definitions
> > and
> > >hierarchy as it related to waste minimization.  Waste minimization
> > split
> > >into source reduction (product changes and source control) and
> > recycling
> > >(reuse and reclamation).  Source reduction was ranked higher over
> > recycling
> > >in terms of environmental desirability.
> > >
> > >In simple terms, it's reduce, reuse, recycle.  For the non-purist,
> > you can
> > >add treat to the end of this list.  As you move down the chain, your
> > energy
> > >and environmental impacts go.   The recycling of a waste material
> > takes
> > more
> > >energy than if you can reuse it as is, and the reuse of a waste
> > material
> > >takes more energy than if you reduce the initial generation of waste.
> > >
> > >What amazes me is that someone thinks this is worth a masters degree.
> > I
> > >believe all these relationships were discussed in the USEPA Report to
> > >Congress (EPA/530-SW-86-033) back in 1986.  A little digging through
> > the
> > >popular literature around 1988-92 would uncover many pertinent
> > articles.
> > >
> > >The law of entropy is not the issue.  The needed study is why do
> > people
> > tend
> > >to think in the reverse order ?  Recycling may use more energy than
> > source
> > >reduction but it tends to take less brain power and dedication.  Its
> > easy
> > to
> > >throw something in a still and push a button, but to eliminate the
> > use of
> > >some material takes creative effort.  This is not an engineering
> > problem,
> > >it's a social problem.
> > >
> > >Just my two cents,
> > >
> > >Mike.callahan@jacobs.com
> > >
> > >> ----------
> > >> From: Kevin Dick[SMTP:dick@unr.edu]
> > >> Reply To: Kevin Dick
> > >> Sent: Wednesday, October 21, 1998 9:47 AM
> > >> To: p2tech@great-lakes.net
> > >> Cc: tw1712@erols.com
> > >> Subject: Re: Questioning the P2 Hierarchy
> > >>
> > >> What P2 Hierarchy??
> > >>
> > >> The Pollution Prevention Act includes an environmental management
> > >> hierarchy which identifies source reduction (P2) as the preferred
> > >> environmental management technique.  To call this a P2 hierarchy
> > trashes
> > >> the whole concept of pollution prevention.  Not that it hasn't been
> > >> done, but it certainly shouldn't be referred to as a P2 hierarchy
> > in a
> > >> masters thesis.
> > >>
> > >> Kevin Dick
> > >> BEP-UNR
> > >> (702) 689-6677
> > >>
> > >
>