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                            TABLE OF CONTENTS
1.    INTRODUCTION TO BEST MANAGEMENT PRACTICES  	1-1
      1.1    PURPOSE OF THIS MANUAL		1-1
      1.2    BACKGROUND OF NPDES PERMITTING  	. . 1-2
            1.2.1    BMP Regulatory History	1-3
      1.3    BEST MANAGEMENT PRACTICES AND POLLUTION
            PREVENTION	1-4

2.    BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT		2-1
      2.1    PURPOSE OF THIS CHAPTER	. . . .	2-1
      2.2    BMP APPLICABILITY	2-2
            2.2.1    What Activities and Materials at an Industrial Facility
                    Are Best Addressed by BMP?	........ 2-2
            2.2.2    How Do BMPS Work?	 . 1 . . 2-3
            2.2.3    What Are the Types of BMPS?		2-4
      2.3    COMPONENTS OF BMP PLANS .		2-5
            2.3.1    BMP Plan Planning Phase  .	2-6
                    2.3.1.1     BMP Committee	2-6
                    2.3.1.2     BMP Policy Statement	2-11
                    2.3.1.3     Release  Identification and Assessment  	2-15
            2.3.2    BMP Plan Development Phase  		2-23
                    2.3.2.1     Good Housekeeping	 2-24
                    2.3.2.2     Preventive Maintenance	2-29
                    2.3.2.3     Inspections	 ^	 2-35
                    2.3.2.4     Security	,	2-40
                    2.3.2.5     Employee Training	2-43
                    2.3.2.6     Recordkeeping and Reporting	2-48
            2.3.3    BMP Plan Evaluation and Reevaluation Phase	2-54
                    2.3.3.1     Plan Evaluation	 2-54
                    2.3.3.2     Plan Reevaluation  	2-55

3.    INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES		.3-1
      3.1    PURPOSE OF THIS CHAPTER	3-1
      3.2    INDUSTRY CATEGORY SELECTION  		3-2
      3.3    METAL FINISHING	3-3
            3.3.1    Industry Profile	 .	 . .	 .  3-3
            3,3.2    Effective BMPs . .	  3-4
      3.4    ORGANIC CHEMICALS, PLASTICS, AND SYNTHETIC FIBERS
            (OCPSF) MANUFACTURING	3-6
            3.4.1    Industry Profile	3-6
            3.4.2    Effective BMPs .	3-7
      3.5    TEXTILES MANUFACTURING	3-8
            3.5.1    Industry Profile	3-8
            3.5.2    Effective BMPs	3-10
      3.6    PULP AND PAPER MANUFACTURING 	3-11
            3.6.1    Industry Profile	3-11
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            3.6.2    Effective BMPs	3-13
      3.7    PESTICIDES FORMULATION	3-14
            3.7.1    Industry Profiles		3-14
            3.7.2    Effective BMPs	.	3-15
      3.8    PHARMACEUTICALS MANUFACTURING	3-16
            3.8.1    Industry Profile	3-16
            3.8.2    Effective BMPs	3-17
      3.9    PRIMARY METALS MANUFACTURING 	3-18
            3.9.1    Industry Profile		3-18
            3.9.2    Effective BMPs	3-20
      3.10   PETROLEUM REFINING	3-21
            3.10.1   Industry Profile	3-21
            3.10.2   Effective BMPs		3-22
      3.11   INORGANIC CHEMICALS MANUFACTURING	 3-23
            3.11.1   Industry Profile	3-23
            3.11.2   Effective BMPs	3-24

4.     RESOURCES AVAILABLE FOR DETERMINING BEST MANAGEMENT
      PRACTICES	4-1
      4.1    PURPOSE OF THIS CHAPTER	4-1
      4.2    NATIONAL AND INTERNATIONAL RESOURCES	4-1
            4.2.1    Pollution Prevention Information Clearinghouse (PPIQ	4-2
            4.2.2    International Cleaner Production Information
                    Clearinghouse (ICPIQ  . . .	4-5
            4.2.3    Waste Reduction Institute for Training and Applications
                    Research, Inc. (WRITAR)	4-6
            4.2.4    National Technical Information Service (NTIS)  	4-7
            4.2.5    Nonpoint Source (NPS) Information Exchange Bulletin
                    Board System  (BBS)	4-8
            4.2.6    Office of Water Resource Center	4-9
      4.3    REGIONAL RESOURCES	4-10
            4.3.1    Northeast Multimedia Pollution Prevention (NEMPP)
                    Program  	4-10
            4.3.2    Waste Reduction Resource Center for the Southeast
                    (WRRC)  . .	 4-11
            4.3.3    Pacific Northwest Pollution Prevention Research
                    Center (PNPPRC)		4-12
            4.3.4    EPA Offices and Libraries	4-13
      4.4    STATE, UNIVERSITY, AND OTHER AVAILABLE RESOURCES . .  . 4-16
            4.4.1    Center for Waste Reduction Technologies (CWRT)	4-16
            4.4.2    Solid Waste Information Clearinghouse (SWICH)	4-17
            4.4.3    State Resources	4-18
            4.4.4    University-Affiliated Resources	4-18
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APPENDIX A — BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT CHECKLIST

APPENDIX B — EXAMPLE FORMS AND CHECKLISTS

APPENDIX C — THEORETICAL DECISION-MAKING PROCESS FOR BMP PLAN
            DEVELOPMENT

APPENDIX D — BIBLIOGRAPHY
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                         LIST OF EXHIBITS
2-1    FACTORS AFFECTING SPECIFIC BMP SELECTION .. . ..	2-6
2-2    SUGGESTED ELEMENTS OF A BASELINE BMP PLAN		. . 2-7
2-3    BMP COMMITTEE ACTIVITIES AND RESPONSIBILITIES .	2-8
2-4    EXAMPLE OF COMMITTEE FORMATION TO EFFECTIVELY
      MANAGE AN ENVIRONMENTAL PROGRAM 	.	2-9
2-5    EXAMPLE OF THE USE OF A POLICY	2-12
2-6    AN EXAMPLE OF THE EFFECTIVENESS OF USING A RELEASE
      IDENTIFICATION AND ASSESSMENT APPROACH  .		  2-17
2-7    AN EXAMPLE OF THE SUCCESSFUL IMPLEMENTATION
      OF A GOOD HOUSEKEEPING PROGRAM .	2-26
2-8    CONSIDERATIONS FOR SELECTION OF MITIGATIVE PRACTICES . . .  2-28
2-9    DEMONSTRATION OF THE NEED FOR AN EFFECTIVE
      PM PROGRAM	.	2-31
2-10   EXAMPLES OF POOR COORDINATION BETWEEN
      OPERATIONS AND MAINTENANCE STAFF 		2-33
2-11   RELEASES WHICH COULD HAVE BEEN PREVENTED BY
      EFFECTIVE INSPECTION PROGRAMS	2-36
2-12   POSSIBLE COMPONENTS OF A SECURITY PLAN	2-41
2-13   EXAMPLE OF THE IMPLEMENTATION OF EMPLOYEE TRAINING
      TO ENSURE THE SUCCESS OF ENVIRONMENTAL CONTROLS	2-44
2-14   EXAMPLE OF AN EFFECTIVE REPORTING PROGRAM
      DESIGNED TO PREVENT ENVIRONMENTAL RELEASES	2-50
3-1    BMP SELECTION PROCESS	3-1
3-2    SUMMARY OF BMPs UTILIZED IN THE METAL FINISHING
      INDUSTRY	3-26
3-3    SUMMARY OF BMPs UTILIZED IN THE OCPSF
      MANUFACTURING INDUSTRY	3-36
3-4    SUMMARY OF BMPs UTILIZED IN THE TEXTILES
      MANUFACTURING INDUSTRY	3-38
3-5    SUMMARY OF BMPs UTILIZED IN THE PULP AND PAPER
      MANUFACTURING INDUSTRY  	3-43
3-6    SUMMARY OF BMPs UTILIZED IN THE PESTICIDES
      FORMULATION INDUSTRY	  3-48
3-7    SUMMARY OF BMPs UTILIZED IN THE
      PHARMACEUTICAL MANUFACTURING INDUSTRY	3-50
3-8    SUMMARY OF BMPs UTILIZED IN THE
      PRIMARY METALS MANUFACTURING INDUSTRY	3-52
3-9    SUMMARY OF BMPs UTILIZED IN THE PETROLEUM
      REFINING INDUSTRY			3-59
3-10   TYPES OF INORGANIC CHEMICALS	3-24
3-11   SUMMARY OF BMPs UTILIZED IN THE INORGANIC
      CHEMICALS MANUFACTURING INDUSTRY ....		3-60
4-1    PPIC CONTACT INFORMATION	4-3
4-2    INSTRUCTIONS FOR PIES USE	4-4
4-3    ICPIC CONTACT INFORMATION	4-6
4-4    WRITAR CONTACT INFORMATION	4-7
                                  NPDES Best Management Practices Manual

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                         LIST OF EXHIBITS
4-5    NTIS CONTACT INFORMATION . . .	4-8
4-6    NFS BBS CONTACT INFORMATION	4-9
4-7    OFFICE OF WATER RESOURCE CENTER CONTACT INFORMATION . . 4-10
4-8    NEMPP CONTACT INFORMATION	4-11
4-9    WRRC CONTACT INFORMATION		4-12
4-10   PNPPRC CONTACT INFORMATION		4-13
4-11   EPA REGIONAL POLLUTION PREVENTION CONTACTS	 4-14
4-12   EPA LIBRARY CONTACT INFORMATION  .	4-15
4-13   CWRT CONTACT INFORMATION . .	; . ... 4-17
4-14   SWICH CONTACT INFORMATION  .	4-18
4-15   STATE PROGRAM INFORMATION	4-19
4-16   UNIVERSITY AFFILIATED RESOURCES 	,	4-28
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INTRODUCTION TO BEST MANAGEMENT PRACTICES
CHAPTER 1
              1. INTRODUCTION TO BEST MANAGEMENT PRACTICES

       Best management practices (BMPs)  are  recognized as an important part of the  National
Pollutant Discharge Elimination System (NPDES) permitting process to prevent the release of toxic
and hazardous chemicals. Over the years, as BMPs for many different types of facilities have been
developed, case studies have demonstrated  not  only  the success but the flexibility of the  BMP
approach  in  controlling  releases  of pollutants  to receiving waters.   More recently, pollution
prevention practices have become part of the NPDES program, working in conjunction with BMPs
to reduce potential pollutant releases. Pollution prevention methods have been shown to reduce costs
as well as pollution risks through source reduction and recycling/reuse techniques.

       The Federal Water Pollution Control Act  of 1972 established the objectives of restoring and
maintaining the chemical, physical, and biological integrity of the Nation's waters. These objectives
remained unchanged in the 1977, 1982, and  1987 amendments, commonly referred to as the Clean
Water Act (CWA). To achieve these objectives, the  CWA sets forth a series of goals, including
attaining fishable and  swimmable designations by 1983 and eliminating the discharge of pollutants
into navigable waters by  1985.  As part of the CWA strategy to eliminate discharges of pollutants
to receiving waters, NPDES permit limitations have become more stringent.  The Environmental
Protection Agency (EPA) recognizes that industrial and municipal facilities  subject to the NPDES
program may need to undertake additional measures to meet these permit limitations,  as well as the
goals of the  CWA.  EPA believes that such measures can be technologically and  economically
achievable through the development of formalized plans that contain BMPs and  pollution prevention
practices.

