A Compendium  of Exercises and Activities
         U.S. Environmental Protection Agency



      s manual provides instructors with descriptions of '"'
and duplicated in any course or workshop.

                  List of Training Exercises and Problems
 1. The Amazing Blitzfh Exercise
 2. "Blitzfh Parts Exercise
 3.  Fun Factory
 4.  The Oily Washers Game
 5. The Green Square Game
 6.  Abes' Electric Company Problem
 7.  Solvent Reduction Case Study                                       •
  8.  Pollution Prevention Program Planning Problem
  9. Colarama Paint Factory
  10. Bluemoon Inc. Multirmedia Training Exercise
  11  4-Ways Management May Evaluate Prevention Options
   12.  Reactions in Implementing Change Role P^y
   13. Gase Studies                   •
   formaUy conductmg the exercise witklarger groups.
   Deborah Hanlon of US Environmental Protection Agency at (202) 260-2720.



     Technics                   lSlly^e^to1??! Nation .of
                                 is not taX.n into account .
     cross^media         g
considered when ^^^ns.rrlng the contaminants from
alone may create a new «J*t«J£ writer may consider requiring, a
                    - prior lo^r in Place of air  stripping.
    ,  Th. new corrective action |
 emphasis on source """f'^pucy, waste reduction

                    * * * September, 21,  1990 * * *


•             ,t4nCFR
A.    Pursuant to 40 CR -
                                        and Section 3(K)5(h)olRCRA.4^U,S:C.69:5ih).ihc

                                          Administrauir. at least annually, a waste m.n.rmzauon
B     The Permittee must certify that:

            human health and the environment.

       information in the Waste Reduction Impact Statement:

             An identification of the annual amount and types of hazardous waste that are-generated:

             For each waste stream, an Identification of the source of generation of these hazardc.us
                      \     .'.•       -    . -.        '.',-'          ...-,,,'     .          :
             wastes:               "                                     -.-,.'.
       (1 ,
           ,  19X4. at a minimum: and

        (4)   a program and scheduie for implementing the feasible hazardous waste reduction   .

   D.   In

        ifH^HlUlllll iijv***>* •••«»«»•• ..— - — -    .   »         ^

        the Waste Reduction Impact Statement required.
                                                                 C above.


        Pollution Prevention Orientation Workshop,

                          Instructor's Guide

1.  Instructors greeting and introduction:                 instructor Notes

Welcome people to the course and make them
        K  ^  tof/?

             by Deborah Hanton and Jeuli Bartenstein U.S. EPA

                    General Information


topics that you feel comfortable in teaching.

anS :ntlrS«ng wo^shops is one way to accomplish this goal.
        ffl"d timing



  ;±r^"^^               that may be ot ""^
  interest to them.

       Be prepared and ma*e sure your have ^workshop essentials:

Finally snow EPA's formal definition  of pollution prevention:'.     •   instructor Notes
 Soofies  t« f«5  sectors of society  including Industry,
         words or p/irases from c/ass c°ntribut
          °      words that cant,* used in the EPA
 Make sure participants understand the environmental protection
 Werarchy that emphasizes prevention as first choice but also
 conSs recycling, treatment, incineration and disposal o
 ^^Sd^SittSi as  important components en the overall
 •Sy tor Environmental protection.  *«^™g^
  reduce the burden of costly treatment, recycling i and disposal
 •W ^ "*5ny cases.   This wu. be illustrated m the  EPA
  Pollution  Prevention slide  show.
  Show EPA's  or your own  Pollution Prevention s//ef<
  ^Dreoared script of examples of pollution preven /on
   Quesf/on  audience:  What are some of the reasons we are
   now turning our attention to pollution prevention?

   5, Barriers and Incentives Piscovery Exercise:

   Tralnina  Obiective:  To help participants think about the
   SStt'SSSweiillno pollution P^ention options and to
   find some  creative solutions to these problems. Studens will


4.  What   is   pollution   prevention?   (clean
Training objectives:,
a. To ensure participants understand what pollution prevention
 s and is not  and;
managing   or  regulating pollution  after ,t is generated or
released into the environment.
      sure that you, as the instructor,  have a clear grasp of the
           i SSSZ «,»«»
Agency memos etc.
         activltv  to  help  participants understand  and
        J5? the* cSncep? £ po..uPtlon prevention:
        each word separately In own words)
 fire, crime etc. (concept is important)
 Show definition of prevention;
 .«0^iuitv  that  keeps  something  from  happening.
 an?«c.pat.on of outcome" source:  Webster's Dictionary
  pollution as defined by EPA's Science Advi
   Ask participants to define pollution prevention in plain English
   (what it means to them)
                                                           instructor Notes

                                        [   ,-•-._      \ .       =       ,
Discovery Training Activity:                                 Instructor Notes
n,v/Vte class into groups of 3, or 4 to work  on  problems and   '
pwniK^                                         J

.the program,
 Report Out from each group.
 Discussion among groups on lessons learned.
 7. Pollution Prevention  Resources
  information pertaining to them.
   Resources, where to go for more information.
  Start bv discussing the Pollution Prevention Clearinghouse,*
  ORD and OPTS Studies on Pollution Prevention, State act,v,t,es
  and resources.
  The Pollution Prewntloh/ Information ^earlnflhouse.
   ordering and
   fact sheets)
    Refer to th* Pollution Prevention Resources and Tra/n/ng
    Discuss further needs.

identity potential programs, solutions an d incentives th, at vv,tf       lnstructor Notes
help to  resolve/overcome these problems.  Report Out on
solutions   Allow discussion .  Ask  participants for additional
Pollution Prevention.


                  fnr '
 improve public relations
 Save money in long run          uu
 Protect worker and community health
 Give tax incentives to upgrade
 Recognition programs             .
 Technical assistance  and info dissemination

          for mnsumers
 Provide education
 Make it easy
 Make it inexpensive etc.

           for FPA employees

  Employee award program
  Get top and middle management support
  Provide training on what to do etc.
  6. How to do Pollution Prevention.

    (Hands on exercise  demonstrating that  you don't
  need to be a Rocket Scientist to Implement pollution

  Depending  drt audience you may want ^<^**«J
  examples  of  pollution prevention aTOOr?P|lshtme"!tsah^?  *
  conduct a descriptive short Jecture on  how to establish  a
   pollution prevention program/

   Discuss the essential components as identified in EPA's Facility
   Pollution Prevention Guide EPA#  600-R-92-088.
   i.e. top management commitment, goals, pe riodic assessments,
   adcountinq practices, technology transfer and  evaluation.
         e ements are applicable to all sectors and programs.

8  Closing and Evaluation:                           Instructor Notes

 evaluation of class.                         , -

                                                 '    :,•
 ;Cle.aringhouse at (703) 351-4004.-

     Recommended Reading List for Pollution Prevention Instructors

1.  A Whack On the Side of the Head, Von Oech, 1985.
2.  Hazardous Waste Minimization, Harry Freeman (ed.)  1990. McGraw
3.  Serious Reduction of Hazardous Waste, US Congress Office of
   Technology Assessment 1986.
4. The Age of Dirrdnished Expectations, Paul Krugman,  MIT Press 1987.
5. Conceptual Blockbusting, Adams, 1986.
6. EPA Pollution Prevention Facility Guide, 1992
7.  Prosperity Without PoUution, Oldenberg, Hirschorn,  1990
 8.  Quality is Free, Philip Crosby,  1987.
 9.   Instructor Training Workshop Manual, EPA Institute,  1988.
 10.  UNEP Audit Manual

   Discovery Exercises for
Pollution Prevention Training


                  The Amazing Blitzfn Exercise Role Play;          : •  -

Purpose: To motivate audiences, to promote pollution prevention through ".
enhanced communication and teamwork by taking them through a mock industrial
exercise.  The exercise will demonstrate the importance of planning for
prevention and will illustrate some of the requirements of a comprehensive
facility program. .                          ,

Time required:  2 hours    Materials needed listed on exercise.

Instructions: Assemble participants into teams of 4,5 of 6. Assign each a role
to play in the manufacturing of the Blitzm.           /

Provide each team a new factory floor (flip chart sheet) and a copy of the
attached Blitzfn Exercise.

After reading the exercise together, tell the teams they have one hour to produce
the blitzfns.

During the exercise call the leaders to staff meetings, call the engineers to staff
meeting and tell them that EPA has passed new laws that require companies to
shut down  for 5 minutes if there are any hazardous materials spills, have
employees attend Union meetings, etc

At the end of an hour visit each team and begin to inspect Blitzfn and factory.
Play role of critical customer and inspect each Blitzfn in front of entire group
for specifications. Notice  spills, wastes, check hands for contamination etc.

 After each plant is examined, begin discussion.
 Suggested Discussion questions:

 1. What did you do to minimize waste and pollution?
 2. What roles were important in the process?
 3. Was there top management commitment?
 4. What were some of the barriers to minimizing pollution?
 5. What recommendations would you make to WHO to produce more
 environmentally friendly Blitzfns?
 6. Based on the experience gained hi this exercise, what do you think
 are the key elements of a comprehensive pollution prevention

The A mazing Rlitzfn
      D. Hanlon & H. Freeman, US EPA
       Congratulations!  You have been chosen to be part of a team responsible for producing the
new blitzfhs.  Blitzfhs are devices used by the WHO to produce magic cures for diseases. These
new blitzfns'are similar to other blitzfns produced in the facility, but are hew and improved and
will require the establishing of a new production line. There have been several teams of
individuals such as yours that have been given the opportunity to demonstrate the best way to
produce these new blitzfns. The team that produces the best blitzfh will open up a new factory in
the Bahamas next year. Your group is to produce	of the blitzfhs.

       Our CEO, Ms. Letsdoitbetter has recently become enamored with the current push in the
country towards pollution prevention and has recently issued a policy statement to guide our

       "There is nothing more important than preserving our environment We will do everything
we can do to prevent pollutants to air, water and land. We shall produce no waste or pollution
before its time and we will strive to produce environmentally friendly products that contain no toxic
elements".                       .              ,

       In addition to being an overall hard worker, you will have the duties outlined on the card
provided to you by the instructor.

       The specs for a blitzfn are on the reverse side of die page. (Two sided copying, great
pollution prevention idea.) Your production materials, processing equipment and costs are
outlined below.
 paint brushes
 reaction vessels
 mix tanks
 markers (ink has hazardous
 air emissions)
 plastic spoons
Materials                       Costs
             blue powder paint (hazardous)	no cost
             yellow powder paint	no cost
             9"  x 11" paper board	$3.00
             wooden craft  sticks	$0.25
             paste  (voc's)	no  cost
             drafting tape	...$1.00  per inch
             napkins	»	no  cost
             paper clips	$1.00 each
 After your group decides how its going to produce the blitzfns, you should send your Purchasing
 Agent to the Central Store to get the necessary materials:


 1.     Minimi^ wMtea and reduce hazardous emissions from your factory. Spend sufficient
        time in your design phase to consider options to minimize waste and reduce emissions.
 2.     Your blitzfn must perform as required by the specs.
 3.     Criteria for selecting the "best1* blitzfn:
                 Time to produce
                 Environmentally Friendly                .
                 Pollution Prevention Program-.
                 Customer satisfaction
                 Employee safety

                               Role  Assignments


 do i ™erc way/but you wiU have to make that decision,
 Quality Control/Safety Ofricer/Regulmtory  Specialist

 environmental/OSHA regs.
 Plant Engineer/Pollution Prevention Advocate
  could be improved.

