A Compendium of Exercises and Activities
U.S. Environmental Protection Agency
1993
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Introduction
s manual provides instructors with descriptions of '"'
and duplicated in any course or workshop.
setting.
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.
Ifyouhaveanyquesdonsona^o^F
Deborah Hanlon of US Environmental Protection Agency at (202) 260-2720.
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LESSOM LZMOTD -- COKMCTITI! XCTIOH ,.
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
lrh
"
* * * September, 21, 1990 * * *
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• ,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 .
techniques:
D. In
ifH^HlUlllll iijv***>* •••«»«»•• ..— - — - . » ^
the Waste Reduction Impact Statement required.
and
in
C above.
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Pollution Prevention Orientation Workshop,
Instructor's Guide
1. Instructors greeting and introduction: instructor Notes
Welcome people to the course and make them
K ^ tof/?
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I P4HER'S GUIDE FOR CONDUCTING AN INTERACTIVE
loLLUTION PREVENTION ORIENTATION WORKSHOP
by Deborah Hanton and Jeuli Bartenstein U.S. EPA
General Information
Purpose
topics that you feel comfortable in teaching.
CO-,KK»^
anS :ntlrS«ng wo^shops is one way to accomplish this goal.
ffl"d timing
Audience
workshop.
Materials
;±r^"^^ that may be ot ""^
interest to them.
Be prepared and ma*e sure your have ^workshop essentials:
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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
3^^
arise.
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
identified.
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4. What is pollution prevention? (clean
production?)
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
one
pollution as defined by EPA's Science Advi
Board.
resources.
Ask participants to define pollution prevention in plain English
(what it means to them)
instructor Notes
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[ ,-•-._ \ . = ,
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
events.
Discuss further needs.
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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.
Examples.
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
prevention)
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.
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8 Closing and Evaluation: Instructor Notes
evaluation of class. , -
' :,•
;Cle.aringhouse at (703) 351-4004.-
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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
Hill.
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
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Discovery Exercises for
Pollution Prevention Training
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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
program?
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The A mazing Rlitzfn
Exercise
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
efforts.
"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.
Production
Equipment
scissors
rulers
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:
Guidelines:
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
Cost
Specifications
Environmentally Friendly .
Pollution Prevention Program-.
Customer satisfaction
Employee safety
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Role Assignments
Leader
.
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.
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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
prevention?
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?
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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^' "•:. / • .. .
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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.
i
4. Criteria for selecting the "best" blitzfn:
* Time to produce
* Cost .'•••'
* Specifications
* Environmentally Friendly
* Pollution Prevention Program
* Customer satisfaction
* Employee safety
* Total waste generated
5. EVERYTHING OTHER THAT THE BLITZFN PARTS
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,"
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Role Assignments • ' ,
Leader
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.
Worker
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.
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The Fun Factory
An
Interactive Exercise
for
Waste Reduction Training
by:
WRTTAR
Waste Reduction Institute
for Training and Applications Research, Inc
.completed
February, 1991
byThadSchifcky
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Introduction
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
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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.
Purpose
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
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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.
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\. 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.
WRITAR, 1313 5th ST SE, Ste 325, MiBne.polls MN 51414-4502
Ph. 612-379-5995 FAX 612-379-5996
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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.
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Instructions
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
standards.
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!* .
7.
them.
a 30 minute astern and then * second90 minu» exaciie. A half-hour break can be
" \ ' *""
inserted in the exercise.
WRITAR, 1313 5th ST SE, Ste 325, M*"***Jff 55414^502
Ph. 612-379-5995 FAX 412-379-599«
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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.
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8
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
another.
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.
WRITAR, 1313 5th ST SE, St. 325, ™*™**™ 5541^4502
Ph. 612-379.5995 FAX -
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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
?
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The Oily Washers
Game
•... • • An '
Interactive Exercise
Waste Reduction Training
WRTTAR
Waste Reduction Institute
for Training and Applications Research
completed
Maidfc.1991-
by Thad Schifsky
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Outline for Qily Wishers Exercise
•v/I Introduction
iles
on
Tfceory or Principles
a. Principles of Operati
b. Purpose
c. Objectives
f
Instructions Section
Equipment and Materials Needed
\ '*
WRTTAR, 1313 5th St SB, Ste 325, Minneapolis£JN5
Ph. (612) 379-5995 FAX (612) 379-5996
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Introduction
Public policy staff in regulatory antopolky making positions are in an import
'
posiaon.
i an exercise which can heighten pubHc policy staffs'
At
industrial setting and to use group ^^ problem solving techniques.
a group through tte Oily Wasn^
ofop^uonsectionexplaininghowwcd^
^eexerc^^
a list of equipment and materials needed for das exercise.
™- ^^li^s^5414"502
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Principles of Operation
Nearty all Mining » o*e to was= reduction has been based on tenures andcase studies,
ail of which arem«pn*erty
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Objectives
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
unde«ta*iingofte
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
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Instructions
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
washer.
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
amongrtemselvesforano^
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
'washers.
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
6
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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.
-oneforeachtcamtokeepoperator'shandcleanwhaecl^
4. 'Roll of paper towels.
- provide at least two towels for each team.
5. 4 eight ounce paper cup*.
-------
*•
10
Felt-tip markers.* flip chart, chalk and erasers
if blackboard.
11. Paper and pencils for each group.
8
379-5996
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CASK STUDY - THB RCRA COIO2CTIVB XCTIOH PROCBSS
- 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
practicable."