1.1  PURPOSE OF THIS MANUAL
       The purpose of this manual is to provide guidance to NPDES permittees in the development
of BMPs for their facilities.  The manual may also be useful to NPDES permit writers and inspectors
charged with evaluating the  adequacy of BMP plans.  In particular, the manual  promotes the
integration of pollution prevention concepts and practices in BMP plans. This manual has four major
goals: (1) to provide a general understanding of the requirements of the CWA pertaining to BMPs
and show the relationship between  BMPs and pollution prevention practices; (2) to provide a starting
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point for developing and implementing an effective BMP plan that integrates facility-specific and
general BMPs and pollution prevention practices; (3) to provide specific examples of effective BMPs
and pollution prevention practices to aid facilities endeavoring to develop their own BMPs;  and
finally (4). to identify sources which a facility may consult when developing BMPs and pollution
prevention practices.

       This manual includes four chapters intended to achieve the above goals.  Chapter  1 provides
an  introduction to the NPDES program and the regulatory context for BMPs.  The relationship
between BMPs and other pollution prevention requirements such  as the Pollutant Prevention Act is
also discussed. Chapter 2 discusses the suggested components of a BMP plan, including  committee
formation, policy derivation, release identification and assessment, good housekeeping, preventive
maintenance, inspections, security, employee training,  and recordkeeping and reporting.  Each
component is defined and described  in terms  of what the component is, how the  component
functions, methods to create the component, and what to do/what not to do.  Additionally, the
usefulness of each component is  illustrated by an example, thereby promoting the development of
an  effective BMP plan.  Chapter  3 sets forth process-specific  BMPs for the metal plating  and
finishing, pesticides,  textiles, pulp  and paper, organic chemicals, Pharmaceuticals, primary metals
manufacturing and forming, inorganic chemicals, and petroleum refining industries.  Successful and
demonstrated BMPs  are discussed  in this chapter in terms of benefits to water,  benefits to other
media, and other incentives.  Data sources are also cited to enable readers to consult the referenced
document.  Finally, a discussion  of available resources at the international, national, regional,  and
State levels is presented  in Chapter 4..  Programs are summarized in terms of the general resources
available and limitations in the scope of assistance.  Specific information is provided to enable
readers to contact programs directly and obtain necessary information.

1.2 BACKGROUND OF NPDES PERMITTING
       The principal mechanism for reducing the discharge of pollutants from point sources is
through implementation  of the NPDES program,  established  by Section 402 of the CWA.   All
facilities with point  source discharges must apply for  and obtain  a NPDES  permit.   NPDES-
authorized States are tasked with issuing permits.  Where State NPDES authorization has not yet
occurred, EPA Regions issue NPDES permits..
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       Four minimum elements are typically included in each permit issued:  (1<) effluent discharge
limitations; (2) monitoring and reporting  requirements; (3)  standard conditions; and  (4) special
conditions. The numeric effluent discharge limits contained in a NPDES permit are based on the
most stringent value among technology-based effluent guidelines limitations, water  quality-based
limitations, and limitations derived on a case-by-case basis. Permits also contain standard conditions
that prescribe primarily administrative and legal requirements to which all facilities are  subject.
Finally, permits may contain any supplemental controls, referred to as special conditions, that may
be needed in  order to ensure that the regulations driving the NPDES program and, ultimately, the
goals of the CWA are met. Best management practices are one such type of supplemental  control.
1.2.1  BMP Regulatory History
       Section 304(e) of  the CWA  authorized the EPA Administrator to publish regulations to
control discharges of significant amounts of toxic pollutants listed under Section 307 or hazardous
substances listed under Section 31.1 from industrial activities that the Administrator determines are
associated with or ancillary to industrial manufacturing or treatment processes. As defined by the
CWA, the discharges to be controlled by BMPs are plant site runoff, spillage or leaks, sludge or
waste disposal, and drainage from raw material storage.

       On September 1,  1978,  EPA proposed regulations  (43  FR 39282) addressing the use of
procedures and practices to control discharges from activities  associated with or ancillary to industrial
manufacturing or treatment processes.  The proposed rule indicated how BMPs would be imposed
in NPDES permits to prevent the release of toxic and hazardous pollutants to surface waters.  The
regulations (40 CFR Part 125, Subpart  K, Criteria and Standards for Best Management Practices
Authorized Under Section 304(e) of the  CWA) were proposed on August 21, 1978, in the NPDES
regulations (43 FR 37078).  While this  Subpart never became effective, it remains in the Code of
Federal Regulations and can be used as  guidance by permit  writers.

       Although 40 CFR Part  125, Subpart K was  not finalized, EPA and States continue to
incorporate BMPs into permits based on the authority contained  in Section 304(e) of the CWA and
the regulations set forth in 40 CFR 122.44(k).  While Section 304(e) of the CWA restricts the
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             application of BMPs to ancillary sources and certain chemicals, the regulations contained in 40 CFR
             122.44(k) authorize the use of BMPs to abate the discharge of pollutants when (1) they are developed
             in accordance with Section 304(e) of the CWA,  (2) numeric limitations are infeasible, or (3) the
             practices are necessary to achieve limitations/standards or meet the intent of the CWA. Thus, permit
             writers are afforded considerable latitude in employing BMPs as pollution control mechanisms.

             1.3  BEST MANAGEMENT PRACTICES AND POLLUTION PREVENTION
                    Best management practices are inherently pollution prevention practices. Traditionally, BMPs
             have focused on good housekeeping measures and good management techniques intending to avoid
             contact between pollutants and water media as a result of leaks, spills, and improper waste disposal.
             However, based on the authority granted under the regulations, BMPs may include the universe of
             pollution  prevention  encompassing  production  modifications, operational  changes,  materials
             substitution, materials and water conservation, and other such measures.

                    EPA endorses pollution prevention as one of the best means of pollution control.  In 1990,
             the Pollution Prevention Act was enacted and set forth a national policy that:
                           "... pollution should be prevented or reduced at the source whenever
                           feasible;  pollution that cannot be prevented should be recycled in an
                           environmentally  safe  manner, whenever feasible;   pollution that
                           cannot  be  prevented or  recycled  should  be  treated  in   an
                           environmentally  safe manner  whenever  feasible;  and disposal  or
                           other release into the environment should be employed only as a last
                           resort and should be conducted in an environmentally safe manner."
                    EPA recognizes that significant opportunities exist for industry to reduce or prevent pollution
             through cost-effective changes in production, operation, and raw materials use.  In addition, such
             changes may offer industry substantial savings in reduced raw materials, pollution control, and
             liability costs, as well as protect the environment and  reduce health and  safety risks to workers.
             Where pollution prevention practices  can be both environmentally beneficial and economically
             feasible, EPA finds their implementation to be prudent.
_
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INTRODUCTION TO BEST MANAGEMENT PRACTICES
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       EPA believes that the intent of pollution prevention practices and BMPs are similar and that
they can be concurrently developed in a technologically sound and cost-effective manner.  Thus,
although this manual primarily focuses on best management practices, which pertain to the NPDES
program, the reader may be compelled to also consider pollution prevention for all media in order
to maximize the benefits achieved.
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BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT
CHAPTER 2
             2.  BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT

       Many facilities currently implement successful measures to reduce and control environmental
releases of all types of pollutants. These measures have been successfully implemented both formally
as part of best management practice (BMP)  plans and informally as part of unwritten standard
operating procedures. In the context of the NPDES permit program, permittees are required to
develop BMP plans to address specific areas of concern. The BMP plan developed by the permittee
becomes an enforceable condition of the permit.   The Environmental Protection Agency (EPA)
believes that to ensure the continuing and greater successes of these programs, pollution prevention
measures should be incorporated into a written company-wide plan.

2.1  PURPOSE OF  THIS CHAPTER
        This chapter  provides the reader with the information needed to develop and implement a
BMP  plan.   The chapter begins  with  a discussion of applicability of BMP plans to industrial
facilities. The remainder of the chapter provides a detailed discussion of each of the recommended
components of a BMP plan, set forth in the following format:
        •  What is the component? A description  is given including definitions, applicability, and
           general limitations.
        •  How does the component function ? The text discusses how the component interacts with
           other components, considerations when developing the component, and an outline of the
           steps involved in the development process.
        •  How is the component created/developed? An explanation of the detailed steps to take
           in developing a program around the element is provided.
        •  What to do/what not to do.  Guidance has been offered in terms of helpful hints as well
           as potential problems to avoid.

        To increase the usefulness of the information, examples of actual BMPs accompany the text.
 Additionally, three  appendices supplement  this  Chapter.  Considerations when planning and
 developing the BMP plan are set forth in a checklist format in Appendix A. Example forms and
 checklists that may  be  useful to  facilities in  the development and implementation of BMP plan
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 activities are provided in Appendix B.  Appendix C contains an example BMP plan and the decision-
 making process used during its development.

 2.2  BMP APPLICABILITY
       BMPs are developed as part of the National Pollutant Discharge Elimination System (NPDES)
 permitting requirements to control releases of harmful substances.  BMPs may apply to an entire site
 or be appropriate for discrete areas of an industrial facility.  Many  of the same environmental
 controls promoted as part of a BMP plan may currently be used by industry in storm water pollution
 prevention plans, spill prevention control and countermeasure (SPCC) plans, Occupational Safety and
 Health  Administration  (OSHA)  safety programs,   fire  protection programs,  insurance  policy
 requirements, or standard  operating procedures.   Additionally,  where  facilities have  developed
 pollution prevention programs, controls such as source reduction and recycling/reuse may be similar
 to those promoted as part of a BMP plan.  The following basic questions can be used to establish
 the scope of BMP plans: (1) What activities and materials at an industrial  facility are best addressed
 by BMPs?  (2) How do BMPs work?  and (3) What are the types of BMPs?

 2.2.1 What Activities  and Materials at an Industrial Facility Are Best Addressed by BMPs?
       Traditionally, BMP activities have  focussed on  activities  associated with or ancillary  to
 industrial manufacturing or treatment processes. These have been identified in Section 304(e) of the
 Clean Water Act as "plant site runoff, spillage or leaks, sludge or waste disposal, and drainage from
 raw material storage which the  Administrator determines are associated with or ancillary to the
 industrial manufacturing or treatment process."  These activities have historically been found to be
 amenable to control by BMPs. Some examples include the following:
       *   Material storage areas for toxic, hazardous, and other chemicals including raw materials,
           intermediates, final products, or byproducts. Storage areas may be piles of materials  or
           containerized substances. Typical storage containers could include liquid storage vessels
           ranging in size from large tanks to 55-gallon drums; dry storage in bags, bins, silos and
           boxes;  and gas  storage in tanks and  vessels.  The storage areas can be open to the
           environment, partially enclosed,  or fully contained.
       •   Loading and unloading operations involving the transfer of materials to and from trucks
           or rail cars, including in-plant transfers. These operations include pumping of liquids  or
           gases from truck or rail car to a storage facility or vice versa,  pneumatic transfer of dry
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CHAPTER 2
           chemicals during vehicle loading or unloading, transfer by mechanical conveyor systems,
           and transfer of bags, boxes, drums, or other containers from vehicles by fork-lift, hand,
           or other materials handling methods.

           Facility  runoff generated principally  from rainfall on a plant site.  Runoff can become
           contaminated with harmful substances when it comes in contact with material storage
           areas, loading and unloading areas, in-plant transfers areas, and sludge and other waste
           storage/disposal sites.  Fallout, resulting from plant air emissions that settle on the plant
           site, may also contribute to contaminated runoff.  In addition to BMPs, facility runoff
           from industrial sites may also be directly regulated under the NPDES storm water
           permitting program.                                                   ,

           Sludge and waste storage and disposal areas including landfills, pits, ponds, lagoons,
           and deep-well injection sites. Depending on the construction and operation of these sites,
           there may  be a  potential  for leaching of toxic pollutants or hazardous  substances to
           groundwater, which  can eventually  reach surface  waters.  In addition, liquids may
           overflow to surface waters from these disposal operations.
       With the increasing in awareness of pollution prevention opportunities as well as the increase

 in legislation  and regulatory policies directing efforts towards pollution prevention,  much  of the

 traditional focus  of BMP  activities is  being redirected  from  ancillary  activities  to  industrial

 manufacturing processes.  This redirection is resulting in  the integrated application of traditional

 BMPs and pollution prevention practices into cohesive and encompassing plans that cover all aspects

 of industrial facilities.