  Purchasing  Person/ Worker
               '                                                      '
   usually just produces headaches. You JJJ**%wJ51L^4!i can be difficult. Incidentally,
                 t^£^^^%^°*«* *• *» wm"° *•*
                                                           le project.
   n ^\^*i^^* j**'»*j'»'w'" ~~"(    _  .
   been giving you a hard nme.

                    The Amazing Blitzfn Parts Exercise

Purpose:  This is shorter, simpler version of the Blitzin exercise.
Participants will become aware of some of the conflicting demands of working in
an industrial setting and trying to minimize wastes and pollution. The exercise
demonstrates the importance of planning, communication arid teamwork in
preventing pollution.

Time required: One hour   Materials required are listed in exercise.

Instructions: Assemble participants into teams of 4, 5 or 6. Assign each person
a.role to play in the manufacturing of the Blitzfh part.  Provide each team a clean
factory floor (flip chart paper). Read instructions together and give the groups
25 minutes to complete two blitzfh parts. Call staff meetings and conduct
inspections during the activity. At die end of 25 minutes inspect each factory and
examine the parts to ensure quality. Be a critical customer looking at both sides
of the blitzfn, inspect hands. Begin discussion.

Suggestions for discusssion:

1. What did you do to minimize waste and pollution?
2. What  roles were important in the process?
3. Did the workers contribute to or hinder pollution  prevention
activites and ideas.
4. How important was top managments1 committment to pollution
5. What were the barriers to prevention in this exercise? What are
the barriers to prevention in industrial situations?
6. What kinds of incentives could be provided?
7. Do you have recommendations for more environmentally friendly
blitzfn parts?
8. What do you think are the most important considerations In
developing a pollution prevention program in an ipdustrial setting?

    The  Amazing  Blitzfn*  Parts  Exercise

•Blitzfns are imaginary devices used by the World Health Organization to cure all
diseases. New "green" blitzfn parts need to be produced to improve upon the old
uncoated blitzfn.            .

Instructions:                        :                          •
    1.  Two uncoated blitzfn parts are provided.Your team must
. coat each part by painting the part green on one side and
labeling (in black)  the other side "BLITZFN".
    2.  All work must be completed in 25 minutes and ready for
inspection by the World Health Organization representatives. -
     3. Your goal is to coat two blitzfn parts on time, at the
least expense, with as little waste as possible.
    4.  World Health Organization will want to know after the
exercise is over what you did to minimize pollution  and what
recommendations you can make, based on this experience,  to
produce safer, more environmentally  friendly BLITZFN parts.
    5.   Keep track of total costs for producing your blitzfns.
        (including costs for disposal)
    6.  After your group decides how its going to produce the
blitzfn parts, you should send your Purchasing Agent to the
Central Store to get the necessary materials, keeping in mind
the production requirements, (see reverse)
                  •--'..  \ - -".       _    '   .   ,    •
    These materials are available from the Store:

Production  Equipment       Materials                 Costs
(no  cost)
spoons                     blue powder paint (toxic)... ,$1 per spoon/$.85 1/2 spoon
markers (ink has hazardous       yellow powder paint......... $1 per spoon/ $.85 1/2 spoon
air emissions)                wooden craft sticks	$.25 each
paintbrushes                 water.....	.	...........$.25  per spoon
 napkins                             .
 blitzfn part (unpainted)
• .mix tanks   _ .-  "-•/.•    .''"'.. ~x L-  '    -  •     •-•"'.  ..-.'.'.•• '.-.'••
                      ' (-       \   ''.'•'    '     - '
• •-•    . ':•  •••  "  '   •-'•  '•  •   .  over  •.  -•"'« "v^'     "•:.  / •   ..  .

                  Production Requirements:

1.   Green paint used for the exercise is made from one part
blue paint and two parts yellow paint.  One part water per one
part paint is required for adequate coverage.

2.   Minimize wastes and reduce hazardous emissions from
your factory.  Spend sufficient time in your design phase to
consider options to minimize waste and reduce emissions.
         t       *   •                             ,  •  ' •
3.   Your blitzfn parts must meet all specifications.

4.   Criteria for selecting the "best" blitzfn:
         * Time to produce
         * Cost                     .'•••'
         * Specifications
         * Environmentally Friendly
         * Pollution Prevention Program
         * Customer satisfaction
         * Employee safety
         * Total waste generated

WILL BE A "WASTE". Therefore in closing your facility
after the exercise is over,  you will be required to send all of
your hazardous wastes (materials and equipment contaminated
with blue or green paint)to an incinerator at $10.00 per item.
All non-hazardous waste (materials and equipment) will be
shipped off site for recycling or disposal at $1.00 per item.
 6.  All work should be carried on the "plant floor,"

                                   Role  Assignments               •   '   ,


       You .are the one responsible for; making this happen. You will have to answer to WHO if
there is a screw up. What ever happens, you better have the blitzfh parts when the bell rings.

       Now this pollution prevention stuff is OK if it does not get in the way of producing the
product.  Be ruthless in sticking to the main business at hand, i.e. producing a product on time
that meets the spec. Now it may very well be that the best way to get this done is to let the troops
do it there way, but you will have to make that decision.
               - .             '   •     '    -    - '              '   ''     "       •     ,  .   I
Quality  Control
       You don't really care to much about the time allotment, but if the Blitzfn part does not meet
the spec, or if somebody gets hurt, you are in trouble. Make real sure the workers are doing things
safely and correctly.

Plant  Engineer/Pollution  Prevention  Advocate

       You sold WHO on this pollution prevention stuff. If this project flies, and you produce
less waste you will be recognized.  You will also be recognized if this pollution prevention stuff
gets in the way of meeting the deadline. Get really involved in coming up with creative ways to
reduce.  Keep notes on how your group could have done it better.  You will be responsible for
identifying the necessary requirements for an overall pollution prevention program and selling it to
top management                                                              ~

Purchasing Person                                    •
                                - /•     •     •     •          •       •-.     • '   '  .
       You are responsible for the materials being at the plant when needed. While you want to be
sure the plant uses only what is needed, you want to be sure that they do not run out of materials.
Plan your purchases carefully before going to the Central StoreJceep track of all costs.


       You and your feUow workers have to make this thing. The pollution prevention stuff
usually just produces headaches. You just want to get it done and go home. If your team mates'
suggestions make your work easier, they are OK. Otherwise you can be difficult Incidentally,
there is a meeting tonight of the American Federation of Blitzfn makers that you want to go to.  The
Union is concerned with all of the toxic materials the workers are exposed to.


The  Fun Factory

       Interactive Exercise


     Waste Reduction Training
        Waste Reduction Institute
  for Training and Applications Research, Inc
             February, 1991


   Public Policy staff in regulatory and/or policy-making positions are in an important position.
They can influence waste generators in industry to adopt methods of environmental protection.
This training manual outlines an exercise which can heighten public policy staffs' awareness of
how waste is produced^
 solving techniques.
    TT« instructions in this manual show 
Principles  of Operation
    Nearly all training to date in waste niinimization has been based on lectures and case studies, all
of which are more properly termed education. Training to date has been given a lesser priority
because the information to conduct training has not been available.
    Our early training attempts at verbal role plays and small group discussions, while useful, did
 not prove as powerful, successful, and flexible as the Fun Factory training exercise. It's a fun
 exercise and we believe that people who have fun while learning are more likely to retain what
 they've learned We are employing the principle that hands-on training allows trainees to become
 participants rather than observers.  People would rather have the actual tools to work with rather
 than reflecting on concepts.
     We determined that the regulatory audience who will participate in this exercise may not be
 familiar with what it is like  to function in an industrial setting. Because of this, we wanted to
 construct an exercise to give these participants a good sense of how a business operates day-to
 day.  By participating in this exercise, they will also acquire a sense of how waste is generated and
 subsequendy learn to recognize processes that create waste. Finally, with their enhanced sense of
  an industrial setting and knowledge of how waste is.generated, we believe these participants will
                .                "  "             i •
  be more effective in promoting waste ntinimization in their respective positions.
     To motivate audiences to promott, persuade and encourage waste minimiation by taking them
   thrtHighamodciiidusmalprocess. Tnis mock process is intended to heighten the participants'
   awarenessof ,he imports of conimumcati™^                         In addition, it is
   minimization, and resistance to change.
                WRITAR,  1313  5th  ST SE,  Ste 32S, Mta«P«* JJN   51414-4502
                              Ph. 612.379-5995   FAX  612-379-5996

Objectives-                                    -
    We have several objectives in mind for thisexercise. One is to help participants not familiar
with industrial processes to understand these processes. Another is to help participants understand
the challenges and frustrations of reducing waste in an industrial setting. A related objective is to
show the participants that by taking part in this exercise, they may find their previous
 understandingof was*reduction aiuiitsi^
 waste reduction in an industrial setting. Our final objective is to   p parncipan
 the importance of communication in waste reduction efforts, and to become aware of some of the
 many factors that make it difficult td a^
 relations, customer demands, and competition.

                                                                                         \. 4
                                  Participant  Roles
An ideal sue for the group of participants is 20 people.
•  acilitat
    The facilitator would be ideally filled by a person who is comfortable with taking charge and
leading a group of people through an exercise. Since the successful completion of this exercise
depends on a high level of interaction among the participants, the facilitator should also be adept at
promoting this interaction by his/her own example.
 •     orrier '
    The facilitator takes on the role of the Customer after the Play-Doh machines are handed out
 The Customer's role is to place orders, create pressure, demand quality, and generally harass the
 teams with the goal of creating an atmosphere of good natured chaos. The Customer's job begins
 with circulating to each team and placing the first order with each "Big Boss.rAfer the teams
 have begun working, the Customer begins requesting sample parts from each team and inspects
 their quality. While inspecting each team's product, me Customer mentions how well their
 competition is performing. The Customer continues to inspect each team's product, mentionsthe
 competition's performance, and how important the job is to their company throughout the exercise.
    Rig BOSS
      Keep your back to the process at all times. Everything is always late. You only care about the
  bottom line. Your links to your team are through Quality Control and the Production Manager,
  communicate to your team through them.
      The techs are lazy, QC is crazy, and the boss is on your case.  You can look at the process
   once every five minutes. Get those pans out now!
       Everyone wants to slip something by you. Watththose techs carefully. You're the only
   guardian of the company's good name! If it's no good by you, it's no good.
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                             Ph. 612-379-5995   FAX 612-379-5996

            rrechlfTwo Techs per Team)
   You are underpaid and overworked. Only you uridersmd the process. If only management

could get organized! Don't let them push you around    ;               „

. ££BAJnSBfi£Ioj (Optional)
   You know that  every facility has something to hide and your job is to find it The paper work

 is never filled out right; their records are never where they* supposed to be, and all the labels are

 upside down.


1.   Assemble attendees inn teams of five and seat them around the "production floor." (see
     Materials Needed, page 9, line 4)
2.   Assign a city or country name to each team for identification, and write die team names on a
     flip chan or chalkboard.
 3.  Explain to the teams that they are in competition with.each other to produce a critical^' for
      the military, and they will produce this "pan" from play^loh using the Fun Factory machine.
      Tell them "that since this is work for a defense contract, me pa« have to be made to exacting
 4.   Explain that Red play-doh is a toxic metal. Yellow play-doh is toxic because of volatile
      organic air emissions, and Blue and White play-doh is non-»xic. Explain that if toxic play-
      doh is mixed with non-toxic, the part is contaminated and considered was«. Write these
       specifications on the flip chart for the players'reference.

