Pollution Prevention Problems: A Case Study of the Status of P2 Programs on Whiteman AFB, Missouri With Comparison to Salt Lake City, Utah and Salt Lake County, Utah

David H. McCray

Research paper prepared by David H. McCray, Major, USAF, Environmental LL.M. Candidate, University of Utah, College of Law


Congress recognized the potential for serious harm to the environment and to human health and enacted several different legislative acts that were designed to prevent such harm. Congress stated the policy of the United States regarding pollution prevention when it enacted the Pollution Prevention Act of 1990 (PPA):2 "The Congress hereby declares it to be the national policy of the United States that pollution should be prevented or reduced at the source whenever feasible; pollution that cannot be prevented should be recycled in an environmentally safe manner whenever feasible; pollution that cannot be prevented or recycled should be treated in an environmentally safe manner whenever feasible; and disposal or other release into the environment should be employed only as a last resort and should be conducted in an environmentally safe manner."

Congress clearly identified the preferences in the treatment of waste in the above stated policy--pollution should be prevented at the source. Preventing pollution at its source was a major departure from earlier environmental statutes that focused on the treating of the waste, not the prevention of waste.

The Office of the President has also issued several executive orders (EOs) specifically dealing with waste minimization and pollution prevention. This paper will discuss some of the EOs that apply.

Congress and the EOs have taken away some of the choices that industry and the government had regarding the treatment of waste. However, the choice is still available as to whether to just comply with the minimum requirements or to surpass the requirements, thereby having a stronger impact on the health of the environment and humanity.

The United States Air Force has made some landmark choices in the management of waste and has taken a very proactive role and their programs are part of the main topic of this research paper. One purpose of this paper is to review certain environmental regulations and to see how the Air Force compiled with these regulations. This review will cover the regulations and guidelines implemented by the Air Force, reasons why they selected certain methodologies, equipment used to achieve goals and some pollution prevention (P2) success stories. Specifically, I will focus on Whiteman AFB in Missouri and its environmental management program.

The second major portion of this paper is to analyze whether or not Whiteman's and other Air Force success stories in the P2 arena can be applied to civilian communities and industry. Industry has made major strides in P2, mostly to reduce cost and exposure to liability, which is not insignificant reason for making the change. There are also some communities that are working to recycle and reuse resources, but are they doing enough? My contention is that these communities can use the programs developed by the Air Force and make a significant impact on their management and elimination of waste.

For example, what do communities do with green waste they pick up from your curb and city parks? How do they treat oil, antifreeze and solvents recovered from their city transportation system and government fleet vehicles? Does the community recycle bottles, cans, cardboard, etc.? What is the size of their recycling program? What is the emphasis on reducing waste streams? These are just some of the issues handled by Whiteman AFB that a municipality may be able to implement in an efficient and productive manner.

The paper then discusses important definitions related to the topic for clarification purposes. With these few definitions explained, it is important next to turn to the more prevalent statutes that discuss pollution prevention and waste minimization. This discussion is brief and not meant as an all-inclusive analysis of the legislation. The paper than looks at the EPA's suggested successful P2 program.

The case study of Whiteman AFB follows this section. A critical look at the methods and procedures Whiteman has implemented is undertaken. The program is then compared to the EPA suggested program.

Next, a look at Salt Lake City and Salt Lake County's P2 program. Telephone interviews were completed with individuals involved in the process and the findings are reported in the paper.

Finally, the conclusion lists 10 steps that the City and County should pursue in order to establish a viable P2 program and also discusses the necessity for, and benefits of such action.