 2.2.2 How Do BMPs Work?

        •  BMPs are practices or procedures. They include methods to prevent toxic and hazardous
           substances from reaching receiving waters.  They are most effective when organized into
           a comprehensive facility BMP plan.

        •  BMPs are qualitative. They are designed to address the quality of a facility's practices,
           and may ultimately affect the  ability  of  the  facility to meet  environmental control
           standards.

        •  BMPs  are flexible.   Many  different practices  can  be used to  achieve similar
           environmentally protective results.  With  facility-specific considerations  as the major
           consideration hi selecting appropriate BMPs, this flexibility allows a facility to tailor a
           BMP plan to meet its needs using the capabilities and resources available.
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  2.2.3 What Are the Types of BMPs?
         BMPs may be divided into general BMPs, applicable to a wide range of industrial operations,
  and facility-specific (or process-specific) BMPs, tailored to the requirements of an individual site.
  General BMPs are widely practiced measures that are independent of chemical compound, source
  of pollutant, or industrial category.  General BMPs are also referred to as baseline practices, and are
  typically low in cost and easily implemented.  General BMPs are practiced to some extent at almost
  all facilities.   Common  general  BMPs  include good  housekeeping,  preventive  maintenance,
  inspections, security, employee training, and recordkeeping and reporting.

         Facility-specific BMPs are  measures used to control releases  associated with individually
  identified toxic and hazardous substances and/or one or more particular ancillary source.  Facility-
  specific BMPs are often developed when a facility notes a history of problem  releases of toxic or
  hazardous chemicals, or when facility personnel believe that actual or  potential pollutant discharge
  problems should be addressed.  Facility-specific BMPs may include many different practices such
  as source reduction and on-site recycle/reuse.

         Facility-specific BMPs will vary  from site to site depending  upon site characteristics,
  industrial processes, and pollutants.  For example,  a site-specific BMP in the form of area dikes may
 be adopted due to the location of the facility:  facilities in flat areas or on slopes are likely to utilize
 dikes to control  spills whereas there may be  no need for dikes for  facilities  located in basins.
 Additionally, plants handling and storing large amounts of liquid chemicals would be more likely to
' utilize dikes  than facilities storing  and using dry chemicals.   Facilities  experiencing erosion and
 sediment control  problems may consider establishing vegetative buffer  strips or indigenous ground
 cover for purposes of soil stabilization and infiltration of runoff.  Facility sites located adjacent to
 other industrial areas may consider runon controls to prevent  extraneous spills and contaminated
 runon from entering the facility site.  Other site-specific considerations,  such as endangered species,
 may motivate facilities to store materials in an alternate location so as to prevent  exposure.

        Processes also drive the determination of  appropriate specific  BMPs.   Materials handling
 procedures that  expose  employees  to toxic chemicals (e.g., hand  drawing)  may  prompt the
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CHAPTER 2
consideration of procedures that  reduce the potential for exposure (e.g., automated pneumatic
pumping in enclosed conduits).  Some examples of process-specific BMPs include the following:
       •  Using splash plates designed to prevent spills at a metal finishing facility
       •  Installing solvent recovery equipment to control benzene releases at a petroleum refinery
       •  Purchasing solvents in reusable containers rather than 55-gallon drums to ease storage
          concerns and reduce wastewater resulting from requirements to triple rinse  drums.

       Pollutant characteristics such as volatility and toxicity also affect BMP  selection. More and
more, harmful chemicals are being considered for replacement with less toxic alternatives, or for
elimination from the process. Ozone layer-depleting solvents which are  used  for cleaning at many
facilities are being  replaced with detergent-based cleaning agents.   Additionally, facilities using
materials with toxic properties have been inspired to take more proactive control measures (e.g.,
double walled containment).

       The choice of facility-specific BMPs can be affected by a number of factors such as those
discussed in Exhibit 2-1.

2.3  COMPONENTS OF BMP PLANS
       Suggested components of BMP plans are defined and  described  in this section.   The
suggested elements of a good BMP plan can be separated into three phases:  planning, development
and implementation, and evaluation/reevaluation. Generally, the planning phase, discussed in Section
2.3.1, includes demonstrating management support for the BMP plan and identifying and evaluating
areas of the facility to be addressed by BMPs.  The goal of plan development should be to ensure
that  its implementation will prevent or minimize the generation and the potential for release of
pollutants from the facility to the waters of the U.S. The development phase consists of determining,
developing, and implementing general and facility-specific BMPs and is described in Section 2.3.2.
The  evaluation/reevaluation phase described  in Section 2.3.3 consists  of an assessment of the
components of a BMP plan and reevaluation of plan components periodically, or as a result of factors
such as environmental releases and/or changes at the facility.  Suggested elements of a BMP  plan
are provided in Exhibit 2-2.
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          EXHIBIT 2-1: FACTORS AFFECTING SPECIFIC BMP SELECTION
             Chemical nature: The need to control materials bas^d on toxicity and fate and
             transport.    _             ..''"_      '..:  lT:_       . "*-,  r,  ',
             Proximity to waterbodies:  The need to control liquid spills prior to  their
             release to media such as water from which materials may not later be separated,
             Receiving waters:  The  need to protect sensitive receiving waters which are
             more severely impacted by releases of toxic or hazardous materials* The need
             to protect the water uses including recreational waters, drinking water supplies*
             and fragile aquatic and biota communities.
             Proximity to-populace: The need to control hazardous materials with potential
            . to be "released near populated areas.     ,                            '«
             Climate: The need to prevent volatilization and ignita1>iiity in warmer climates.
             The need to reduce wear on moving parts in freezing climates.  The need to
             avoid spills in climates and under circumstances where mitigation cannot occur.
             Age Of the facility/equipment:  the need to prevent releases caused by older
             equipment with greater capacity for failure.  The need to address obsolete and
             outdated instruments and  processes which are not environmentally protective.
             Process complexity: The need to address problems of materials incompatibility.
             Engineering design: The need to address design flaws and deficiencies.
             Employee safety:  The need to prevent unnecessary exposure between employee
             and chemicals.
             Environmental release record:  The need to control releases from specific
             areas demonstrating previous problems.                            '   <•
2.3.1 BMP Plan Planning Phase

       In the planning phase, a facility must decide who will take the responsibility for establishing

and carrying out the BMP plan.  The plan should be initiated with clear support and input from

facility management and employees. The facility must also identify and evaluate areas of the facility

that, because of the substances involved and their management, will be addressed in the BMP plan.

Each of these elements  is discussed in detail on the following pages.


2.3.1.1  BMP Committee

What is a BMP Committee?

       A BMP committee  is comprised of interested staff within the facility's organization.  The

committee  will represent  the  company's  interests  in all  phases  of  BMP  plan  development,
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.implementation,   oversight,   and   plan
evaluation.
 EXHIBIT 2-2:  SUGGESTED ELEMENTS
       OF A BASELINE BMP PLAN
       It  should be  noted  that  a BMP
committee may function similarly to other
committees that might exist at an industrial
facility   (e.g.,   pollution   prevention
committee)  and  may  include  the same
employees.

How Does the BMP Committee Function?
       The BMP committee is developed to
assist a facility in managing all aspects of
the BMP plan.  The committee functions to
conduct   activities   and   shoulder   the
responsibilities of all elements discussed in
Exhibit 2-3.
Planning Phase Considerations
1.   BMP committee
2.   BMP policy statement
3.   Release identification and assessment
Development Phase Considerations
4.   Good housekeeping
5.   Preventive maintenance
6.   Inspections
7.   Security
8,   Employee training
9.   Recordkeeping and reporting
Evaluation   and   Reevaluation   Phase
Considerations
10.  Evaluate plan implementation benefits
11.  Periodically or as needed, repeat steps 1-9
       To be most effective, the committee must perform tasks efficiently and smoothly. In large
 part, the personnel selected to act as committee members will determine the committee's success.
 Some of the considerations for personnel selection include the following:
       •  A lead committee member must be determined
       •  Committee members must include persons knowledgeable of the plant areas involved
          (e.g., process areas, tank farms) and utilization of chemicals and generation of pollutants
          (e.g., solvents, products, chemical reactants) at the facility
       •  Committee members should have the authority to make decisions effecting BMP plan
          development and implementation
       •  The size of the committee must be appropriate to the facility.
       •  The committee must represent affected areas of the plant and employees.
       An example of the effectiveness of the formation of a committee is provided in Exhibit 2-4.
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         EXHIBIT 2-3:  BMP COMMITTEE ACTIVITIES & RESPONSIBILITIES

             Develop the $cope of the BMP plan              ~ r.             ^      "
             Make recommendations to management in support of company BMP policy
             Review any existing accidental Spill control plans to evaluate existing BMP&
             Identify toxic and hazardous substances       ~   "_
             Identify areas with potential for release to the environment
             Conduct assessments to prioritize substances and areas "of concern^
             Determine and select appropriate BMPs
             Set forth standard operating procedures for implementation of BMPs
             Oversee the implementation of the BMPs
             Establish procedures for recordkeeping and reporting
             Coordinate  facility environmental release response, cleanup, and  regulatory
             agency notification procedures                   JlL
             Establish BMP training for plant and contractor personnel
             Evaluate the effectiveness of the BMP plan in preventing and mitigating releases
             of pollutants      -                             7r          -  '  .
             Periodically review the BMP plan to evaluate the need to  update and/or modify
             the BMP plan.
•
*
How Is a BMP Committee Developed?

       The BMP committee is responsible for developing the BMP plan and assisting the facility

management in its implementation,  periodic evaluation, and updating. While the BMP committee

is responsible for developing the plan and overseeing its implementation, all activities need not be

limited to committee members. Rather, appropriate company personnel who are knowledgeable in

the areas of concern can carry out certain activities associated with BMP plan development.  With

this in mind, the selection of the committee members can be limited to a select set of individuals,

while the resources of interested and knowledgeable employees can still be utilized.


       In order to ensure a properly run organization, one person should be designated as the lead

committee member.  Thus,  the first, step in developing a  BMP committee is to determine the

appropriate committee chairperson. The  determination of a  single leader will assist in the smooth

conduct of meetings  and the designation of tasks, and will aid in the decision-making  process.

Generally, the chairperson should be highly motivated to develop and implement the BMP  plan,

familiar with all committee members and their areas of expertise, and experienced in managing tasks
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             EXHIBIT 2-4: EXAMPLE OF COMMITTEE FORMATION TO
             EFFECTIVELY MANAGE AN ENVIRONMENTAL PROGRAM

             The 3M company, a manufacturer of diverse products such as coated abrasives,
      pressure sensitive tape, photographic film, electrical insulation materials, and reposition
      notes, has developed a corporate philosophy that Pollution Prevention Pays (referred to
      as the 3P program). As part of the 3P program,  3M has created a 3P Coordinating
      .Committee   which  includes  employee  representatives  from   the  engineering
      manufacturing, laboratory,  and corporate environmental sectors.

             The  3P Coordinating  Committee  provides  support and  coordination  for
      nationwide  teams establishing 3P  programs. These  3P Teams  are  organized  by
      employees that have identified pollution problems and recognize potential solutions.

             The 3P Coordinating  Committee and the 3P Teams have been instrumental in
      source reduction of hydrocarbons, odor, water, dissolved solids, sulfur, zinc, alcohol,
      and incinerated scrap. In the first year of the 3P  programs, air pollutants have been
      reduced by 123,000 tons, water pollutants by  16,400 tons, wastewater by 1,600 million
      gallons, and solid wastes pollutants by 409,000 tons. This has resulted in savings of
      more than $500 million.