  5.   Explain that anything that is.contaminated or isn't finished product is considered waste,
       therefore it can't be recycled and should be placed in awaste pile.
  6.   Assignees by handing out the index cards (see Materials Needed, p.9, line 5,  and
       Participant Roles, p.4). Roles can be assigned arbitrarily. Any extra people can be
       regulator!*                                    .
        a 30 minute astern and then * second90 minu» exaciie. A half-hour break can be
                                           " \ ' *""
        inserted in the exercise.
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                              Ph.  612-379-5995   FAX  412-379-599«

8.   Tell the teams that you arethe customer, and that you wiU order only through the Big Boss.

9/TeU the teams to open up the machine^
      pause with your instructions.                                   .
          . ,     .  •            ' :        '.',..                    i --.''..
 10.  Give the teams the first order to make 10 blue stan with a thicloiess comparable to the Ud of
    '  the PlayDoh can. Explain that the pam are to be extrud^ wim the m
      hand. Tell teams that finished parts should be smooth on bom sides, an^

"•:'..    colors/Write me order and^

           k    each team's progress. Begin quality control at this rime, checking for parts that are
       not smooth or are shaped badly.                                      "  :  •  ;  •/

  12'. When any team is near completion of m^
       white stars with the same thickness of me blue stars.
  i     about me content of this and future orders.

   13  Place the third (5 blue rectangtes)and
      ^ o-'—iido^Wa.^^^^^
        the smaUest possible, with the same thiclmess as the stars. T^
        long as an index card is wide.

    14  AfteryouarecertamaUof^
         announceto allof me teams that the^customer has changed their third orders
         and the fourth Older to 5 blue rectangles.  Tins win (and is intended) to cause confusion and

         dismay among the jeamsuthe^
         machineWand guard against color contaminanon. ;

;--" 15.   Conanuecheckmg^^
          parts for streaks of color resulting from sloppy color changes.

16.  Remind the 'teams that they are in competition with each other. Since teams will work at
     different speeds, tell them you might hive to pull the job from one team and give it to
17. At 90 minutes,^ the Banian
     their machines. Determine who finished first Inspect each team's finished pans for
     conformity to the standards of smoothness and shape and inspect each teams waste piles and
     notetheamountofwastegenerated. You may wish to weigh each team, waste with a small
     scale to determine which team generated the most waste.

 18.  Askmeteamstoappomtagroupspokesman^^
      Write responses on flip chart. Ask them what they think is wrong with the exercise as an
      industrial process (process analysis). Next, ask what they would change and why (options
      generation). Then ask each team what is the first thingthey would modify and why
      (implementation). Last, point out the insights they have gained from the exercise. Examples
      of insights include:
       a. how this exercise can hdp pariah n^
          complexities of waste reduction in an industrial setting. TOs includes the added
          complexity and additional waste order changes can cause, especiaEy with small orders
           which require the same "retooling" and cleaning as a large order.
        b. aEw«« reduction kk« derived from this exercise cam^
           often the case, or should be, inreal industrial facilities.
        c. asenseofhowwasteisactuaUyge^
           waste reduction ideas.
   20.  cleanup.
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                        List of Equipment  and Materials .Needed

  1.  Play-Doh Fun Factories
._2.  supplemental supply of Play-Doh
  3. flip'chart or black board
  4. 24" x 36" sheets of white paper (often removed from a flip chart)
     for "production floor"
   5. packet of 3" x 5" index cards
   6. felt-rip markers for flip chart
   7. chalk and erasers for blackboard


The Oily Washers
    •... •  •    An  '

    Interactive Exercise
 Waste Reduction Training
     Waste Reduction Institute
for Training and Applications Research
         by Thad Schifsky

Outline for Qily Wishers  Exercise

       •v/I     Introduction

Tfceory or Principles
a. Principles of Operati
b. Purpose
c. Objectives
Instructions Section

Equipment and Materials Needed
                           \ '*
    WRTTAR, 1313 5th St SB, Ste 325, Minneapolis£JN5
              Ph. (612) 379-5995   FAX (612) 379-5996

      Public policy staff in regulatory antopolky making positions are in an import

                                 i an exercise which can heighten pubHc policy staffs'
 industrial setting and to use group ^^ problem solving techniques.
       a group through tte Oily Wasn^


 a list of equipment and materials needed for das exercise.
                ™- ^^li^s^5414"502

Principles of Operation
      Nearty all Mining » o*e to was= reduction has been based on tenures andcase studies,
ail of which arem«pn*erty
       We have several objectives in mind for this ewrcise/One isxto help participants not
familiar with industrialprocessesto understand these processes. Another.is to help participants
understand the chaUenges aiid frustrations of substituting aqueous cleaners for organic solvents in
an industrial setting. A related objective is to show the participants that their previous
ofrcplacementeffotsmani^^       Our final objective is to help participants become
 aware of the importance of coounuiucarioc in efforts to exchange aqueous cleaners for solvents,
 and to become aware of some of^the many facton that make it difficult to actu^^
 substitution, such as customer demands and timetables.                       ''..•''""
                     '                     Page       '          '  '
                 WRTTAR, 1313 SmStSE,Ste 325, Mir.^
                           Ph.(612)379-5995   FAX (612) 379-5996


 1.            Assemble participants into teams of five and seat each team around atray.

 2            Explain to the teams that they will be given oily sasel washers along wim three
 different cleaners. Explain that they will be evaluated on how fast they clean the oil from the
 washers, and afterwards, how clean and dry they are in comparison to your model of a clean, dry
 3            Tell the teams that they too are going® evaluate tl»e three cleanen, but during the
 exercise. Tell them theywfll do this by deciding on criteria to evaluate the cleaners and *at they
 will be required to document how they evaluate each cleaner by making notes on each one.

 4             TeU ,he teams that they also have to decide if to ^
 criteria to help determine if they are clean. Tell them they must document these criteria andthek
  evaluation of the washers cleanliness.

  5            Explain to the teamsthatin the past your industry has used organk solvents and
  you've been able to clean 50 washers at a time in one tntoute and they came om dry. Explain that
,  they are expected to meet this standard of 50 washers perminutt.

  6             Handoutthethe^prepreparedwyscontammgm^
  and tell them they wffl have 20 minutes to complete the exercise.

  7             Tell the teams to begin and note the time.

   g.            At the 20 minute mark, tell the teams to stop.

   9             Display the preprepaied flip chart which shows the participants the cost of each
   cleaner  Tell the teams* note the cost of the cleaners aM to deba« the merits of etch cleaner

   10           Attheendofthel5minuteperiod,visiteachtt^
   chosenandwhy. Whiledoing this, pointout the rust that witt have developed on the washers as
   proof that the washers are son wet, in spite of the team's efforts » dry them.

,1           N.H, ask all -the «aras how they know the wuhen.« clean. Toanswo.hu

q«snon, ask .hern «o i*r hack . *« citeia and .valuanoa of how «11 ^ cteao.4
 12           TeUtheteamsyouliavea^
           washen by dunking them in water and examining them for waier beading. If water
                                     to the team and explain that the beading is caused by
 oU still present on the washer.
  for their estimate of the costs of correcting this problem.

        b)     addngth*^

  washers.           .••    • •.-'   .           -.--'••'    •  -

  End of Exercise

                           List of Equipment & Materials

Items #1 through «6 are readied and placed on each of the four trays in advance of the exercise.
Flip chart is readied in advance also (see #8).

1      20 zinc coated steel wishers.
       -stripwishenofziiKcoaiingandimmediatelycoatthemwith                 Place

washers in plastic baggies for transport.

2.     4 six inch pieces of stainless steel wire.
       - should be stout enough to hold one washer at a time.

 3.     One latex glove.

 4.    'Roll of paper towels.
        - provide at least two towels for each team.

 5.     4 eight ounce paper cup*.

Felt-tip markers.* flip chart, chalk and erasers
                                                  if blackboard.
  11.   Paper and pencils for each group.



    - A large tobacco^^                                     .
7,000 xg/month of a|^fu^'|0ctLn engraved, print ing cylinders,
halogenated degreaser^ usea ^  and, other machinery used for
cylinder pans, SP1*"6*^* £0r  cigarette packages.  The    ..
printing cartons a"!solvents are shipped to ££&£*„ site  in  55-gallon drums

ielbrf shtpm;ntSiod?n incinerator facility.

      in  compliance with the  19S4 J^-^Sf^S.
 condition ^d retirement .of thj manifest, ^ ^g^

                                         •conom ically
      Ih. .aciUtyha.
 as a storage facility.  A JSr*  is  any evidence of a release.
replacement of the leaking tank;

ground-water stripping to clean up the contaminated

  A J -. . .K«k^l     '.,--'        ' «     --
       (21  «j»———   • •
            media; and

       (3)  installation of a batch-distillation .unit for solvent


   The Problem .....                   .                  ._
             lono-tern »!!»!"« and effectiveness, and

         .    reduction of toxicity.  nobility or volume of vast.

              (§264.525 (b).).

                    * * * .September. 21,  1990***

             first decision factor, the proposed rule specifies
     H      .5i Effectiveness may rule out alternative remedies
that "lonj-^.;! fJiian Sp targets in the short term, but at the
that might    ieve cJnorP?er future risks that may
                                action. «
     For the second  decision  factor, the proposed rule  says that

th«  facility."
             of** wide range of remedies,"
      YOU have 20 minute, to consider the following questions arid
 evaluate wSSh.r Solution prevention can be addressed in the
 development of this Part B permit.

       m  is cross-asdia transfer presently taken into account
       ( }  wnen corrlctive action remedies are WOjjd or
           rft«»nnroved?  Would you recommend considering cross-
           me5SPIwnsrer in the evaluation of this corrective
           action process?
            this alternative remediation technique?

            can and should you recommend batch-distillation solvent
            reSovSryaS a source control option for  leaking
            underground storage tanks?
            during th« corrective action process.
                    *  *  * September 21, 1930 * * *

Customer reaction        •'     •'.'".••    •".-/••''    :': -        .  '  ,

PP = Pollution preventer         "      .   "
C =- Customer        .         :      '        •_.'•;
pp.   Do you have any particular concerns to the switch to a new cleaner?

C-    Ml ong as I get my parts and they're good., don't care.  That'sr> basic*.  ! -
      be looking harder for a while, though                         •

 PP:   You'll do mote inspections, things like that?

 C:   Right                                           .                   ."/. .^
 PP-  VVill you hold these parts to a higher standard for a while?

 C:   I suppose that's about the gist of >.  We have ha^ good  parts, and we have to be
      careful. .   .      •,•.•" "     ; .  •". - -      ..   '.,-•  "  '-     ', -   . .  ;:-   \

 PP- were you consulted about the change?

 C:    Not in advance,  in fact, we only found out by chance through one of our buyers.
       That doesn't help matters.    ,

  PP:  Have you ever been consulted on a manufacturing change in advance?

  C-   Ohisometimes. Notcommon*. There's not much we have to offer.  Meet the
   .    specs, don't charge too much.


Production reaction   '.. ,

PP = Pollution preventer

WP = Working person
PP:  what do you think about getting rid of the solvent?