Ih. .aciUtyha.
as a storage facility. A JSr* is any evidence of a release.
(1)
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
recovery.
The Problem ..... . ._
ox
lono-tern »!!»!"« and effectiveness, and
. reduction of toxicity. nobility or volume of vast.
(§264.525 (b).).
* * * .September. 21, 1990***
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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 * * *
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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.
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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.
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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
smell.
LM: That's one good thing. «* a whote tot easier to work a whole day back here now.
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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.
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Role Play #2 .
4 groups who have a stake in implementing change
-management *
-line management
-production
—customers •
riascription
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
-------
.TECHNICAL
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?
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TECHNICAL
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?
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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^
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PHILOSOPHICAL .
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.
-------
BUSINESS STRATEGY
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?
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BUSINESS STRATEGY
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?
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LABQR/MA-NAGEM.ENT SCRIPT,'Alternative #2
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.
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LABOR/MANAGEMENT SCRIPT, Alternative #1
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.
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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.
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POSITIVE:
. 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.
OUTCOMES:
Positive:
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.
Negative:
Potential for turf battles and/or negative political impacts.
DISCUSSION OF GROUPS' RESPONSES/CONCERNS:
. 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
factors.
-------
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?
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Exercise design by: ,
Jane Straus, Bare Bones Training & Consulting
Tony Eulo,-Local Government Commission .
Dave Hartley, California Department of Health Services
QUESTION #1:
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
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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
significantly.
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.
-------
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"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
o Locate equipment as close as possible to each .other. This would limit the amount of wastes
nenerated by the transfer processes.
o
clean.
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-
site.
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.
-------
o
«
cc
^
u
CD
"5
-------
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
o
oxide.
„ 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
grinder.
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
each.
-------
o
"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
(decomposes).
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
-------
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The Waste Minimization Assessment Procedure
The recognized need to minimize waste
1
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
selected'options
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
IMPLEMENTATION
Justify projects and obtain funding
Installation (equipment)
Implementation (procedure)
Evaluate performance
Repeat the process
i
Successfully implemented
waste minimization projects
M40M-4
-------
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
FS-308
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
-------
FREO.N CLEANING AGENTS
FS-30A
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
?
5
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-
nants.
Equipment design affects three principal mechanisms
of solvent loss from degreasers and defluxers. The
mechanisms are DIFFUSION, DRAGOUT, and
LEAKAGE.
DIFFUSION
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
fli
at t
2 i 2
Freeboard Width
'.Hi
ee r <
vn 5 ^
8 =
ce
•eeboard/Width
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
Water
Jacket
Sump Safe
Thermostat
Temperature
Indicator"
Steam Coils
Vapor
Safety Thermostat
Cleanout Door
Solvent Level
Sight Glass
Freeboard
Cpndensate
Trough
Water
Separator
Rood Valve
Heating Elements
Work Rest and Protective Grate
FIGURE 2 - Vapor Degreaser with Spray Attachment
Water
Jacket
Steam Coils
Spray Lance
Freeboard
Storage Tank
Water Separator
Cooling Water
Heating Elements
Work Rest Grate
0440684
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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
'incineration.
The degreaser has a freeboard-to-width ratio of 0.75 and is equipped
refrigerator coils and a hinged cover.
Identify candidate WM options.
-------
WASTE REDUCTION METHODOLOGY CHECKLIST:
' COMMODITIES PRODUCED. IN BATCHES
Dves. Inorganic Pigments, Paint, Agricultural Chemicals
Formulaliofen phenolic Resins, wood Preserving
Material Handling:
Reaetion/Processing
Step
Filtration and
Washing
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
-------
HOdVA
H31VA1
s
i
i
ft
b
b
-------
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
sludge.
lems.
frnhtem
* 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
Objective
* Reduce hazardous sludge
* Reduce worker exposure to lead dust
SEE ATTACHED PROCESS FLOW DIAGRAM
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-------
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
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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.
1313
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Instructions
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
blackboard.
'• ^^^^^^
much the modS representing the customer's desired color.
4. Exp.^^
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
pollution.
1313 5^t7»^T612) 379-5996
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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
pollution."
-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
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intended to help participants become more aware of sources of waste, options for waste
minimization, and resistance to change.
Objectives
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
1313
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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 ,
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Introduction
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
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Outline for Green Square Exercise
vl Introduction
Theory or Principles -
a. Principles of Operation
b. Purpose
c Objectives - .';••", " - .
Instructions Section
Equipment and Materials Needed
1313
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The Green Square
Game
An
Interactive Exercise
for
Waste Reduction Training
by
WRTTAR
Waste Reduction Institute
for Training and Applications Research
completed
February, 1991
by Thad Schifsky
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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
people.
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
uner
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 * * *
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- 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 * '* *
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- 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:
safety,
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 * * *
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CASE STUDY — ELECTROPLATING FACILITY ASSESSMENT
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 * * *
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~ 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
technologies.
• 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 * * *
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L2880H8 LBMUIED -- ELICTROPLAIIHO FACILITY
^
or
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 * * *
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CASE STUDY -- PETROLEUM REFINERY
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 * * *
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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
perspective?
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
* * *
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••*•
•*"
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
technologies.
of process
from one environmental medium
avoided whenever possible.
* * *
DRAFT: 8«pt«mb«r 21,
1990 * * *
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