       Adapted from: T. Zeal, "Case Study: How 3M Makes Pollution Prevention Pay Big
                  Dividends," Pollution Prevention Review, Winter 1990-91.
of this magnitude.  The chairperson will be responsible for ensuring that all tasks are assigned to

appropriate  personnel, keeping facility  management and  employees informed, and  cohesively

developing the BMP plan.  Potential candidates for this  role are plant managers, environmental

coordinators, or other distinctly knowledgeable technical and management personnel.


       The next step is to select the appropriate personnel to comprise the committee.  Personnel

selected should represent all affected facility areas.  Members might also be selected based on their

areas of expertise (e.g., industrial processes).   Personnel might be selected  who have  a full

understanding of the manufacture processes from raw materials to final products, as well as of the

recycling, treatment, and disposal of wastes.  Possible candidates include foremen in manufacturing,

production,  or waste  treatment and disposal; maintenance engineers; environmental  and  safety

coordinators; and materials storage and  transfer managers.  Not only must committee members

understand the activities conducted throughout the entire facility,  members of the BMP committee
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 rttust also include individuals who are in the decision-making positions within the company structure.
 Some committee members must represent company management and have the authority to implement
 measures adopted by the committee.

        While the BMP committee should reflect the lines of authority within the company, it should
 also be sensitive to general employee interests. It is crucial to ensure that employees are aware of
 and in support of the BMP plan and the responsible committee, as it is primarily the employees who
 will implement the changes resulting from committee decisions.  Forming a  committee comprised
 solely of upper level management and administrative personnel would exclude  general personnel
 whose input is critical for the development and implementation of the plan.   Selecting employee-
 chosen representatives,  such as union stewards, may be an appropriate means to ensure employee
 involvement.

        The size of a BMP committee  should reflect the size and complexity of the facility, as well
 as the quantity and toxicity of the materials at the facility.  The committee must be small enough to
 communicate in  a open and interactive manner, yet large  enough to  allow for  input from all
 necessary parties.

        Where needed,  committee members should call upon the expertise of others  through the
 establishment of project-specific  task forces.  For  example,  personnel involved in research and
 development may be asked to research the effectiveness of product substitution and process changes
 that are being considered as part of BMP plan development. This method of calling upon specialists,
 when the need arises, should allow the committee to remain a manageable size. Generally, the size
' selection process outlined below presents a good rule of thumb:
        •  For small facilities, a single committee member is acceptable as long as that person has
           the requisite expertise and  authority
        •  For larger facilities,  selection of six  to eight people as  permanent members of the
           committee should be ideal.
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BMP Committee - What to Do

       •  Develop a roster of BMP committee members which includes area of specialization and
          projected  responsibilities.  This list  helps  identify  any holes in the planned BMP
          development activities and any missing expertise.

       •  Include a list of alternate BMP committee members where transfers are expected to occur
          during the life of the BMP plan.

       •  Post BMP committee member names and including them  in the plan to allow  any
          interested parties the opportunity to contact BMP committee members.

       •  While developing and updating the BMP plan, include input from interested employees
          not on the committee. Employee input sessions and suggestions boxes can be used to
        .  meet this goal.

       •  Extend technical reviews to personnel not on the BMP committee, where specialized
          expertise is necessary or where interest is expressed.

       *  Follow up with all responsible parties on a periodic basis to ensure they are aware of
          their BMP-related responsibilities.

       •  Encourage BMP committee members to spend time on-the-line in order to communicate
          with other potentially interested parties.

       *  Set schedules with milestone dates for the performance of important  activities.  This
          avoids possible procrastination and allows  the  BMP plan development to remain on
          schedule.
       BMP Committee - What Not to Do

       •  The committee should enable, not impede, the decision-making process for preventing
          or mitigating spills or otherwise responding to events addressed by the BMP plan.

       •  Remember that personnel contributing to the design of a BMP need not be member of the
          BMP committee. This is of particular importance where a technical specialist or manager
          simply would not have the time to contribute on a regular basis.


2.3.1.2 BMP Policy Statement

What Is a BMP Policy Statement?

       A BMP policy statement  describes the objectives of the BMP program in clear,  concise

language and establishes the company policies related to BMPs. Exhibit 2-5 provides examples of

the successful use of a policy.
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                 EXHIBIT 2-5:  EXAMPLE OF THE USE OF A POLICY

            Dow.Chemical has observed a significant impact as a result of their company's
      environmental policy. As part of their "Environmental Policy and Guidelines," Dow has
      set forth a hierarchy similar to that developed as part of theTPollution Prevention Act
      of 1990, Dow's policy sets form preferences to handle materials by reducing pollutants
      at the source,  followed by  recycle and use of materials whenever possible. Where
      disposal is necessary,, Dow has specified that incineration be considered first, followed
      by land disposal on Dow-owned property, and finally land disposal on property not
      owned by Dow,

            Dow's decision to follow its disposal hierarchy wasTased in large part on the
      liability of disposal. Dow reasoned that incineration was the most appropriate disposal
      method since it resulted in the pollutants in the ash materials^ being in elemental form.
      In many cases, the company has identified opportunities for recycle of materials found
      in the incinerator ash. Dow also imposed a $215 per drum surcharge for hazardous
      wastes 'going to a landfill to provide incentives for finding  alternatives to landfilling,
      Dow  also believes  that they can better exercise control of onsite  disposal, thus
      influencing the preferences for onsite rather than off site disposal,

            Dow's  policy has resulted  in an impact on  the environmental releases.  For
      example, at the Dow Pittsburg, California facility, wastewater discharges have been
      reduced by 95 percent over the past 10 years. Additionally,  the approximately 10.2
      million pounds of chlorinated organics wastes which are generated are either incinerated
      or recycled.                -                                   	"_=_-,

              — Adapted from: D. Sarokin, W.  Muir,  C.  Miller, S. Sperber,
         -  Cutting Chemical Wastes: What 29 organic Chemical Plants are Doing to
            Reduce Hazardous Wastes, INFORM, Inc., New York, New York, 1985.
How Does a BMP Policy Statement Function?

       The policy statement provides two major functions:  (1)  it demonstrates and reinforces

management's support of the BMP plan; and (2) it describes the intent and goals of the BMP plan.

It is very important that the BMP policy represent both the company's goals and general employee

concerns.   Several steps to take  in developing an effective BMP policy statement  include the

following:
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       •   Determine the appropriate author
       •   Develop tone and content that are positive, but that establish realistic and achievable goals
       •   Distribute the policy statement effectively.

How Is a BMP Policy Statement Created?
       The first step in creating a BMP policy statement is determining the appropriate author.  To
indicate management's commitment, the policy statement should be signed by a responsible corporate
officer.  A responsible corporate officer can be the president, vice president, or the principal
manager of manufacturing, production,  or operations.  Generally, the policy statement author should
be a person who performs policy- or decision-making functions for the corporation/facility.

       The next step in developing the  BMP policy statement is to  craft the specific language.  The
policy statement may include references  to the company's commitment to being a good environmental
citizen, expected improvements in plant safety, and potential cost savings. Regardless of personal
style, in all cases the policy should: (1)  indicate the company's support of BMPs to improve overall
facility management and (2) introduce the intent of the BMP plan.

       The length and level of detail of the policy statement  will vary depending on the  writer's
personal style. The following variations may be included in a BMP policy statement:
       •  An outline of steps that will  be taken
       •  A discussion of the time frames for development and implementation
       •  An indication of the areas and pollutants of focus
       •  A projection of the end result of the BMP plan
       •  Create enthusiasm and support for  the BMP plan by all employees.

       The tone of the BMP policy statement  is also important.  The projected positive impacts of
BMP implementation should be discussed in general terms.   If specific goals  are outlined, the level
of information  and the expectations presented should  be reasonable, to avoid  overwhelming  the
reader.   Ultimately, the policy  should provide  an  upbeat message of the improved working
environment that will result from BMP implementation^  Since gaining  employee support is so
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important, it may be appropriate to solicit employee concerns prior to the development of the BMP
policy.  These concerns can be highlighted as areas which will be evaluated during BMP plan

development.


       Finally, to ensure that all employees are aware of the  impending BMP plan, the policy
statement should be printed on company letterhead (for an official appearance) and distributed to all
employees. Complete distribution can  be best ensured if the statement is both delivered  to each
employee and posted in common areas.


BMP Policy Statement - What to Do

       •  Utilize meetings and open sessions to solicit employee participation  in the development
          of the BMP policy.

       •  Demonstrate that employee  ideas are welcome by immediate follow-up on  suggestions.
          Discuss possible implementation opportunities or reasons that implementation is feasible.

       •  Keep the statement clear and concise.

       •  Post the BMP policy statement in key locations where employees  congregate so that
          employees will discuss it.

       •  Use the policy statement to  promote an emblem/motto that represents the BMP plan and
          its benefits.

       •  Emboss the objectives of the BMP policy on a plaque.


BMP Policy Statement - What Not to Do

       •  Do not include details of the BMP plan in the policy statement.

       •  The BMP policy statement should not be issued solely by the BMP committee. It should
          be issued by the company.
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2.3.1.3 Release Identification and Assessment
What Is Release Identification and Assessment?
       Release identification is the systematic cataloging of areas at a  facility with ongoing or
potential releases to the environment.  A release assessment is used to determine the impacts on
human health and the environment of any on-going or potential releases identified. The identification
and assessment process involves the evaluation of both current discharges and potential discharges.

       The release identification and assessment process can provide a focus for the range of BMPis
being considered on those activities  and areas of a facility where the risks (considering the potential
for release and the hazard posed) are the greatest.  In some cases, the assessment may be performed
based on experience and  knowledge of the substances and circumstances involved.  In other cases,
more detailed analyses may be necessary to provide the correct focus, and release assessments may
then rely  on some of the techniques of risk assessment (e.g., pathway analysis, toxicity, relative
risk).  Understanding the dangers of releases involves both an understanding of the hazards each
potential pollutant poses to human health and the environment, as well as the probability of release
due to the facility's methods of storage, handling, and/or transportation.

       -Some facilities may identify a number of situations or circumstances representing actual or
potential hazards that should all be  addressed in some detail through the BMP plan.  However, in
some instances prioritizing potential hazards is the most sensible  and cost  effective approach.  The
following example illustrates the need for BMP prioritization:  ACME Concrete is a concrete and
supply facility with a designated area used to house maintenance vehicles  and materials as well as
to stockpile construction materials and equipment.  Among other things, this facility contains a  large
stockpile of building sand used to prepare concrete, a vehicle maintenance  area where oil is drained
from company vehicles, and a shed where drums of solvents used in cleaning operations are stored.
Although  each of the three materials mentioned at the  site (sand, used oil, and solvents) can cause
environmental or health damage unless they are controlled, it would not be feasible or reasonable
to control losses of small amounts of clean building sand with the same careful attention given to the
release of toxic solvents.  As this simplistic example  shows, priorities for BMPs  should reflect a
basic understanding of the loss potential and hazards posed by these potential losses.  A prudent
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manager of the ACME Concrete maintenance yard could first limit the potential for escape of
solvents through careful training and periodic preventative maintenance and inspection of drums and
storage facilities, then prevent runoff of used oil to surface waters or groundwater by collecting and
recycling used oil, and finally control major losses of sand through constructions of filter fences or
sediment ponds.

How Does Release Potential Identification and Assessment Function?
       Identifying and assessing the risk of pollutant releases for purposes of a BMP plan can best
be accomplished in accordance with a five-step procedure:
       •   Reviewing existing materials and plans, as a source of information, to ensure consistency,
           and to eliminate duplication
       •   Characterizing actual and potential pollutant sources that might be subject to release
       •   Evaluating potential pollutants based on the  hazards they present to human health and the
           environment
       •   Identifying pathways through  which pollutants  identified at the site might  reach
           environmental and human receptors
       •   Prioritizing potential  releases.