WP: It's all right, I guess.: ft sure did smell back here at times.   ;            . .   '

PP-  Dp you think the alkaline cleaner will work as well?
      don't like that
 pp-  What can you do?

     ' expect to get that kind of thing clean with a Irttle soap.

 PP-  HOW do you usually start up a new process?                         ,
                   on. They get the screwiest ideas sometimes about what m,ght work.

Line management reaction -
PP = Pollution preventer
LM = Line-management                                                 -'
l_M:  This sure Js getting to be a lot of work.

pp:  How so?
LM:   Moving all this equipment around, drumming stuff up.  fm having a heck of a «me
      keeping a production schedule.
 PP:   But the end's in sight, isn't it? You look pretty well done with the hook-up.
 LM:  . wish R were so, but I've got to get all my wj. squared away on this deaning
      process, and I'm not even qurte sure how it goes..
 PP:  Has the supplier been working with you?
 LM:  Yeah,right. "Call me if you run into any trouble," he said.  Just what I need.
 PP:  R sure does smell better back her* now, though.  It must be great to be rid of that
 LM: That's one good thing.  «* a whote tot easier to work a whole day back here now.

Management reaction       ""'.'',.

PP = Pollution preventer
M = Management                 :

PP:  Are, you having any afterthoughts about the changes being made?
 /-..-''"       ~        '     '   -        • -        .""'*"           •   *
M:.  Not much.  Seems like it could be expensive.

PP:  How so?           .                                            ;

M-   Well, I have chemicals'to dispose of, and equipment whic^isnt fully depreciated
     which no one wants, and if we have QC problems I could lose customers.

 PP:  But you knew all that, and still decided to go ahead.               ..

 IvV   I pretty much had to. Between worker exposures and the neighborhood knowing
     morVabout what's what in here and all these laws about plans and such, I just had
     to do it.                                                         ;••-.•"

 PP:   Any feedback yet?                       ,

 M-   I'm sure they're all just waiting out in the shop for their first reject so they can
      'rt on me cleaner.  But when it comes right down to it, they have to like rt. They
      have no choice.

Role Play #2 .
4 groups who have a stake in implementing change

-management                                *
-line management
—customers                                                      •

                                                     solvent use from the shop, by
                                                           • ...    	. _• .KI.«*^*if+ ^% TnA
                                  i   A*^**» *** Aiimm9Tf>t ^lOivBi iv wow »* **• • • *    —  *
ABC Co. has decided after «^,ewlf^^^$75(«) will cover replacing the
switching to an aqueous jJ^^JStaoS and purchase of chemicals. Disposal of
degreaser with appropriate tanks •""£            ^ be taken lest it build up in
waste cleaner will be simpler and cheaper, mn car^^ ^ quarrty are still not fully
heavy metals and be judged a nazaraous T^^ resuHs> Material costs will drop
icnnwm  althouah bench-scale testing ga           _i__-  ut •+ +ni^ time extension should
substentiaHy  Parts will take nearly twice as long to clean, buums OTTO e»«
Sect the profitability of the process.
             ^f pnllution DP

       much evaluation, ABC has

 Management position description                            > •                      '

              -              "-'''"•-„         "
 Things to ask about;
      How hard is it to run the distillation unit well enough to get usable solvent?
 -    Can quality be affected by poorV distilled solvent?                ,
 -     How safe are these units?              •                     "      ,
 -     Aren't the still bottoms considered a hazardous waste?
 .     Are these units easier to maintain than a degreaser?
  ,'•    Will I get more control over solvent quality?
  .     Am I to be ahead of the pack if I do this?
  To get you started:
  M:   So, what good ideas do you have for us?
                 • ' '     .                '            ••            ~
  PP:   Have you ever considered recycling your solvent here in the shop?

Pollution Preventer description
       and reliability are big i
      •  plunger cans in place of open buckets
      •  Lid and hoist for the degreaser
      •  On-s'rte distillation and re-use
      •  Replace solvent with another cleaner.
 Things to mention:
      Since there are quite a few distillation units in thefield, technical back-up h good.
       Many questions can't be answered without some testing on specfflo applications.
  .'   These units are built to be operated safely in a shop environment
  To get you started:
  M:   So/what good-ideas do you have for us? •
  PP:  Have you ever considered recycling your solvent here in the shop?

PHILOSOPHICAL       '     \              ..  . '
Management position description
gators don^^
There's no way things can. be accu •***"£•? u         business.  waste reduction

 hey're seeing.            -
 Things to ask about:
 /    Why should I change my processes?
 -     Why do the regulations keep changing?
      How do I know what to do first?
 .    My people have worked with this solvent for a long time, and they're all healthy.
 .,.   I can't stay in business with all this paperwork getting iri theway.
 .    What about all those other guys?
 To get you started:
  M:   See anything interesting?
  PP:  Well, I do think there are some changes you might wanttolookat
  M:  Youknow^wouldn^avetolc^

Pollution preventer position description   •
When confron,e^ manaT^J^^

                        s best *ou *"•  A9aia *" opdons are:
       • Plunger cans in place of open buckets
       • Lid and hoist for the degreaser
       • On-s'rte distillation and. re-use
       • Replace solvent with another cleaner
 Things you might defend yourself with:
       You might have fewer annoying regulations to deal with "rf you reduce the waste
       you generate.
       There are no guarantees; all you can do is try something out in your shop.
       You probably will save some money by reducing your solvent waste.
  .      The regulations change slowly; we might be able to reduce your waste right away.
  To get you started:
  M:   See anything interesting?
  PP:  Well, I do think there are some changes you might want to look at.
  M:   You know, I wouldn't have to look at anything if it wasnt for these crazy rules.

Management position description
 Things you might ask about:
...     is distilled solvent as good as:the new stuff?
 -     How hard are these distillation units to run?
       How can I find a substitute cleaner?
 ;     Do you know what other shops are doing to reduce solvent waste?
 ...   HOW will changes be regarded under the regulations?
       How can I do something*) protect myself from future liability?
 To get started:
  M:   So, what good ideas do you have for us?
  PP:  Have ^you considered doing this cleaning withoutthis sotveht?

       1                   n                    i                         '
Pollution  Preventer position description
       • Plunger cans in place of open buckets
       • Lid and hoist for the degreaser
       • On-srte distillation and re-use
       • Replace solvent with another cleaner

 Things you might mention:
       « you're able to distill your used solver* yourself and re-use it, you could save up'
       to 3000 per year at your waste volume.

       « you're concerned about quality, you might lust do a trial run rift a substitute to
       see how it works.
        Hav.e you heard anything about what other shops are trying?

  .     „ you did away wHh this sort of sofcent, you could improve working condrtions,
        reduce your liability, and reduce your cost, all at once.
        What do you workers think about the solvent smell out there?

        is there anything you'd like to look at more, or maybe try?

   To get you started:                       ^       -
   M:  So, what good ideas do you have for us?

   PP: Have you considered doing this cleaning without this solvent?

PP =  Pollution Preventer                                           ,    ;    :
M = Management

M:    well, what did you find in your .little walkaround?          -         ,

pp.   There are a few things that could be changed...

M-    Well now, that always the case, isn't it? Just wait 'til those guys hear something
    -might be changed.  I'll have questions thick as black flies. What exactly do you
      have in mind?                                         ,

PP:   For one thing, all those open buckets are evaporating quite a lot of. solvent into the
      air.  • '•-       .  - •   -.'"-../.'.'  ...     ;v  '    .    ••- ;   '•;.''   • •'

M-    Great  that's great.  If I tell them to lose those buckets, they'll just hide them under
      thlbenches  We can't even switch to another solvent, that's how stubborn they

      are.V   '    -     •'•".•'   ,-      ',.  ..  '. ,'-'

 PP:  It also might be possible to cut some evaporation by modifying the degreaser.

 M;   What do you mean?                            .

 PP   I was thinking about a lid ;that would close automatically and some sort of hoist to
      control how fast parts are pulled out of the degreaser.

 M-   We might get somewhere with the hoist.  They complain a lot  about having to yank
      baskets out of there. The lid would be disabled in a week,.I guarantee you.  In the
  PP:   Don't they complain about the solvent smelr>

  M:   Come to think of it, they do. That kind of argument could help.

  PP:   Now I've got a couple of bigger changes on my list.  First you could be doing some
       distillation and  reusing...

  M   Oh boy  now there's a can of worms.  I  can hear it now.  This used solvent's no
    '   good.  This just don't clean right Remember what I said about trying to change
       solvents? This would be a lot worse, let me tell ya.

  PP-  Maybe the way around a lot of this is to switch out of solvents altogether, dean with
       something else. You have fairly simple requirements, it seems.    .
           • '   *      -   '    '•'''• \    .     ''.-•,.    /•       •
  M-   Still the same problem. They just don't want to change.  Everything is too much
       work for them. I have to watch all the time to get out of them what I do.


PP = Pollution Preventer                 .  '  •'
M = Management

M:    So, what good ideas do you have for us?

PP-   Well there are a lot of open buckets of solvent'out there.  I've seen some
      container! called plunger cans that might cut down some  evaporabon loss.
                                           \ '•       .    ;'       _             '   • '
M-    Oh  areat  If I tell them to lose those buckets, they'll just hide 'em under their
      ?en*es  Theycar, be stubborn, you know, about how they like to do trangs.
                      J                                 '           '            ,
PP:   Don't they mind the solvent smell?

M-   Some do, some don't. But I could mention that. Lord knows they complain
      enough about pther things. Any. other ideas?

 PP-  You might consider an automatic and a hoist above the degreaser.  Then it would
   '  be closed more often, and  parts wouldn't get yanked out so fast.

 M-   Well I think a lid would be  disabled in a week.  There's no way they'd put up with
      that  Bui a hoist might fly.  They don't like  pulling baskets out. It's hard on the
      back, I know it is.

  PP-  Maybe you could go a step further and recycle that dirty  solvent yourself.  You'd
    '  save some money, and I've seen other shops like yours do it.

  M-   Sounds like another can of worms. I can hear it now.  "That recycled stuff don't  ^
      clean%ht  Wy do  we have to mess around like this"?  They'd blame the soK/ent
      even/time they  had a reject.

  PP-  I know I've seen that happen too. If you're- going to get them riled ^P anyway  I
      think you should stop using that solvent entirely.  A different cleaner m.ght do the
       trick,  ft would  probably take some testing, but...                •

  M-   Riant and who's going to do all that? I've got a shop to run here. Show me
       s^ngSwor^sfor sure  and I'll think about it. I can't afford to rock the boat.
       Things are tight enough.

Role Play  #1 .   ' .  .                 .'..-"•

4 ways that management may evaluate pollution preventions

—as a labor/management issue
--as a business strategy issue                               ;
-as a philosophical issue                       •    /
--as a technical issue
                                   *   ">•'   ''   .,         •.        '     •    '     ' ,
Situation description

 ARP Co is a small  shop using a solvent (1 ,1 ,1-trichloroethane) for degreasing, parts.
Wast Tso^ent * genSed at the rate of one drum per month, and disposed ata cost of
       '       cS drum per month            '
 per month x $300 per drum = $7,200 per year.. After a walkthrough °* the shop to
 evaluate solvent use, the following pollution prevention options are indicated.

