Pollution Prevention - Urban Watersheds: Geology, Contamination, and Sustainable Development - page 443

13.3.5 Step 5: Preventing Pollution through ESPM Methods
Pollution prevention can be implemented with a stepwise evaluation process that proceeds
from the most preventative measure to the least preventative measure. This process is
referred to as ESPM and consists of the following steps:
• E limination: Not using potentially harmful chemicals
• S ubstitution: Using a less potentially harmful chemical instead of a harmful one
• P revention: Using engineering controls and other measures to minimize the
potential for a release; employed if eliminating or substituting a potentially harm-
ful chemical is not possible.
• M inimization: Reducing usage of harmful chemicals or a reduction in generated
wastes through process changes, recycling, or other methods.
After steps 1 through 4 have been completed, a focused and achievable plan for pollution
prevention can be developed and implemented. Facilities where a synergistic effect could
be realized between the environment and the contaminant properties should receive the
highest initial effort. This effort is characterized by aggressive pollution planning initia-
tives for reducing the potential risks (Rogers et al. 2006).
13.3.5.1 Elimination
The most aggressive form of pollution prevention is elimination of hazardous chemical use.
Where possible, elimination of hazardous substance use is the preferred pollution preven-
tion method because it is the easiest to manage and has the greatest benefit to the environ-
ment. As noted in Chapters 7 and 8: if there is no hazardous chemical use, there is not risk.
In most cases, total elimination of hazardous chemical use is very rare, so the elimination
of chemicals should focus on contaminants with high CRFs. For example, chromium VI
and DNAPL VOCs have high CRFs for groundwater, while PAHs, chlordane, PCBs, and
mercury have high CRFs in soil.
A crucial step in the process of eliminating hazardous substances is to develop a chemi-
cal ordering procedure. This procedure protects against unauthorized hazardous sub-
stances making their way into operations at the facility without prior knowledge. All
proposed chemicals or substances should undergo a review process to evaluate whether
they are acceptable for use.
13.3.5.2 Substitution
The next most aggressive form of pollution prevention is substitution . Substitution involves
using alternative chemicals with the goal of greatly reducing risk. For instance, if a facility
uses DNAPL VOCs for cleaning, an effective substitute may be citrus-based cleaners. The
Solvent Alternatives Guide provides options and guidance for evaluating available chemical
substitutes for common solvents (USEPA 2010b).
Other alternatives exist for chemical substitution. For instance, mercury-containing
devices such as switches, thermometers, and monometers can be substituted by digital
devices. Liquid transformers containing PCBs can be substituted by dry transformers or
with transformers not containing any detectable concentration of PCBs.