       Once established, these priorities may be used in developing a BMP plan that places the
greatest emphasis on the sources with the greatest overall risk to human health and the environment,
considering the likelihood of release and the potential  hazards if a release should occur, while still
implementing low cost BMPs that might contribute to safety or other worker driven needs.  An
example of the effectiveness of this type of assessment is provided in Exhibit 2-6.

        An example of a release identification and assessment worksheet is provided in  Appendix B.
A completed version is also provided to demonstrate how this worksheet can  assist facilities in data
compilation..
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          EXHIBIT 2-6:  AN EXAMPLE OF THE EFFECTIVENESS OF USING
            A RELEASE IDENTIFICATION AND ASSESSMENT APPROACH

             Borden Chemical company conducted an evaluation of their Fremont, California,
      facility consistent with the approach for a release potential identification and assessment.
      Initially, Borden conducted extensive monitoring to determine the sources, of organic
      loadings. Then,  knowledgeable plant personnel conducted a plant inspection to identify
      and assess sources of organic loadings. The comprehensive inspection involved the
      evaluation of the entire site from initial materials arrival, through production, to final
      product shipment. The Borden staff were considerate of both actual and  potential
      sources. Based on the information from the monitoring program and the inspection, the
      plant management prioritized three areas in which modifications were needed:  filter
      rinse operations, reactor vessel rinses, and employee practices.

             Based on this assessment, Borden implemented a system which involves process
      changes, employee training,  and a  continuing  monitoring program.  Ultimately, the
      amount of organic materials discharged was reduced by 93 percent.

      Adapted from: D. Sarokin,W. Muir,C. Miller,S. Sperber,Cwm'/zg Chemical Wastes:
           What 29 Organic Chemical Plants are Doing to Reduce Hazardous Waste,
                         Inform, Inc., New York, New York, 1985.
 How Is a Release Potential Identification and Assessment Performed?

       The first step in the conduct of a release identification and assessment involves the review

 of existing materials and plans to gather needed information. Many industrial facilities are already

 subject to regulatory requirements to collect and  provide information that may be useful in the

 identification and assessment of releases. In some cases, these plans may have been developed by

 persons in plant safety or process engineering who do not normally consider themselves part of the

 environmental staff.  In particular, the following plans should be identified and reviewed:


       •   Preparedness, prevention, and contingency plans (see 40 CFR  Parts 264 and 265)
           require the identification of hazardous wastes handled at a facility.

       •   Spill control and countermeasures (SPCC) plans (see 40 CFR Part 112) require the
           prediction of direction, rate of flow, and total quantity of oil that could be discharged.
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 effects.  Some chemicals, for example, may be hazardous because of flammability  and therefore
 represent fire hazards. Other products may be toxic and represent a threat to waterways and their
 associated flora and fauna, contaminate groundwaters, and/or threaten workers cleaning-up spills who
 are not provided with the proper protective equipment (e.g., respirators).  Potential releases of
 pollutants to  the environment might be  subject to regulation under  environmental permits, and
 represent threats to the facility in the form of noncompliance.

        Detailed information on material properties should be available from plant safety personnel.
 When evaluating the threats posed by chemicals, facility personnel should consult available technical
 literature, manufacturer's representatives, and technical experts such as safety coordinators within
 the plant. A variety of technical resources can provide information of chemical properties including
 the following:
        •  Material safety data sheets
        •  American Council of Government and Industrial Hygienist publications on fume toxicity
        •  N. Sax, Dangerous Properties of Industrial Material, Seventh Edition, Volume 1-3, Van
           Nostrand Reinhold Company, Inc., New York, New York, 1989.
        •  National Institute of Occupational  Safety and  Health (NIOSH)  Pocket Guide to
           Chemical Hazards, U.S. Department of Health and Human Services, 1990.
        •  EPA guidance documents.  (Call EPA Public Information Center (202) 260-7751.)

        These references can provide information on specific physical/chemical properties that should
 be considered in evaluating hazards, including toxicity, ignitability, explosivity,  reactivity and
 corrosivity.  Careful evaluation of these data will provide a basis for determining the intrinsic threat
 posed by materials at the facility. Armed with  such understanding and subsequent identification of
 exposure pathways and potential receptors (the next step in the process), the need  for developing
 BMPs comes into focus.

        The fourth step in the release identification and assessment process  involves identifying
 pathways by which pollutants identified at the site might reach environmental and human receptors.
 Identifying the pathways of current releases can easily be accomplished based on visual observations.
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 However,  identifying  the pathways of potential releases requires  the use  of sound engineering
judgement in determining the point of release, estimating the direction and rate of flow of potential
 releases toward receptors of concern, and identification and technical evaluation of any existing
 means of controlling chemical releases or discharges (such as dikes  or diversion ditches).

        Information from the site  map and observations made during the visual inspection (e.g.,
 location of materials, potential release points, drainage patterns) should prove useful in this analysis.
 Of primary concern will frequently be exposures to workers in the immediate area of a release where
 concentrations will be highest.  Migration pathways for other exposures will often be of secondary
 concern.       •            .                    '

        When  identifying pathways  and  receptors, all  logical alternative pathways  should be
 considered. Contaminations may be released  through a  number of methods (e.g.,  volatilization,
 leaching, runoff) to a number of media (e.g., air, groundwater, soil), all which may result in release
to water.  The  analyst should  consider all pathways carefully  in combination with the materials
inventory to identify possible release mechanisms and receptor media.

        During  the site-assessment, each area  should be evaluated for potential problems.  These
problems might include equipment failure, evidence of wear or corrosion, improper operation (e.g.,
a tank overflow or leakage or exposure of raw material to runoff), problems caused by natural
conditions  (e.g.,  cracks or joint separation due  to extremes in temperature), and materials
incompatibility.  The adequacy of control and planned remedial measures should also be examined.
For example, the volume of oil in a storage tank holding liquid petroleum fuel oil might exceed the
amount that could be controlled by a dike or a berm in the case of a tank failure.  Increasing the size
of containment can remedy  such a problem.   The availability and location of absorbent materials
and/or booms would  be of interest  in  case of spill or  tank failure and  should be  evaluated to
determine sufficiency.

       The fifth and  final  step in the release identification and assessment process requires the
application of best professional judgment in  prioritizing potential  releases.  Priorities should be
established for both known and potential releases. A combination of information identified in the
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previous steps about releases (the probability of release, the toxicity or hazards associated with each

pollutant, and descriptions of the potential pathways for releases) should be evaluated. Using this

information, a facility can rank actual and potential sources as high, medium, or low priority.  These

priorities can then be used in developing a BMP plan that places the greatest emphasis on BMPs for

the sources that present the greatest risk to human health and environment.
Release Potential Identification and Assessment - What to Do

        «   Consider using other resources when conducting the release identification and assessment.
           Corporate or brother/sister company personnel may be available for consultation and
           assistance. Also, non-regulatory onsite assistance may be available (see Chapter 4 of this
           manual for details).

        •   Utilize worksheets and boilerplate formats to ensure that information is organized, easily
           evaluated, and easily understood.

        •   Utilize videotapes and photos to capture a visual picture of the facility site for use in later
           assessment  evaluations.  These  representations may  also  be  useful  in BMP plan
        ,   evaluation/reevaluation.

        •   Consider conducting monitoring to identify pollutants, pollutant loadings, and sources.

        •   Conduct brainstorming  sessions to  gather  creative  solutions for prioritized problems,
           followed by screening to eliminate impractical resolution.

        •   Evaluate technical merits and economic benefits of alternatives in an organized fashion.
           Consider ranking alternatives based on effects to product quality, costs, environmental
           benefits, ease of implementation, and success in other applications.

 Release Potential Identification and Assessment - What Not to Do

        •  Do not make the site map so busy that information cannot be discerned. Enlarge the site
           map, or separate information on transparencies to later superimpose on the base map.

        •  At large facilities, be cognizant of not overloading BMP committee members with release
           identification  and assessment responsibilities.  Consider the establishment  of several
           evaluation teams,  each assigned to assess a specific area.

        •  Do  not  make  changes in processes prior to  allowing for an update in the release
           identification  and assessment.  Allow for the determination as to whether alternate
           methodologies or materials can be identified which are more environmentally protective
           or cost effective.
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       •  Do not proverbially bite off more than the company can chew. Consider implementing
          changes in stages. Simple, procedural changes can be implemented immediately, while
          evaluations may need to be performed prior to the adoption of other measures.

2.3.2 BMP Plan Development Phase
       After the BMP policy statement and committee have been established and the release potential
identification and assessment has defined those areas of the facility that will be targeted for BMPs,
the committee can begin determining the most appropriate BMPs to control environmental releases.
The BMP plan should consist of both facility-specific BMPs and general BMPs.

       To provide a possible starting point in developing BMPs, Chapters 3 and 4 of this manual
present industry-specific BMPs and resources available for determining BMPs, respectively. These
chapters can be used as a convenient reference to determine one or more facility-specific BMPs that
might serve to reduce, control, or eliminate site-, process-, or pollutant-specific releases of harmful
substances.  Facilities should select the most appropriate specific BMPs based on effectiveness in
reducing,  controlling, or eliminating pollutants and feasibility.

       General BMPs are relatively simple to evaluate and adopt. As previously indicated, general
BMPs are practiced to some extent at all facilities.  It is EPA's belief that all BMP .plans should
consist of six basic components:
       •  Good housekeeping:  A program by which the  facility  is kept in a  clean and orderly
          fashion
       •  Preventive maintenance:  A program focused on preventing releases caused by equipment
          problems, rather than repair of equipment after problems occur
       •  Inspections:  A program established  to oversee facility operations and identify actual or
          potential problems
       •  Security:  A program designed to  avoid releases due to accidental or  intentional entry
       •  Employee training: A program developed to instill in employees an understanding of the
          BMP  plan
       •  Recordkeeping and reporting:  A program designed to maintain relevant information and
          foster communication.
       A discussion of each of these basic components follows.
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2.3.2.1 Good Housekeeping
What Is Good Housekeeping?
       Good housekeeping is essentially the maintenance of a clean, orderly work environment.
Maintaining an orderly facility means that materials and equipment are neat and well-kept to prevent
releases to the environment.  Maintaining a clean facility involves the expeditious remediation of
releases to the environment.  Together, these terms, clean and orderly, define a good housekeeping
program.

       Maintaining good housekeeping is the heart of a facility's overall pollution control  effort.
Good housekeeping cultivates a positive employee attitude and contributes to the appearance of sound
management principles at a facility.  Some of the benefits that may result from a good housekeeping
program include ease in locating materials and equipment; improved employee morale; improved
manufacturing and production efficiency; lessened raw, intermediate, and final product losses due
to spills,  waste  or releases; fewer health and safety problems arising  from poor materials and
equipment management; environmental benefits resulting from reduced releases of pollution; and
overall cost savings.

How Does a Good Housekeeping Program Function?
       Good housekeeping measures can be easily and  simply implemented. Some  examples of
commonly implemented good housekeeping measures include the orderly storage of bags, drums,
and piles  of chemicals; prompt cleanup of spilled liquids to prevent significant runoff to receiving
waters; expeditious sweeping, vacuuming, or  other cleanup of accumulations of dry  chemicals to
prevent them from reaching receiving waters; and proper disposal of toxic and hazardous wastes to
prevent contact with  and contamination of storm water runoff.