       .     Replace open buckets with plunger cans             .       ,   ^
       .     Install automatic lid on vapor degreaser and automatic removal system
       •     Distiir waste solvent on-site and re-usa
       •     Replace solvent with alkaline cleaner                        -
       '•  .           '   .      - •                 '  '       '   '                -•'

  Description of pollution preventer

  After situation was evaluated, suggestions were pulled from basic re sources ^rt    _
  evaluation  as to  payback and practicaJlty  is up to the company. The job of the pollution
  prevenler is to promote, persuade, and encourage infavor of further explorafon and
  implementation.                                             .
                         .      4    !'  ~         ,  ' ^        .  -   • '    '  -
  Description of management             -,.„•        ..

  Founder and  owner.  Profitable company. In compliance; with all current regulations.
  Minor violations in the past. Friendly but conservative.


.    Encourage cooperation, resulting in.fewer inter-agency disputes and better
     utilization of personnel and information.
     Establish cross-training programs.
     Establish regional goals.
     Coordinate compliance incentives of all agencies.               -„-•„«/
     Consolidate consulting work for one plan instead of one for each agency.
     Allow agencies to pool technical and financial resources.
     Synchronize inspections.
     Assure that all environmental media are addressed.


       Having one permit will reduce cross media waste.            +^un^,0nx/
       Management will be provided with all available information and technology.
 !     Management will be provided wrth contacts at lead agencies that can answer
       regulatory questions in a comprehensive manner.


       Potential for turf battles and/or negative political impacts.


  .    Laws are not set up for interagency work

  .     TherS arfpotential problems of accountability and liability.
  •     Fear from administration.
        Difficultv in formulating a one-format permit application.      •.,...•     .
  .     SlStors S be necessary to dose the gap between avartablity and

   .    ' KZ^SSXXSL* of economic and environment and poiiBcai

     Ask "what resources, are available, i.e., consultants, industry associates, public.
     relations?"           '.''".
     Ask for financial assistance, tax incentives.              -
    Jrnplement proactive top management.
     Propose a time line & plan to change process.           .
     Begin treatment to keep regulators off of their back.
     Temporarily shutdown plant to correct problem.
     Utilize a transportable treatment unit.
     Implement a waste exchange program.
     Encourage industry-wide research and development.
     Recyple bluegoo.
     Eliminate bluegoo from production process via substitution.
.QUESTION #2:                                                         .  ,

What kinds of approaches could be pursued by the regulatory agencies working
together?                                 ,'                      .

•     Perform multimedia/comprehensive waste audits.
•     Hold interagency scoping meeting:
           Determine lead agency for coordination.
           Discuss roles and responsibilities of each agency.
           Come to agreement on information needed from the facility.
           Agree on permits needed.
      Review regulations and needs from agencies; .eliminate contradictions.
      Coordinate overlapping functions.                     .
      Identify individual agency concerns.
      Have each agency identify its problems and its tolerance (what each agency can do
      without violating its own requirements).
      Set priorities among agencies.
      Coordinate the collection of information.
      Develop a comprehensive regulatory package for industrial firms.
      Meet with facility top management to:
      Seek cooperation.                                                       .
      Obtain input from facility. Define issues/problems.
      Discuss available alternatives.
      Explain plan of action.
 .    Utilize  BACT (best available control technology)
      Seek most efficient way to treat waste in air, water, and land.  Determine which of
      these three processes is most effective-sand treat all waste this way.
 •    Form a compliance schedule.                        •   '      .
      Long-term:  Lobby the legislature to require interagency coordination.
                                   '*%   .  •   . '              *
 How could these approaches affect  the outcome?

Exercise design by:                                                       ,

Jane Straus, Bare Bones Training & Consulting
Tony Eulo,-Local Government Commission  .
Dave Hartley, California Department of Health Services


What would be your agency's possible respohse(s) to the situation with Blue Moon?
                                                     -             ' • '
Small Group Answers:

      Evaluate the facility:
      Review current practices at Blue Moon.                            .
      Review Blue Moon's SB 1"4 plans.
      Determine the impact of bluegoo.
      Reaulate and cut Blue Moon's allowable discharges.
 !    Sdeln^mction regarding pretreatment and alternative disposal methods;
      on proper disposal sites.                        .
 .  "  Reduce emissions of  bluegoo via control technologies:
      Scrubbers wet/dry
    * Baghouse
      Catalytic converters
 •    Increase monitoring of Blue  Moon:
      Develop compliance schedule.          ,
      Require immediate compliance when possible.                     nrn^c
  .    Consider Bluegoo for use as a raw material in another manufacturingIP**"*
  .    Reduce the volume/toxicity of bluegoo at the source v,a process modrfication or
      safer substitutes.                                    -
       Recycle bluegoo at Blue Moon  or at a recycling facility.
  •     Encourage commitment from management.
       Consider a local tax  incentive for capital improvements.
  .     Injection wells are not recommended; would like to see EIR for wells.

  What would Blue Moon's likely response be to each of those?

  Group Answers:                       .

       Ask "Why start now?"
  .    Ask for more time.
       Go to Mexico.
       Ship bluegoo to third world & label "recyclable.
       Threaten to take jobs away.
        "Job out1 to subcontractors making parts for widgets.
        Request a special waiver.
        Ask "How much cost is involved?1       ....
        Request a meeting  with regulators regarding compliance issues.
        Ask "Which  laws have precedence in cases of conflicting laws r

Multimedia Pollution Prevention Training Exercise Design                 ,       , ,

10 min    Air Land, and Water get into groups to answer:  What would be your
      ;    agency's possible response(s) to this situation with BlueMoon? They list on
          flipchart paper.

20 min.    Agencies  report back to full group what is on flipchart.

20 min    Facilitator: What would BlueMoon's likely response be to each of these?
          (Done separately) Recorder lists. What would BlueMoon's likely response be
          to all of these combined?  Are these responses best for the environment?  For
         , each agency?  Rhetorical question:  What would happen if interagency
          communication and cooperation occurred?

20 min     New groups form including agerfcies and industry reps, to answer: What
           kinds of approaches could be pursued by the regulatory agencies working
          together? How could they affect the outcome?
                                            i,                                    '
30 min.    Groups report to full group on answers to both questions.

 10 min     Facilitators:  Discussion centering on group's responses and on this being the
           goal pf the rest of the day's program.  They will hear big picture perspective
           from the  keynote speaker, will hear local agencies' issues, perspectives, and
           programs, and will hear about a successful pilot project that used an
           innovative multimedia approach to waste minimization.

Training Exercise Background
 BlueMoon is a major employer in the economically depressed area of Industrial Town.

 They currently have permits to discharge 6,000 tons of bluegoo into the sewer and
 6,000 tonTof bluegoo into the air. The remaining 6,000 tons is disposed of in a
 hazardous waste landfill.
 The Industrial Town Consolidated Sanitary District has been "^^J^The
 ft* he discharge from their treatment facility is not meeting new federal standards.  The
 teal lair dXtrict is now regulating the treatment facility as a major emitter of ozone   .
 precursors  In addition, the treatment facility's sludge has contaminants ,n excess of
 noDosed EPA levels.  To address these constraints facing the.r operates, the Sanrtary
 DteSSte Considering reducing the discharge limits of all permittees, including
 SS^^TS?^ doesn't respond to state and federal laws, they may be fined

 The Industrial Town Air Pollution Control District is receiving pressure from the State Air
 ?eso±TBoardTo clean up Industria. Town's air  which .does not meel : standards
 established by the Clean Air Act. In addition, local en^onmenfa.9ro"Pst^istrict dea
 successful^ sued the District and obtained a court order mandating that he ^d
 UD the air   BlueMoon is a major source of air contaminants in the ar basin If the Dis
 3s to clean up the air, the EPA may take over air pollution control in Industrial Town.

 The Industrial Town Environmental Health Agency has been informed by ^e operator of
 the nearbv hazardous waste disposal facility that they can  no longer accept untreated
  hia^dous wfsS due to ,and disposal bans established by State and Federal laws. The
  En^onmln^ Health Agency has informed BlueMoon of this development and has also
  hSttL that a nlw stete law has been passed which requires major hazardous
  waste generators to conduct source evaluation and review plans analyzing waste
  Generation and disposal patterns in their operation. In addition, a waste management
  KTT^Siotoito ahazardous waste management taffy 'near Industrial Town to
  handle bluegoo.  Town leaders are. opposing the proposed facility.
  The trade association that BlueMoon is involved in has recently co["P'fe* ^^
  describing how injection wells can be used for bluegoo d.sposal.  The.r analyse ,s that
  injection wells can be a legal, cost-effective waste disposal technology.


                            "Hot Block Refractory Corp." Solutions
               ;« .r-,.nr tnininc - Does the operator wear prpper protective gear?  A sloppy
      Z"u^ cunt rwrcH^tive^rf any WM measure. Mistakes due u, .gnorance „,„ he
      "Sod by training, mistakes due u, carelessness are mexoMbk.
            Provide closer supervision.

            Tichten equipment inspection and maintenance.

                     • i  /     .toil,, .KM mivst hayardousl in pre-weighed containers (eliminates

"     ^^^^KS^^^f' *-"*•• <° n-< f<™ ""»*" be ""
      alternative.           ,                                               ,

                                                      rs A and B.  Use a
 o     Locate equipment as close as possible to each .other.  This would limit the amount of wastes
       nenerated by the transfer processes.
       dust control and collection systems and a scheduled filter maintenance plan.

       Dedicate grinding units so that the need for cleaning is minimized or eliminated.  Don't ewer
        snOUiU UC iJlciv^cu uiiww« *»**•» «•» «•-    f-                        ,      ,
        To reduce spillage, install a positive cut-off valve on the wet grind unit.

  o     Install dedicated baghouse dust collection system for equipment so as not to contaminate all

        collected shop dust with chrome.                     •

  o     Investigate ways to recover chrome compound fron, sludge and dusts for possible re-use on-
  o     Investigate off-site usage of sludge and dust as raw material (possibly sell to a smelter or
        pigment manufacturer).                                                 ,

  o     Segregate empty packages.

  o     Store raw materials properly.





                                          Problem 3

                               Hot Block Refractory Corporation
The Hot Block Refractory Corporation produces ceramic bricks used as refractory in boilers and
hc-ucr   The process involves the wet mixing of two powders followed by drying and tiring ol the
mixture in bulk form.  You have been asked to study the weighing and mixmg operation as shown m
the attached figure. The following information is available:

            Powder A consists of an inert ceramic/binder mixture:  Powder B consists of-chrome
      „    The two powders are delivered in 50 pound sacks to the weighing station'. 12» pounds
            of A and 60 pounds of B are weighed and manually transferred to the wet vibratory

       o     Water is added to the grinder and after mixing, the slurry is gravity fed into brick .form.
             The  forms rest on the floor and when one becomes full, the operator uses an empty
             form to push  the filled form out from under the  spigot.

       o "    The  grinder is flushed with water after each batch. The area is washed down after each
             shift. All wastewater goes to  the area sump.