       The primary impediment to a good housekeeping program is a lack of thorough organization.
To overcome this obstacle, a three-step process can be used, as follows:

        •   Determine and designate an appropriate storage area for every material and every piece
           of equipment
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       •  Establish procedures requiring that materials and equipment be placed in or returned to
          their designated areas
       •  Establish a schedule to check areas to detect releases and ensure that any releases are
          being mitigated.                                                             ,
       The first two steps act to prevent releases that would be caused by poor housekeeping. The
third step acts to detect releases that have occurred as a result of poor housekeeping. Exhibit 2-7
provides an example of a good housekeeping program that has functioned to prevent releases.

How Is a Good Housekeeping Program Created?
       As with any new or modified program, the initial stages will be the largest hurdle; ultimately,
though, good housekeeping should result in savings that  far outweigh the efforts associated with
initiation and  implementation.  Generally,  a good housekeeping plan  should be developed in a
manner that creates employee enthusiasm and thus ensures its continuing implementation.

       The first step in creating a good housekeeping plan is to evaluate the facility site organization.
In most cases,  a thorough release identification and assessment has already generated the needed
inventory of materials and equipment and has determined their current storage, handling, and use
locations.  This information together  with that from further assessments can  then be used to
determine if the existing  location of materials and equipment are adequate in terms of space and
arrangement.

       Cramped spaces and those with  poorly placed  materials increase the potential for accidental
releases due to constricted and awkward movement in these areas. A determination should be made
as to whether materials can be stored in a more organized and safer manner (e.g., stacked, stored
in bulk as opposed to individual containers, etc). The proximity of materials to their place of use
should also be evaluated.  Equipment and materials used in a particular area should be stored nearby
for convenience, but should not hinder  the movement of workers or equipment. This is especially
important for waste products.  Where waste conveyance is  not automatic (e.g., through chutes or
pipes) waste receptacles should be located as close as possible to the waste generation areas, thereby
preventing inappropriate disposal leading to environmental releases.
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       EXHIBIT 2-7:  AN EXAMPLE OF THE SUCCESSFUL IMPLEMENTATION
                       OF A GOOD HOUSEKEEPING PROGRAM
            Emerson Electric Company's Murphy, North Carolina location developed a good
     housekeeping program which resulted in better waste management. Emerson noted that
     a number of activities contributed unwanted pollutants to their treatment plant and storm
     water discharges. These included oil spills from the scrap loading site (20 gallons per
     week),  spills from the aluminum die-casting operations (45 gallons per week), and
     dumping of miscellaneous chemicals  including  monthly dumping of alkaline cleaner»
     Additionally, the  company noted that unlabelled hazardous chemicals were located in
     random locations, some in outside storage areas.  These chemicals  and other non-
     hazardous substances were identified as having the potential to result in spills of up to
     20,000 pounds.

            As a result, the facility established good housekeeping procedures and measures
     which included:
             •   Installation  of sump  and pump in the die-casting and scrap
                loading areas which recovered 65 gallons of oil per week.
                                                  ~ ,      ^ f*f f ~ -
                                              •'      •»   .•*•*    „; „
             •   Requirements for the discontinuance of dumping activities.

             •   Implementation of labeling and manifesting procedures for all
                hazardous wastes  and the storage  of  these wa'stes in inside
                controlled areas.

             The program involved informing personnel of their "responsibilities under the
      program and the maintenance of daily log sheets which demonstrate proper activities.
      The ongoing good housekeeping program is monitored closely by the in-plant process
      engineer. Any violations of good housekeeping procedures are reported to and addresses
      by the plant manager.

                     Adapted from: D. Huisingh, L. Hilger, N.  Seldman,
        Proven Profits from Pollution Prevention: Case Studies in Resource Conservation
        and Waste Reduction, Institute for Local Self-Reliance, Washington, D.C., 1985.
       Appropriately designated areas (e.g., equipment corridors, worker passageways, dry chemical

storage areas) should be established throughout the facility.   The effective use of labeling is an

integral part of this step.  Signs and adhesive labels are the primary methods used to assign areas.

Many facilities have developed innovative labeling approaches, such as color coding the equipment

and materials used in each particular process.  Other facilities have stenciled outlines to assist in the

proper positioning of equipment and materials.
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       Once a facility  site has been organized in this manner, the next  step is to ensure that
employees maintain this organization.  This can be accomplished through explaining organizational
procedures to employees during training sessions (see 2.3.2.5 for information on training programs),
distributing written instructions, and most importantly, demonstrating by example.

       Support of the program must be demonstrated, particularly by responsible facility personnel.
Shift supervisors and others in positions of authority should act quickly to initiate activities to rectify
poor housekeeping.   Generally, employees will  note  this dedication  to the good housekeeping
program and  will typically  begin  to  initiate good housekeeping activities  without prompting.
Although  initial implementation of good  housekeeping procedures may  be challenging,  these
instructions will soon be followed by employees as standard operating procedures.

       Despite good housekeeping measures, the potential for environmental  releases remains.
Thus, the  final step in developing a good housekeeping program involves the prompt identification
and mitigation of actual or potential releases. Where potential releases are noted, measures designed
to prevent release can be implemented.  Where actual releases are occurring, mitigation measures
such as those described  below may be required.

       Mitigative practices are simple in theory: the immediate cleanup of an environmental release
lessens chances of spreading contamination  and lessens  impacts due to  contamination.   When
considering choices for mitigation methods,  a facility must consider the physical state of the material
released and the media to which the release occurs.  Some considerations are provided in Exhibit
2-8.   Generally,  the ease  of implementing mitigative  actions should also be  considered.   For
example,  diet, crushed  stone,  asphalt,  concrete,  or other covering may  top a  particular  area.
Consideration as to which substance would be easier to clean  in the event  of a release should be
evaluated.

       Conducting periodic inspections is an excellent method to verify the implementation of good
housekeeping measures.  Inspections may be especially important in the areas identified in the release
identification and assessment step where releases have previously occurred.  Inspections and related
concerns are discussed in Section 2.3.2.3.
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                 EXHIBIT 2-8: CONSIDERATIONS FOR SELECTION
                             OF MITIGATIVE PRACTICES

            Manual cleanup methods, such as sweeping and shoveling, are generally most
            appropriate for materials released in the solid phase to solid media and  small
            releases Of liquids which have saturated the soil,
            Mechanical cleanup methods such as excavation ^practices  (e.g.,  plowing,
            backhoeing), are most  appropriately used for large releases  of solid phase
            materials to solid media and  for larger areas  contaminated by liquid material
            releases to the soil.  Vacuum  systems, a less common mechanical cleanup
            method, can be used for large releases of solid phase materials to solid media
            and for removing liquids released to water media when mixing has not occurred.
            Other  cleanup methods  may  be the only option for mitigating  the release of
            certain materials to the environment.  These include the following:
            *   Sorbents such as straw, sawdust, clay,  activated carbon and miscellaneous
                complex organics may be  used to clean up small gaseous or  liquid releases
                to water and solid media.  Sorbents must later be remediated by manual or
                mechanical cleanup methods.
            -   Gelling  agents  including poly electrolytes, polyacrylamide, butylstyrene
                copolymers, polyacrylonitrile, polyethylene oxide, and the universal gelling
                agent interacts with a liquid or gaseous releases to form a more viscous mass
                which can then  be remediated by manual or mechanical cleanup methods.
                Gelling agents can effectively mitigate liquid releases prior to discharge to
                a water media or infiltration into the soil.
       It may not always  be possible to immediately correct  poor housekeeping.   However,

deviations should occur only in emergencies.  The routines and procedures established as a part of

the program should allow for adequate time to conduct good housekeeping activities.


Good Housekeeping - What to Do

       •  Integrate  a  recycling/reuse  and  conservation  program  in  conjunction  with good
          housekeeping. Include recycle/reuse opportunites for common industry wastes such  as
          paper, plastic, glass, aluminum, and motor oil, as well as facility-specific substances such
          as chemicals, used oil, dilapidated equipment, etc. into the good housekeeping program.
          Provide reminders of the need for conservation measures including turning off lights and
          equipment when not in.use, moderating heating/cooling, and conserving water.

       •  When reorganizing, keep pathways and walkways clear with no protruding containers.

       •  Create environmental awareness by celebrating Earth Day (April 22) and/or developing
          a regular (e.g., monthly) good housekeeping day.
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          Develop slogans and posters for publicity.   Involve employees and their families by
          inviting suggestions for slogans and allowing children to develop the facility's good
          housekeeping posters.                                                        .

          Provide suggestion boxes for good housekeeping measures.

          Develop a competitive program that may include company-wide competition or facility-
          wide competition.  Implement an incentive program to spark employee interest (i.e., l/i
          day off for the shift which best follows the good housekeeping program).

          Conduct inspections to determine the implementation of good housekeeping.  These may
          need to be conducted more frequently in areas of most concern.

          Pursue an ongoing information exchange throughout the facility, the company, and other
          companies to identify beneficial good housekeeping measures.

          Maintain necessary cleanup supplies (i.e., gloves, mops, brooms, etc.).

          Set job  performance standards which include aspects of good housekeeping.
Good Housekeeping - What Not to Do

       •  Do not allow rubbish or  other waste to accumulate.   Properly dispose of waste, or
          arrange to have it removed in a timely fashion.

       •  Do not limit good housekeeping measures to industrial  locations.  Office areas should
          also be involved in the good housekeeping program.
2.3.2.2 Preventi.ve Maintenance

What Is Preventive Maintenance?

       Preventive maintenance (PM) is a method of periodically inspecting, maintaining, and testing

plant equipment and systems to uncover conditions which could cause breakdowns or failures.  As
part of a BMP plan, PM focusses on preventing environmental releases.  Most facilities have existing

PM programs.  It is not the  intent of the BMP plan to require development of a  redundant PM
program.   Instead, the objective  is to have personnel evaluate their existing PM program and
recommend changes,  if needed,   to address concerns raised as part of the  release  potential

identification and assessment (See Section 2.3,1.3).  Ultimately, this will  result in the focus  of

preventive maintenance on the areas and pollutants determined to be of most concern. Where no re-
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focussing is necessary, the PM program suggested as part of the BMP plan and the existing PM
program can be identical.

       A PM program accomplishes its goals by shifting the emphasis from a repair maintenance
system to a preventive maintenance system.  It should be noted that in some  cases, existing PM
programs are limited to machinery  and other moving equipment.  The PM program prescribed to
meet the goals of the BMP plan includes all other items (man-made and natural)  used to contain and
prevent releases of toxic and hazardous materials.   Ultimately, the well operated  PM program
devised to support the BMP plan should produce environmental benefits of decreased releases to the
environment, as well as reducing total maintenance costs and increasing the efficiency and longevity
of equipment, systems, and structures.

How Does a Preventive Maintenance Program Function?
       In terms of BMP plans, the PM  program should prevent breakdowns  and failures  of
equipment, containers,  systems, structures, or other devices used to handle the toxic or hazardous
chemicals or wastes.   To meet this goal, a PM program  should  include a suitable system  for
evaluating equipment, systems, and  structures; recording results; and facilitating corrective actions.
A PM program should, at a minimum, include the following activities:
       •   Identification of equipment, systems, and  structures to which the PM program  should
           apply
       •   Determination of appropriate PM activities and the schedule for such maintenance
       •   Performance of PM activities in accordance with  the established schedule
       •   Maintenance of complete PM records  on the  applicable equipment and  systems, and
           structures.

       Generally, the PM program is designed to prevent and/or anticipate problems resulting from
equipment and structural  failures.   However, it is unrealistic to expect that the PM  program will
avert the need for repair maintenance as a result of unanticipated problems.  Adjustments and repair
of equipment will still be necessary where problems occur, and replacement of equipment will be
necessary when adjustment and repair are not sufficient.
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       Generally, all  good PM  programs will  consist of the four components noted above.

However, it is of particular importance that the PM program address those areas and pollutants

identified during the release identification and assessment step.  Exhibit 2-9 provides a summary of

releases which are attributed in part to inadequate PM programs.  These releases demonstrate the

need for an effective PM program.


              EXHIBIT 2-9: DEMONSTRATION OF THE NEED FOR AN
                             EFFECTIVE PM PROGRAM

            From a period beginning July 1983 to July 1988, EPA recorded the following
      catastrophic spills:  126,000 gallons crude oil; 8 tons anhydrous ammonia;  10,000
     'gallons hydrochloric acid; 100,000 gallons toluene, xylene and methyl-ethyl ketone;
     ,4,000 bbl of phenol; 60,000 gallons of sodium hydroxide; 3,000 gallons or aromatic
      hydrocarbons; 50,000  pounds  of  phenol  and  cyclohexane; 3,000  gallons  of
      miscellaneous solvent;  60,700 gallons of sodium  bisulfite;  100,000 gallons  of a
      combination  of cadmium, phenol,  and  methylene  chloride;  700,000  gallons of
      ammonium nitrate; 25,000 gallons of jet fuel; 8 tons of anhydrous ammonia; and 1,500
      gallons of hexanol isobutyrate.

       Adapted from: "Best Management Practices (BMPs) in NPDES Permits-Information
         Memorandum, "EPA Office of Water, dated April 15, 1983, March 23, 1984,
            June 3, 1985, August 29, 1986, August 11, 1987, and August 19, 1988.
 How Is a Preventive Maintenance Program Created?


       Although creating and implementing PM programs sounds easy, it is often impeded by lack

 of funding and-of organization.  Lack of funding must be overcome by a facility's  commitment to

 its PM program based on the simple truth that PM  is  less costly than replacement.   Lack of

 organization can be overcome by better planning, which can be achieved by following the steps to

 developing an effective PM plan discussed below.
                                  f

       At the outset of a PM  program, an inventory  should be devised.  This inventory should

 provide a central record of all equipment and structures including: location; identifying information

 such as serial numbers and facility equipment numbers/names; size, type, and model; age; electrical

 and mechanical data; the condition of the equipment/structure; and the manufacturer's address, phone
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number,  and person to contact.   In  addition to the  equipment inventory, an  inventory of the
structures and other non-moving parts to  which the PM  program is to apply should also  be
determined.

       Inventories can be developed through inspections and/or reviews of facility specifications and
operations and maintenance manuals.  In some cases, it is effective to label  equipment and structure
with assigned numbers/names and some of the identifying information.  This information may be
useful to maintenance personnel in the event of emergency situation or unscheduled maintenance
where maintenance information is not readily available.  Several different methods are effective for
recording inventory information including the use of index cards, prepared  forms and checklists, or
a computer database.

       Since the PM program involves the use of maintenance materials (i.e., spare parts, lubricants,
etc.), some additional considerations may apply.  First, good housekeeping measures, as discussed
in Section 2.3.2.1, are particularly important for organizing maintenance materials and keeping areas
clean.   A  tracking system may also be necessary for  organizing maintenance  materials.  The
inventory should include information such as materials/parts description, number, item specifications,
ordering information, vendor addresses and phone numbers, storage locations, order quantities, order
schedules and costs. A large facility may require a parts catalog to coordinate such information.
Large facilities may also find it necessary to develop a purchase order system which maintains the
stock in adequate number and in the proper order by keeping track of the minimum and maximum
number of items required to make timely repairs, parts that are vulnerable to breakage, and parts that
have a long delivery time or are difficult to obtain.

       Once the inventory is completed, the facility should determine the PM requirements including
schedules and specifications for lubrication, parts replacement,  equipment and structural testing,
maintenance of spare parts, and general observations.  The* selected PM activities should be based
on  the  facility-specific conditions  but should be  at  least as stringent as the  manufacturer's
recommendations. Manufacturer's specifications can generally be found in brochures and pamphlets
accompanying equipment.  An operations and maintenance manual also may  contain this information.
If these sources  are not available,  the  suggested manufacturer's recommendation can be obtained
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directly from the manufacturer.  In cases of structures or non-moving parts, the facility will need to
determine an  appropriate maintenance activities  (e.g., integrity  testing).   As with  inventory
information, PM information should be recorded in an easily accessible format.

       After establishment of the materials inventory and the development of PM requirements, a
facility  should schedule  and carry out PM  on a regular basis.   Personnel with  expertise in
maintenance should be available to conduct maintenance activities.  In a small facility where one
        %
person may conduct regular maintenance activities, specialized contractors may supplement the
maintenance program for more complex activities.  An up-to-date list of outside firms  available for
contract work beyond the capability of the facility  staff should be readily available.   Additionally,
procedures explaining how to obtain such support should be provided in the BMP plan.  Larger
facilities should have sufficient PM expertise within the staff including a PM manager, an electrical
supervisor, a mechanical supervisor, electricians, technicians, specialists, and clerks  to order and
acquire parts and maintain records.  Ongoing training and  continuing  education programs may be
used to establish expertise in deficient areas.  Training is discussed in more detail in Section 2.3.2.5.

       Maintenance activities should be coordinated with normal plant operations so that any shut-
downs do not interfere with production schedules or environmental protection.  Examples showing
the results of poor coordination between operations and maintenance staff are given in Exhibit 2-10.

    ""™" EXHIBIT 2-10:  EXAMPLES OF POOR COORDINATION BETWEEN
                       OPERATIONS AND MAINTENANCE STAFF
       Operator-caused
       Maintenance-caused
Inattention to unusual noises  or  conditions; too many
motor stops and starts in one day; tampering with limit
switches; failure to report suspected problems.
Not replacing trip switches; bypassing fail safe systems
or  instrumentation;  imprecise  equipment  alignment;
failure to report other noticed  equipment deficiencies
       Adapted from: Plant Maintenance Program Manual of Practice OM-3, Water Pollution
       Control Federation, Alexandria, VA, 1982.
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              The  maintenance supervisory  staff should also consider  other  timing  constraints  such as the
              availability of the PM staff for both regularly scheduled PM and unanticipated corrective repairs.

                     The  final step in the development  of a PM program involves  the organization and
              maintenance of complete records. A PM tracking system which includes detailed upkeep, cost, and
              staffing information should be utilized.  A PM tracking system  assists facilities  in:  identifying
              potential equipment or structural problems resulting from defects, general old age, inappropriate
              maintenance, or poor engineering design;  preparation of a maintenance department budget; and
              deciding whether a piece of equipment or a structure should continue to be repaired or replaced.

                     There are many commercial software systems that  enable facilities  to track maintenance.
              Computer  systems  allow for input of inventory  and  PM  information and generate daily,  weekly,
              monthly, and/or yearly maintenance sheets which include the required the item to be maintained, the
              maintenance duties, and materials to be used (e.g.,  oil,  spare parts, etc.).    The system can be
              continually updated to add  information gathered during maintenance activities.   Some of the
              maintenance information that proves useful includes the work hours spent, materials used, frequency
              of downtime for repairs, and costs involved with maintenance  activities.  This information in turn
              can generate budgets and determinations of the cost effectiveness of repair versus replacement, etc.
              Computerized systems for maintenance tracking are usually  most effective at larger facilities.

                     Useful  manual systems may involve  index cards,  maintenance logs, and  a  maintenance
              schedule.  Initially, inventory and PM information can be recorded on index cards. This information
              can be consulted during maintenance activities. Maintenance logs should also be developed for each
              piece of equipment and each structure, and should contain information such as the  maintenance
              specifications,  and  data associated  with  the completion of maintenance activities.  Maintenance
              personnel should complete relevant information including the  date maintenance was conducted, hours
              spent on duties, materials used, worker identification, and the nature of the problem.  Appendix B
              provides some examples of formats to use in organizing and recording inventory, PM requirements,
              and PM duty information.
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Preventive Maintenance - What to Do

       •  When  attaching information to  equipment and structures, use bold and bright colors
          consistent with the approaches described for good housekeeping.

       •  Consider and discuss additional PM procedures beyond those normally recommended by
          the manufacturer.

       •  Conduct extensive safety training for PM personnel.

       •  Coordinate scheduling of PM activities with facility or unit downtime.

       •  Keep track of how long materials have been stored.  This will support an evaluation of
          the integrity of storage containers.

       •  Develop a PM staff team approach including team names (i.e., the A-team) to create
          enthusiasm.

       •  Utilize  blackboards and charts  to  assist in organizing and conveying an annual PM
          schedule.               .
Preventive Maintenance - What Not to Do

       •  Do not forget to stock important replacement parts and any specialized tools required to
          repair equipment.

       •  Do not create a paperwork nightmare.  Develop the minimum number of well-organized
          logs necessary to maintain information.

       •  Do not let untrained, unskilled personnel conduct PM activities.  Employees taking part
          in the PM program must be familiar with equipment and maintenance procedures.

       •  Do not forget to determine the availability and time needed to obtain vital parts or
          contractor assistance.
2.3.2.3 Inspections

What Are Inspections?

       Inspections provide an ongoing method to detect and identify sources of actual or potential

environmental releases.   For example, Exhibit 2-6 in Section 2.3.1.3 described the use of an

inspection during release identification and assessment. Inspections also act as oversight mechanisms

to ensure that selected  BMPs are being implemented. Inspections are particularly  effective in
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evaluating the good housekeeping and PM programs previously discussed.  Many of the releases

highlighted in Exhibit 2-9 in Section 2.3.22 also can be partly attributed to failures  in inspection
programs. In addition,  Exhibit 2-11 describes a number of additional  releases  which resulted

primarily from ineffective inspection programs.

      EXHIBIT 2-11:  RELEASES WHICH COULD HAVE BEEN PREVENTED BY
             71         EFFECTIVE INSPECTION PROGRAMS

            From July 1983 to July 1988, EPA recorded the following releases:  100,000
      gallons of toluene, xylene, and methyl ethyl ketone;  300 gallons of phosphorous
      trichloride; 1,100 gallons of trichloroethane; 3,000 gallons of heavy polymer distillate;
      more  than  8>000 gallons of  methyl  isobutyl ketone; and 100,000 gallons of a
      combination of cadmium, phenol, and methylene chloride.

      Adapted from: Best management Practices (BMPs) in NPDES Permits - Information
         Memorandum, EPA Office of Water, dated April 15, 1983, March 23, 1984,
            June 3, 1985, August 29,- 1986, August 11, 1987, and August 19, 1988.
       Many facilities may be currently conducting inspections, but in a less formalized manner.

Security scans, site reviews, and facility, walk throughs conducted by plant managers and other such

personnel qualify as inspections.  These types of reviews, however, are often limited in scope and

detail.   To ensure the objectives of the BMP plan are met, these types of reviews should be

conducted concurrently with periodic, in-depth inspections as part of a comprehensive inspection

program.


How Does an Inspection Program Function?

       Inspections implemented as part of the BMP plan should cover those equipment and facility

areas identified during the release identification and assessment as having the highest potential for

environmental releases.  Since inspections may vary in scope  and detail, an inspection program

should be developed to prevent redundancy while still ensuring adequate oversight and evaluation.


       A BMP inspection program should set out guidelines for: (1) the scope of each inspection;

(2) the personnel assigned to conduct each inspection; (3) the inspection frequency;  (4) the format
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for reporting inspection findings; and (5) remedial actions to be taken as a result of inspection
findings.

       Despite the different requirements of each type of inspection, the focus of inspections
conducted as part of the BMP plan should not vary. As discussed in Section 2.2, some of the areas
within the facility that may be the focus of the BMP plan include solid and liquid materials storage
areas, in-plant transfer and materials handling areas, activities with potential to contaminate storm
water runoff, and sludge and hazardous waste disposal sites.