 Your job is to identify all possible wastestreams and propose viable waste minimization options for

                       "Mechanical Specialties inc." Solutions

 Avoid the need to clean by implementing Jusi-Ifi-Time (JIT)  manufacturing schedules.  JIT
Schedules eliminate the need forstorage and hence the  need  tor applying protecUve'grease.
 This reduces ;the loading of grease into  the solvent hath. It the alkalme cleaner etteUivUy
 rem'oves the oil-water coolant, then the solvent cleaning step can he eltmmaled.   ,
     "4          ".- '     •"          '.'.,•••'        .      "
 Move storace of parts indoors to reduce contamination  and oxidation.  Parts stored outdoors
 quicklv become contaminated with dirt  and moisture (morning condensation and ram).  Both
 dirt and moisture increase the Igading on the solvent bath which 'leads ,to more trequent
 replacement of the solvent.  Another problem with outdoor storage is that parts to be cleaned
 are cold  which slows the cleaning process.  The use of  oil-water coolant leaves  a slight oil him
 on parts which typically provides adequate protection during  short-term indoor storage.

 Maintain the quality of the solvent by the following methods:       .'              .

       Pre-clean parts by wiping off dust, dirt and excessive grease before soaking in solvent
       Cloths should be lint  free so a new source of contamination is not created.  Dirty cloths
       must be handled in an appropriate manner.    '"
       Store parts indoors to avoid moisture and condensation.  Keep parts away from dust or
       fume generating operations.
        Maintain racks and barrels in a corrosion free condition; Rust and scale in  the solvent
        bath leads to increased loading.  Cracks in hooks can  increase loss ol solvent by means
        of "drag-out."   ;          ' ,                  .          . •                  '.   "  •   _
        Routinely remove fines and sludges.  Metal fines can  lead to the break down of
        chlorinated solvents.  Some sludges dissolve slowly over time and, absorb solvent. Also,,,
        excessive sludge in the solvent tank can  lead to  the contamination ot parts with sludge.
        Hard paint chips will soften and swell as they absorb  solvent which can then no longer ;
        be used tor cleaning. With continuous or frequent filtering, these chips can be  removeu
        before dissolving.            '              f
        Monitor solvent composition to ensure that  solvent is dirty before recycling.  Quite.
        often  solvent is prematurely discarded .or change-out because someone   feels that the
        solvent is not cleaning fast enough.  With chlorinated solvents, monitoring  "goes acid

   Reduce air emission from the  tank by employing the following methods:    .

         "Rack" parts to ensure good drainage.of solvent from .the  parts back into the bath.  Cup
         shaped parts should be  racked  upside-down. In addition to proper racking, allow
         enough dwell time over the tank to  ensure good drainage.       *
         Install lids on all tanks  and be  sure to use them to prevent solvent loss and  -
         contamination. Tanks should only be open when placing a part into the tank, manually
         scrubbing a part, or when removing a part.  Slide coyers are preferred over removable or
       „  hinged covers.              •  s                  ;       .              -         .
          Locate cleaning tanks away from open doors or any place where there may be drafts.
   -    '  Ropes or cloth bags should  never be used to hold parts.  The materials used for holding
          parts should be non-porous and non-reactive.  Baskets should be designed to avoid drag-
          out of solvent.      ;                                        ...  -

                                  Problem 2

                          Mechanical Specialties Inc.
Mechanical Specialties  Inc. produce  mechanical components  for use  in the
automotive industry.  Steel parts are manufactured by a milling process which uses
conventional oil-water emulsi*bn coolant. Grease is  then applied  to the parts  to
protect them against oxidation during prolonged storage outdoors.

Prior to assembly, the steel parts are cleaned m  cold  naptha solvent to remove the
protective grease.  After cleaning  in solvent, the parts are alkaline cleaned and
painted   The wastes associated with this process include air emissions and grease.
rich solvent which is periodically removed and sent off site for recycling.  Recovered
solvent is returned to the facility.                                   .

You have been hired to provide the facility with viable waste minimization options
for their degreasing operation.
  Hint:                                                           .   ,     .  .
  Make a list of operating sequences, or flow diagram,* assist you in determining
  wastestreams, sources, and potential areas for waste minimization options.

                      "Colorama Paint Factory" Solutions
a.     The least number of tank batches required to produce 5000 gallons of red
      paint and ,2000 gallons of green paint is simply:

      One 5000 gallon batch of red
      Ong 2000 gallon batch of jp-een               ,             .         .
      A tatal of two batches       /

All other combinations (e.g., 5000 and 2 X 1000,2 x 2000 + 1000 and 2000, etc..) will
result in more than two batches.

b     The least amount of waste would be generated by using the 1000 gallon tank
      only.  Use the 1000 gallon tank five  times to produce the red paint order,
      clean the tank, and, then use the tank two times to produce the 2000 gallon
      green paint order.

      Note that only two tank cleanings are involved; one after  the  red paint
      production, and  one after the .green paint production.  Because the 1000
      gallon tank has the least.amount of wetted surface area, the amount of waste
      generated will be  minimal  (proportional to  2 X 120 ft-6).  All other tank
      utilization combinations result  in  either a larger number of tank cleanings
      and/or larger wetted surface areas.

In a formal comparison, one would have to perform a cost benefit analysis between
strategies a and b, weighing such factors  as labor costs,  waste  generation, and
product  quality.  Most production  planners would  intuitively choose the strategy
resulting in the  least number of batches (strategy a) due to the  reduced labor
requirements and  product quality  considerations.   Alternatively using the  1000
gaUon tank (strategy b) will generate the least amount of waste but will require
more labor to produce the total paint order and could possibly compromise product
quality and consistency when compared to  a single batch.  Another factor which
should  be  considered  is the potential  for product spillage, which is higher for
 strategy b.

                                          Problem I

                                   Colorama Paint Factory
You are a production superintendent in a large paint formulating plant  A customer has ordered
«HK» Mil ns of red paint and 2000 gallons of green paint.  Three tank sizes are available lor linal
Sng  SumXs S)()Gallons and 1000 gallons. All tanks are clean and ready to use. At the
end of the production campaign, all  tahks must he cleaned for the next order.

 1.  ,  Which tank utilization strategy would result in  ,

      (a)   least number of production batches     ^
      (b)   least amount of cleaning waste generated.

 \     List considerations other than waste minimization that enter into strategy development.
 'Hint-  Assume that the amount of cleaning waste is proportional to the tank internal surfacejrea
 Jeued £ the paint at the time when the tank is ready for cleaning. These areas arc as lollows,
             350 ft2 for the 5000 gallon tank
             190 ft2 for the 2000 gallon tank
             120 ft2 for the l(XH) gallon tank


                       The Waste Minimization Assessment Procedure
                               The recognized need to minimize waste
                                  PLANNING AND ORGANIZATION
                                Get management commitment
                               • Set overall assessment program goals
                               • Organize assessment program task force
                         Assessment organization
                         and commitment to proceed^ ,
                                       ASSESSMENT PHASE
                               • Collect process and facility data
                               • Prioritize and select assessment targets
                               • Select people for assessment teams
                               • Review data and inspect site
                               • Generate options
                               • Screen and select options for further study
                               Assessment report of
    Select new
assessment targets
  and reevaiuate
 previous options
                                    FEASIBILITY ANALYSIS PHASE
                                   • Technical evaluation
                                   • Economic evaluation
                                   • Select options for implementation
                             Final report, including
                             recommended options  4r
                                 Justify projects and obtain funding
                                 Installation (equipment)
                                 Implementation (procedure)
                                 Evaluate performance
 Repeat the process
                                     Successfully implemented
                                     waste minimization projects

                    PROBLEM 3

An accountant for Ace Manufacturing, an employer of 2,000
people, reported that the company spent $250,000 for off-site
treatment and disposal of hazardous wastes last year.  Based
on the manifest information, the only source of available in-
formation on  wastes, the company and its eight divisions gen-
erated~the following waste streams:

   50 tons acidic waste
   10 tons paint waste
 .  5 tons used oil
   10 tons various solvents; MEK.TCE, Naptha, Perc.
   1 ton adhesives
   15 tons contaminated soil
   30 tons clarifier sludge

• The General  Manager, alarmed by the 200% Increase In disposal
 costs  assigns  you to develop a waste minimization program.
 You have no budget to do this but can devote all of your time to
 the project.

 1. Outline what steps you would take to begin to develop a
    waste minimization program.

 2. How would you prioritize wastes for reduction?

 3. What resources would you use?

                 FREON CLEANING AGENTS
                                         Recommended Work Practices
                      , ,mpor, r=,e ^^^^S^^^^^^^^
                      would be expected trom tne use ui »«« «        •_ n« Print FREON9 fluorocarbon
                usteo. oelow ar- »*••«-•«* practices that play a rnapr role in Du Pont FRtuiN

cleaning agents emission control.
Cleaning System Location
                                 Cleaning System Design
                                 Small open-top units should have a freeboard, width
                                 ratio of 1.0 or greater. (See Figure 2.)
                                        EFFECT QF FREEBOARD/WIDTH RATIO AND
                                   CONDENSER TEMPERATURE ON DIFFUSION*!. LOSSES
                                         FROM IDLING DECREASES CONTAINING
                                                FREON'TF SOLVENT
Proper-designed and maintained equipment is a prerequisite for minimizing solvent emissions. For over 30 years
Du Pont has worked closely With, cleaning equipment manufacturers to develop the following basic equipment.
design guidelines that permit Du Pont FREON* fluorocarbon cleaning agents to be used effectively with minimal
solvent loss.'                   '             ' -  .               '                                 :
                                BASIC EQUIPMENT DESIGN
FREON-cleaning agents are used in degreasing/defluxing equipment that is configured in a variety of ways.
However all of the configurations are based on the fundamental cencepts of the simple two-sump, open-top
degreaser, shown in Figure 1 on the back fold-out of the brochure, and contain the same basic elements:
  •  A tank containing one or more heated sumps©  .  dimension, which is usually the widthiof the machine.
     i-i koiv* %.*<•     o                _             e	M ____ t>%>, ,,„;»«. ekmiM-haua a froaPlrtarrt. u/irit-h
     that generate solvent vapors, along with one or
     more sumps © arranged in an overflowing cas-
     cade to clean parts by liquid immersion and/or
     spray washing.
  •  A condenser (heat exchanger)© to turn solvent
     vapors back into liquid form. A trough ©  under
     the exchanger collects condensate.

  •  A water  separator (or desiccant dryer) © to
     remove water from the condensate before it is
     returned to the cleaning sump cascade.

   •  A vapor zone (vapor-filled space)© between the
     surface of the liquid in the various sumps and the
     vertical midpoint of the condenser.          r

   • A freeboard zone,® which is the space lying
     between  the vertical midpoint of the condenser
     (top of the vapor zone) and the top edge of the
    ' tank!  .        ',-   •'.-..,    '•   ..••'.
   • Safety controls © ©  to shut off heat to the boil
     sump's if the condenser system faUs, liquid level
     in the boil sumps becomes low, or the boil sump
     temperatures are elevated because of contami-
 Equipment design affects three principal mechanisms
 of solvent loss from  degreasers and defluxers. The
 mechanisms are DIFFUSION,  DRAGOUT, and

 Diffusion  losses result 'from the contact of liquid  or
 vapor with air. The following design parameters con-
 trol diffusion  losses:
 Freeboard Height—Diffusional losses are. inversely
 proportional  to the  freeboard height.  To minimize
 losses, the freeboard should be as deep as possibleand
  at  least 75 percent of the smallest horizontal tank
                                   £   2
                                   •r* ^ •—k
                                   at t
                                   2 i 2
Freeboard Width
                                    ee r <
                                    vn 5 ^
                                    8  =
                                                                   Ratio -I 0
                                             . -»  - *a  .  -m    «*•-    —

                                             AVERAGE CONDENSER TEMPERATURE'
                                                     Figure 2

                                  Condenser Temperature-Diffu^ional losses are
                                  directly related to condenser temperature; therefore;
                                  the condenser should be. designed to operate at the
                                  lowest,practical temperature. In state-of-the-art
                                  design using either mechanical refrigeration, recir-
                                  culating chilled water, or brine, the condensers oper-
                                  ate at temperatures of 40 to 50«F. (See Figure 2.)

                    FIGURE 1  - Vapor Degreaser
Sump Safe
   Steam Coils
                                               Safety Thermostat
      Cleanout Door

         Solvent Level
          Sight Glass
                             Rood Valve
                  Heating Elements
Work Rest and Protective Grate
        FIGURE 2 - Vapor Degreaser with Spray Attachment
 Steam Coils
                                                     Spray Lance
                                                                   Storage Tank
                                   Water Separator

                          Cooling Water
                Heating Elements
                              Work Rest Grate

                            PROBLEM  #2
                            . .• •*-• •-•:•./?&•--
 Mechanical Specialties Inc. produces servo-mechanical components for use in the
 aerospace industry. The parts are manufactured by a milling process which uses
 conventional oil-water emulsified coolant.  Grease is then applied to the parts to
 protect them against oxidation during prolonged storage.

 Prior to assembly, the alloy steel parts are thoroughly cleaned in a vapor degreaser
 with  perchloroethylene (PCE)  to  remove the protective grease.  The wastes
 associated with this process include air emissions, decanted water, and grease-rich
 bottoms which  are  periodically  removed  and  sent off  site  for destructive

 The  degreaser has a freeboard-to-width ratio of 0.75 and  is equipped
 refrigerator coils  and a hinged cover.
                    Identify candidate WM options.

                     '    COMMODITIES PRODUCED. IN BATCHES
              Dves. Inorganic Pigments, Paint, Agricultural Chemicals
              Formulaliofen phenolic Resins, wood Preserving
Material Handling:

 Filtration and
 Baghouse Fines

 Off-Spec Product

  Equipment Cleaning
   Leaks and Spills
1.    Segregate containers by prior contents
2    Use rinseable/recyclable drums
3.    Purchase materials in bulk or in larger containers
4.    Purchase materials in preweighed packages
5.    'Use pipeline for intermediate transfer

I.    Optimize the reaction variables/receptor design
2..   Optimize the reactant addition method
3.   Eliminate the use of toxic catalysts

 1.   Employ efficient washing/rinsing methods
2.   Eliminate the use of filter aids
3.   Use countercurrent washing
4.,  Recycle spent washwater
 5.    Maximize sludge dewatering

 1.    Increase use of dust suppression methods
 2.    Use wet instead of dry grinding
 3.    Schedule baghouse emptying

 1.   Tighter control of reaction temperatures
 2.   Reformulation of off-spec product

  1.   Install high pressure  spray wash system
 2.   Alter .production schedule
  3.   Use mechanical wipers on  mix tanks
  4.   Clean mix tanks immediately after use
  5.   Use a countercurrent rinse sequence
  6.    Recycle spent rinse water
  7.    Increase spent rinse settling time
  8.    Re-examine need for chemical cleaning
  9.    Dewater spent rinse sludge

   1.   Use bellow-sealed valves
  2.   Install spill basins
  '3.   Use canned (sealless) pumps   •
  4    Maximize use of welded vs. flanged pipe joints



                              Problem #1

                    ABE's Electric Company
nariSnprocess. THe ceramic powder goes dry into this process.

 Abe is facing a number of problems including:

   DOSHA has issued a citation to the company for violating TTLV for tead. (worker expo
       sure)                                                             .

   2) EPA's land disposal restrictions will prevent Abe from disposing of the hazardous waste
                    * Emission of Powders into workplace
                          * Powders settle on floor
                         * Area is washed down daily           *«*.;.*•
       * Waste goes to settling pit and hazardous sludge is disposed of offsite

                          * Reduce hazardous sludge
                     * Reduce worker exposure to lead dust


                       List of Equipment &  Materials

1.  Blue tempera paint
   Yellow tempera paint                   ••
   -use 1 teaspoon powder per team as a guideline

3.  4 8oz. paper cups

4.  2 water color brushes
5. 2 spoons
6  24" X 36" sheets of white paper for production "floor"
    -can be removed from flip chart

7.  1 8x12 piece of heavy grade paper
    -cut into 4 squares

 8.  1 half-full cup of water

 9.  flip chart or blackboard

 10. felt-tip markers for flip chart

 11. chalk and erasers for blackboard
                      1313 5th St SE, Ste 325, ^nwpoUs MN 554144502
                             (612) 379-5995   FAX (612) 379-5996

  d  If placing ash in a landfill is recommended, ask how the rainwater might become
     contaminated and enter drinking water supplies.

  e. solicit ideas on how to clean up the contaminated water and what should be done with
     the toxics we remove from the water.

  f. ask what would happen if these toxics were incinerated

  V Doint out 'that, while the volume of waste was reduced, the hazardous portion was not and
  g' Sp^bdng moved around without being completely eliminated..

  h  solicit ways to overcome this problem, Le. how should we deal wtth hazardous waste
    '           in in industrial processes? Is source reduction the answer?
      is disposed;
10.   Instruct teams to clean up.

1 .  Assemble participants into teams of five and seat them around the "production floor"
2.  Ask the groups'to invent their own company name/and write the team names on a flip chart or
'• ^^^^^^
   much the modS representing the customer's desired color.
 4. Exp.^^

   uiciii uiwY w ui* i*«*»» —•«» •         ,
   instructions until the teams are ready.
6. Tell the teams to begin the exercise and note the time.
7  At the 20 minute mark, tell the teams to stop.
8'. Begin inspection of each team's product and evaluate their efforts with the following criteria:
    a.  color match with the customer model
    b.  production floor cleanliness.
    c.  number of contaminated brushes.
    d.  number of contaminated cups.
    e.  number of contaminated spoons.
    f.  cleanliness of back of green square.              -
    g. left over green paint
     h. contaminated hands, clothing, etc.
  9. Begin discussion                                  ,
     a.  ask the  students to discuss techniques they used to nnnimize waste generation.
     b. solicit ideas on how to dispose of waste generated by each company.
                           *      "      '       '            a» '   '  f ~t-. _ •«.*tij-» *%cW ^rtrfi 31T*
         Tf  •    '   *s recommended,  solicitideas on how to dispose of the .tone asn ana air

                      1313 5^t7»^T612) 379-5996

Instructions  Organization
                  •-.,-.       ,••„-'•'    '      -     ' ••    •  - •                 v /
• Form teams        ,              .'•'•'-        ,.-              .'     .-
  '•>•.•        .  .       '       '  i  ••••••         .'..••    ,       -       . • -_
• Explain exercise        '         •                              .               '     .
• Hand out materials    .            ..".'..
• Inform players of your role
• Place order
 • Check on teams progress    >              ,
 • Begin discussion                                  .   .
    -ask the students to discuss techniques theyusedto minimize waste generation.         -
    -solicit ideas on how to dispose of waste generated by each company.
    -If incineration is recommended, solicit ideas on how to dispose of the toxic ash and air
    -If placing ash in a landfillis recommended, ask how the rainwater might become
     contaminated and enter drinking water supplies.
    -^solicit ideas on how to clean up the contaminated water and what should be done with
     the toxics we remove from the water.
    -ask what would happen if these toxics were incinerated.                 ,
    -point out that, while the volume of waste was reduced, the hazardous portion was not arid
     is simply being moved around without being completely eliminated,
    -solicit ways to overcome this problem, i.e. how should we deal with hazardous waste
     generated in in industrial processes? Is source reduction the answer?
    -discuss the relative merits of buying and using products from industries that cannot
     entirely remove hazardous waste. Participants may be interested in researching industries
      in their own communities that generate air;water, and  land pollution and where that waste
      is disposed.
  •  Cleanup
                                          Page 5
                     1313 5th St SE, Ste 325, Minneapolis MN 55414-4502
                            (612)379-5995   FAX (612) 379-5996

intended to help participants become more aware of sources of waste, options for waste
minimization, and resistance to change.

    We have several objectives in mind for this exercise. One is to help participants not familiar
with industrial processes to understand these processes.  Another is to help participants understand
the challenges and frustrations of reducing waste in an industrial setting.  A related objective is to
show the participants that by taking part in this exercise; they may find their previous
 understanding of waste reduction and its implementation has little in common with the reality of
 waste reduction in an industrial setting. Our final objective is to help participants become aware of
 the importance of communication in waste reduction efforts, and «a become aware of some of the
 many factors that make it difficultto actually implement waste minimization, such as labor
 relations, customer demands, and competition.
                                           Pae 4

Principles of Operation
   Nearly'all training to date in waste minimization has been based on lectures and case studies, all
of which are more properly termed education. Training to date has been given a lesser priority
because the informationto conduct training has not been available.
   Our early training attempts at verbal role plays and small group discussions, while useful, were
not as effective as we'd hoped. We found that, aside from role plays and discussions, an.exercise
approach such as theGreen Square Game is a more effective training tool  It's a fun exercise and
we believe that people who have fun.while learning are more likely to retain what they've learned.
We are employing the principle that hands-on training allows trainees to become participants rather
 than observers. People would rather have the actual tools to work with rather than reflecting on
 concepts.                                           .  :         '
    We determined that the regulatory audience who will participate in this exercise may not be,
 familiar with what it is like to function in an industrial setting. Because of this, we wanted to
 construct an exercise to give these participant a g«xi sensed how a business operates day-to-
 day. By participating in this exeidse, they wulal^
 subsequently learn to recognize processes that create waste. In addition, participants will
  understand how hazardous waste, even when properly disposed of, can re-enter the environment,
  and;that landfills and incinerators don't reduce hazardous waste's threat to me enviromnent.
  Finally, with their enhanced,sense of an indusoial setting and knowledge of how waste is
  generated, we believe these participants will be more effective in promoting waste minimization in
  their respective positions.
     •*•'•..                  "      •"'...••        .
  Purpose                                      ,
      To motivate audiences to promote, persuade and encamp
   through a mock industrial process. This mock process irintended to heighten the participants-
   awareness of the importance of communication in waste niiiumizanoneffore. In addition, it is
    '      .        •    >    \      '         ...;•"•'    '  -,    •.   '   . /'
                                           Page 3
                      1313 5th St SE, Ste 325, Minneapolis MN  55414-4502
                             (612)379-5995   FAX (612) 379-5996     ,

   Public Policy staff in regulatory and/or policy-making positions are in an important position.
They can influence waste generators in industry to adopt methods of environmental protection.
This training manual outlines an exercise which can heighten public policy staffs' awareness of
how waste is produced and how it can be reduced.  At the same time, this exercise will provide
participants with a sense of what it's like to work in an industrial setting and to use group problem
            •                      '                           '
solving techniques.
    The instructions in this manual show the exercise facilitator in a step-by-step fashion how to
take a group through  the Green Square exercise.  The training manual also includes a principles of
operation section explaining how we developed this exercise, what our basic ideas are behind the
 exercise, and how we expect participants will benefit from the exercise. We have also included a
 list of equipment and materials needed for this exercise.
                                           Page 2
                      1313 5th St SE, Ste 325, Minneapolis MN  55414-4502
                             (612)379-5995  FAX (612) 379-5996

               Outline for Green Square Exercise

vl   Introduction

     Theory or Principles                        -
     a. Principles of Operation
     b. Purpose
     c Objectives   -                    .';••",   " -  .

      Instructions Section

      Equipment and Materials Needed

 The Green Square
    Interactive Exercise


 Waste Reduction Training
     Waste Reduction Institute
for Training and Applications Research
          February, 1991
         by Thad Schifsky

                  CASE STUDY — SMALL BOATYARD
Description of Pacility

   "  This hypothetical facility, owned and managed by .AquaVamp, .
Ltd   is a small privately-owned boat restoration and renovation
faciiiiyV  The facility is located on a small bay off a na}or
inland waterway and primarily services privately-owned motor-
lowered vessels of 65 feet or less.  The facility services  150 to
l?rvlssels per year.  The staffing of the facility varies  with
the seasons and workload.  Minimum staffing averages seven

     Tvcical  services performed at AquaVamp include washing and
cleaning of vessels, stripping .(using chemicals  and abrasives)
a^d Sainting  of hulls, and servicing and rebuilding of vessel    .,
superstructures and mechanical  systems., Average vessel  residency
is two  to  three days.
     The  facility consists of docks, drydocks,  marine  elevators
and  railways, mechanical  and engine  shops,  and a parking lot.
The  facility  has  all  support services,  including machine shops
and  palnttng  stations,  on site.   Solvents,  fuels,  lubricants,-
oaints   chemicals, and abrasives, are kept on site.   They are
 freq^entfy Sailed and transferred in  the open and/or in large
 quantities.   When these materials are  wastes  they are^handled in
 Accordance with RCRA hazardous  waste regulations (including    -
 manifest,  storage, and waste minimization certification/planning
 requirements).                                   .         ,

      Most of AquaVamp's infrastructure, including the buildings,
 vessel handling systems, and pump/drainage svsjem^"e^|utc 45
 years old.  As the facility ages, maintenance burdens grow
 Itlller.  According to Mr/C.  Leggs, the facility manager,  a
 chronic maintenance problem is the accumulation of used
 sandblasting media in the sumps and pumps of the drydocks.  Mr.
 SggsSs Sited,  however, that a decline 4n the prevalence of
 alaae  and snails  on the superstructure of. the vessel handling
 syltemlharhad  an overall positive impact by reducing required
 maintenance  in that particular area.
  Tb* Problem
     As a permit writer, you are going to use your author i£y
under CWA lection 402 (a) (1)  ^o require faci^y-specif ic bes
                                           PDES  ermit.  The
  management practices (BMPs)  in AquaVamp s NPDES Permit
  objeltive for including the BMPs in their P^^J^'eir
  Dollutioh as much as possible.  Therefore, you would like their
  p?an to" Resemble a waSte minimization/pollution prevention plan
                  * * *   8«Rt««b«r ii, 1990  * * *

                              - 2 -
     You have 20 minutes to  identify and discuss the elements you
will be looking for  in AquaVamp's BMP plan.  In your discussion
you should address the following questions.  At the end of this
time? you will be asked to discuss your conclusions with the rest
of the workshop participants.

     1.   How can you know that AquaVamp's  BMP plan is having its
          desired favorable  impact?

     2.   How would/should AquaVamp's plan  be coupled with or
          complementary to effluent  limitations?

     3    What  is the potential relationship between AquaVamp's
          RCRA  waste minimization planning  and their BMP planning
          under CWA?

     4.   How does  AquaVamp's staff  fit  into a BMP plan?
                  * * *   S«pt««b«r 21, 1990  * '* *

                              - 3 -
Lessons Learned—email Boatyard

i    m general, BMP plans may be most applicable  to  ancillary
    "activities at a particular  facility.  The  general  activities
     for which BMPs may be most  applicable include:

     •    material storage;                                ,
     •    loading and unloading  operations;
   ,  •    facility runoff control;                 -   ,     .
     •    process, materials  transfer, and handling operations;

 ' - '   - •   ' and - "     ':  •  •'  '•'"-..'•,••.   ,   -  '•  '"..'.
     •    sludge and hazardous waste disposal.

 2.   A  BMP  plan, generally has specific elements (requirements).
     These  elements may  include:

          a plant-based  BMP  "committee,11
          risk identification and assessment,
          reporting of BMP incidents,
          materials compatibility
          good housekeeping,
          preventative maintenance,                             ,
           inspections and recprdkeeping,
         —security,  and
           employee training.

      BMPs" may include some of the very same elements as those
      presently used in other programs,  for example:

           loss control,
           fire protection,
           insurance qualification,                .
           waste minimization planning.
           public relations/image management, and          ,„„-„,
           spill prevention,  control, and countermeasures  (SPCC).

      Permit writers do/have  the authority to incorporate
      requirements  for BMP plans in permits  as  a means. °f
      preventing pollution.   This authority  is  described in
      Section 402(a)(1)  of the Clean Water Act.
                  * * *   8«pt«»b«r 2l/ 1990  * * *



     us  Electroplating is a large midwest electroplating  firm
which special's* in  kitchen appliances, utensils, .tools, and
cabinet hardware.  The farm commonly uses a variety of aetal-
cyanide electroplating baths to process its products.  The  firm
generates seven primary waste steams.              .

     Generally, the firm combines concentrated cyanid? wastes  '.
from theplating and  cleaning solutions with  f ilter sludgebefore
treatment and disposal.  Also, acidic wastes  and dilute  cyanide
solution's are segregated and treated separately.  .You are part of
a  special learn of  permitting staff  looking  at the facility  as  it
impacts  all media.                                             "

     U.S. Electroplating recently hired an  independent  contractor
 vou with a sumary of the facility assessment that highlights the
 scope of pollutiS prevention opportunities they have identified,

 Good Housa K««ping Practic«« Applying to All wa«t« Str«a»«

 •    Employee Training

      —   signs and methods of detecting the release of toxic
           materials Into the work environment

      —   a review^of good operating practices for     '/'
           -   • storing and transporting toxic materials
          • -    proper equipment use

 •    procedural Measures                       .

      —  tracking and  inventory  control  of  material /waste's
           location,  quality,  age,  and  use

 •    spill  Prevention

       ~:  monthly inspection of tanks  for leak or potential
 .   ...'.; ;   leakage, •.'•'•"•    \    .. '  /     •. .-,      ' -_    '    :

        Slating solution and Filter Sludg*

       increase longevity of plating solution

       --   clean the workpiece to reduce drag- in contamination
            from one bath to the next

                    *,;;* * September  21,  1990 * * *

     ~   use deionized or distilled make-up water  (tap water may
          have a high mineral or solid content, which can lead to
          impurity build up)

•    Replace cyanide plating solutions with cyanide-free
     solutions.  This option often  requires upgrading of the
     •cleaning techniques because a  much  more thoroughly cleaned
     surface is needed to ensure high quality  plating.

•   ' Return spent plating solution  to manufacturer.  This option
     requires on-site segregation of solutions according to the
     metal in the solution.

Wtstevater Treatment sludge mud Solvent  Recycling Still Bottoms

•    Reduce the volume  of wastewater through surface impoundment
     evaporation;  employ leachate  containment and monitoring

•    The toxicity and volume of treatment sludge can be  reduced
     though recovery of metals prior to 'treatment.

 spent  Alkaline and Acid Cleaning Solution, and Degr«aser Sludge
 from solvent Cleaning                                          -  '

 •    Spent oil-based binders used  in polishing and solvent-
      containing cleaning rags can  be burned in on-site
      incinerators achieving a reduction in hazardous waste and
      energy costs.

 •    Reducing waste due to solvent cleaning operations.   By
      reducing solvent vapors loss  and maintaining solvent
      quality, the need for replacement  is reduced.

      --   install lids on tanks

      —   increase  freeboard space (the distance between the top
           of the vapor  zone and the top of the tank)

 The Problem  .  .  .

  (1)  A« a permit writer, what  value do  you see in being presented
       with a  facility assessment?

  (2)  Choose four promising pollution prevention options and
       evaluate them based on the following criteria

            Pollution Prevention Hierarchy

            Cross-media Considerations

            Waste Reduction Potential

                   * * * September  21, 1990 *  * *


         not there was a net gain.
      treatment sludge.
      Volume reduction through surface impoundment evaporation
      -  ". is lowest on the pollution prevention hierarchy  (land-
           based treatment)   •             -"••'.-'
           must include measures  to control  air and  surface
      ' •'     releases '   ',   •. - ,      ;;  -..•-.'•.'
           without reducing contaminant  concentration in '-the_riw
      "    wSe?   a  largS volume of  sludge  will  be  exchanged for
           a smaller volume of  wastewater               :
      Burning used cleaning rags And spent binder waste
       -.'. ' is low on the pollution prevention hierarchy
       -    will shift waste management from'the land to air medium
* * •*
                          September 21, 1990 * * *


Description of Facility
     A hvDothetca  company, BORCO  (Big Oil  Refining Company) ,.
                               -                               °11
ga  stream may  contain less than 5,000 ppm of SO2.
     The  proposed technology is a weir known approach that has a

li?el?^ischarge of this aqueous waste stream into a local
waterway.,   .  ;   .   : ,     '  •  ; .   ,        '...•-.•••.-.   "      .  • '' •

 permit wr?ter°stSinLg manual you read recently about^the
 importance of considering the cross-media impacts of any air
 permit application.

       since  it occurs to you that there should be a better way to
 controilhe  S0° S^ir emissions than by .putting it i« ^he.water

  containing  endproduct.
                * * * DRAFT:  8«pt««b«r 21,  1990  *  *  *

The Problem  ...

  • -  While vou may  not be  statutorily compelled  (or even allowed)
to reSirl that  loRCO select, an  air pollution control technology
££*£ Kief its other environmental media,  the concern over

S "S ?ong  term Sest interest tfuse a regenerable process.

      YOU have '20 minutes to address  each of the  following  issues.
At the end  of this time, you will  be asked to  discuss your
conclusions wiS the rest of the workshop participants.

      l    Is the proposed pollution prevention alternative (i.e.,
           II use I regenerate FGD technology)  the best
           alternative to consider from a pollution prevention

      2    How much authority do you, the permit writer, have to
           require BORCO to undertake specific pollution
           prevention measures?

      3.   How can you manage the vulnerability to legal challenge
           created by special permit conditions?

      A    what  kind of  coordination and cooperation is needed
        '   between  permit  writers from  the  various Regional and
           State Ldifoff ices  (e.g., air and water) to accomplish
           pollution prevention?

                 *  *  * DRAFT:  September 21, 1990
                                                 * * *

               Lessons L«arn«d — P«troUum R«fin«ry               :        >.

                   ' T^r^Ht writers may  be, able to  influence applicants to adopt
                    EElitiS prevention  techniques even though they may not
                    gave SS^SSfic statutor/authority to require applicants
                    to do so.                               ,    r-                ..
               5    The choice of  a  particular pollution control  technology -may
                 '   have a significant  impact on the  overall net  effect  of  a
                    process  (2r  a  facility)  on the environment  -- permit writers
                    Should be prepared  to affect the  selection  of such
                              of process
                                                   from one environmental medium
                     avoided whenever possible.
                                *  *  *
DRAFT:  8«pt«mb«r 21,
                                                            1990 * * *