How Is am Inspection Program  Created?
    *   An inspection program's goal will be to ensure thoroughness, while preventing redundancy.
Ultimately, this will ensure that the use of resources is optimized. In addition, it should be clear that
the inspection team's efforts are directed to  support  the operating groups  in carrying out their
responsibilities for equipment and personnel safety, and  work quality,-and to ensure that all standards
are met.   In achieving these goals, written procedures discussing the scope,  frequency  and
scheduling, personnel, format, and remediation procedures should be provided. These are discussed
in the following paragraphs.

       The scope of each inspection type should be discussed  in the written procedures.  Many
different types of inspections are conducted as part of the inspection program. Guidelines for the
scope of these inspections include:
       •   Security scan: Search for leaks and spills which may be occurring.  Specifically examine
           problems areas which  have been identified by the plant manager or equivalent persons.
       •   Walk through:  Conduct  oversight of the  duties associated with  a security scan.  In
           addition, ensure that equipment and materials are located in their appropriate positions.
       •   Site review:  Conduct oversight of duties associated with a walk through. Additionally,
           evaluate the effectiveness of the PM, good housekeeping, and security programs by visual
           oversight of their implementation.
       •   BMP plan oversight  inspection:   Conduct oversight of duties associated with a site
           review. Evaluate the implementation of all aspects of the written BMP plan including the
           review of the records  generated as part of these programs (e.g., inspection reports, PM
           activity logs).
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          BMP plan evaluation!revaluation inspection: Conduct an evaluation/reevaluation of the
          facility and determine the most appropriate BMPs to control environmental releases.
       An appropriate mix of these types of inspections should be developed based on facility-
specific considerations. The proper frequency for conducting inspections will vary based on the type
of the inspection and  other facility-specific factors.   Some general guidelines for establishing
frequency follow:
       •  Security scans can be conducted various times daily
       •  Walk through inspections can be conducted once per shift to once per week
       •  Site reviews can be  conducted once per week to once per six months
       •  BMP plan oversight inspections can be conducted once per month to once per year
       •  BMP plan reevaluation inspections can be conducted once per year to once every five
          years.

       There  are no hard  and fast rules  for conducting inspections as part of the BMP plan.
Inspection frequencies should be based on a facility's needs.  Two points should be considered when
establishing an inspection program: (1) As would be expected, more frequent inspections should be
conducted in the areas  of highest concern; and (2) inspections must be conducted more frequently
during the initial BMP implementation until the BMP plan procedures  become part of standard
operating procedures.

       It may  be useful to set up a schedule to ensure a comprehensive inspection program. Varying
the dates  and  times of inspection conduct  is also  good practice in  that it ensures all stages of
production and all situations are reviewed.

       Individuals qualified to  assess the potential for environmental releases should be assigned to
conduct formal inspections.  Members of the BMP committee can generally fulfill this requirement,
but they may not be available to conduct all inspections. Thus, it may be appropriate to identify  and
train personnel to conduct  specific types of inspections.  For  example,  shift foremen  and other
equivalent supervisory personnel may appropriately conduct walk throughs and site reviews as a
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result of their position of authority and ability to require prompt correction if problems are observed.
Personnel with immediate responsibility for an area should not be asked to conduct inspections of
that area as they may be tempted to overlook problems.  Additionally, plant security and other
personnel who routinely  conduct  walk throughs should  not  be assigned to  conduct BMP plan
inspections since their familiarity with the facility may result in their not being suited to best identity
opportunities for improvement.

       Different  perspectives are useful  when conducting inspections.  By developing a team
inspection approach or by alternating inspectors, facilities can receive a more thorough review. One
inspector may observe something that another will overlook, and an inspector tends to focus on the
areas with which  he/she is most familiar.

       An inspection checklist of areas to inspect with  space for a narrative report is a helpful tool
when  conducting inspections.    A  standard form  helps  ensure  inspection  consistency and
comprehensiveness. Sample inspection forms and checklists are provided in Appendix B.

       Checklists may not be necessary for each inspection performed.  This may be particularly
true for facilities  conducting frequent inspections (once per hour, once per shift, etc.); procedures
for using inspection checklists should be reasonable to prevent paperwork nightmares.

       The findings of inspections  will be useless unless  they are  brought to the attention  of
appropriate personnel  and  subsequently acted  upon.  To ensure that reports are acted upon in  an
expeditious and appropriate manner,  procedures  for  routing  and review of reports should  be
developed and followed. Recordkeeping and reporting is discussed  in Section 2.3.2.6.

       Despite the usefulness of written reports, in no way  should  a written report replace verbal
                                         i
communication. Where a problem is noted, particularly environmental releases currently occurring
or about to occur, it should be verbally communicated by the inspector to the responsible personnel
as soon as  possible.
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Inspections - What to Do
       •  Encourage workers to conduct visual  inspections  and report any  actual or potential
          problems to the appropriate personnel.
       •  Develop inspection checklists for each type of inspection. Vary them where necessary
          for each part of the facility subject to BMPs.
       •  Consider utilizing non-regulatory support from EPA, States, or university supported
          resources when conducting site assessments.
Inspections - What Not to Do
       •  Do not rely solely on the use of a checklist for inspections.  Narrative descriptions should
          be included in the reports to ensure that problems are identified and discussed.
       •  Do not conduct inspections and then fail to provide feedback of findings of concern to
          the person responsible for the area inspected.
2.3.2.4 Security
What Is a Security Plan?
       A  security plan describes the system installed to prevent accidental or intentional entry to a
facility that might result in vandalism, theft, sabotage, or other improper or illegal use of the facility.
In relation to a BMP plan, a security system should prevent environmental releases caused by any
of these improper or illegal acts.

       Most facilities already have a program for security in place; this security program can  be
integrated into the BMP plan with minor modifications.  Facilities developing a program for security
as part of the BMP plan may be hesitant to describe their security measures in detail due to concerns
of compromising the facility.  The intent of including a security program as part of the BMP plan
is not to divulge facility or company  secrets; the specific security practices  for the facility may  be
kept as part of a separate confidential system. The security program as part of the BMP plan should
cover security in a general fashion, and discuss in detail only the practices which focus on preventing
environmental releases.
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How Does a Security Plan Function?

       The security program as part of the BMP plan should be designed to meet two goals.  First,

the security  plan should prevent security breaches that result in the release of hazardous or toxic

chemicals to the environment. The second goal is to effectively utilize the observation capabilities

of the security plan to identify actual or  potential releases to the  environment.  Some  of the

components that are typically included in a security scan are provided in Exhibit 2-12.

          EXHIBIT 2-12:  POSSIBLE  COMPONENTS OF A SECURITY PLAN

      «     Routine patrol of the facility property by security guards in vehicles or on foot
      •     Fencing to prevent intruders from entering the facility site
      •     Good lighting to facilitate visual inspections at night, and of confined spaces
      •     Vehicular traffic control (i.e.,  signs)
      »     Access control using guardhouse or main entrance gate, where all visitors and
            vehicles are required to sign in and obtain a visitor's pass
      •     Secure or locked entrances to the facility
     , *     Locks on certain valves or pump starters
      •     Camera surveillance of appropriate sites, such as facility entrance, and loading
            and unloading areas
      •     Electronic sensing devices supplemented with audible or covert alarms
      •     Telephone or other forms of communication.
How Is a Security System Created?

       Typically, security systems focus on the areas with the greatest potential for damage as a

result of security breaches.  As part of the BMP plan, the security program will focus on the areas

that result in environmental  releases.  Typically, these areas have been identified in  the release

identification and assessment step.  In many cases, the findings of this step may  indicate a need to

change the focus or broaden the  scope of the security program to  include areas of  the facility

addressed by the BMP plan.  Since the security program may not be  common knowledge, general

BMP committee members may not be able to recommend changes.  As a result, security personnel

should be involved in the decisions made by the committee, with one person possibly serving as a

member.
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       While performing their duties, security personnel can actively participate in the BMP plan
by checking the facility site for indications of releases to the environment. This may be accomplished
by checking that equipment is  operating properly; ensuring no leaks or spills are occurring at
materials storage areas; and checking on problem areas (i.e., leaky valves, etc).

       The advantages  of integrating security  measures into the BMP plan are  considerable.
Security personnel are in positions that enable them to conduct periodic walk throughs and scans of
the facility, as well as covertly view facility operations. They are in an excellent position to identify
and prevent actual or potential releases to the environment.

       Where  security personnel are utilized as part of the  oversight program,  two  obstacles
generally must  be overcome:  (1) support must be gained from the security staff; and (2) security
personnel must  be knowledgeable about what may and may not be a problem, and to whom to report
when there is a problem. Involving the security staff in the BMP plan development at an early stage
should assist in gaining their support.   Integration  of  the  security staff into the training,  and
recordkeeping and reporting programs discussed in Section 2.3.2.5 and  2.3.2.6, respectively, can
also be used to  overcome these barriers.

Security -  What to Do
       •   File detailed documentation of the security system separately from the BMP plan to
           prevent unauthorized individuals from gaining access to confidential information.
       •   Make certain that all security personnel are aware of their assigned responsibilities under
           the BMP plan.
       •   Post security and informational signs and distribute security and direction  information to
           visitors.  This may be particularly useful for frequently visited buildings.

Security -  What Not to Do
       •   Do not assume that isolation is adequate security.
       •   Do not locate alarms or indicator lights where they cannot be readily seen or  heard.
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2.3.2.5 Employee Training
What Is Employee Training?
       Employee training conducted as part of the BMP plan is a method used to instill in personnel,
at all levels of responsibility, a complete understanding of the BMP plan, including the reasons for
developing the plan, the positive impacts of the plan, and employee and managerial responsibilities
under the BMP plan.  The  employee training  program should also educate employees about the
general importance of preventing the release of pollutants to water, air, and land.

       Training programs are a routine part of facility life.  Most facilities conduct regular employee
training in areas  including fire drills, safety, and miscellaneous technical subject areas.  Thus, the
training program developed as a result of the BMP plan should be easily integrated into the existing
training program.

       Employee training conducted as part of the BMP plan should focus on those employees with
direct impact on plan implementation.  This may  include  personnel involved with manufacturing,
production, waste treatment and disposal, shipping/receiving, or materials storage; areas where
processes  and materials have been identified as being of concern;  and PM, security, and inspection
programs.  Training programs, which include all appropriate personnel, should include instruction
on spill response, containment, and cleanup. Generally, the employee training program should serve
to improve and  update  technical, managerial,  or administrative skills; increase motivation; and
introduce  incentives for BMP plan implementation.

How do Employee BMP Training Programs Function?
       Employee training programs function through:  (1) analyzing training needs;  (2) developing
appropriate training materials; (3) conducting  training; and (4)  repeating training  at  appropriate
intervals in accordance with  steps 1 through 3.  This four step process should be utilized during all
employee  training.  An example of an employee training program is provided in Exhibit 2-13.
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             EXHIBIT 2-13: EXAMPLE OF THE IMPLEMENTATION OF
              "EMPLOYEE TRAINING TO ENSURE THE SUCCESS OF
                           ENVIRONMENTAL CONTROLS
            The largest metal finishing shop in New England began a series of experiments
     with water reuse and conservation measures to reduce water usage from their high level
     of 140,000 gallons per day.  Their studies resulted in the installation of flow nozzles
     which initially reduced their water  use to 60,000 gallons per day* After reaching this
     level, experiments were discontinued.  Immediately, water use rebounded to 100,000
     gallons  per day due to employee  backsliding to previous less conservation-oriented
     practices.                              '       "-"  *T-''

            Realizing that additional measures were necessary, the company installed dead
     rinse tanks and a series of countercurrent rinse tanks.  These measures, supplemented
     by a program of recycle and reuse, reduced pollutant discharge concentration such that
     treatment was unnecessary to comply with effluent limitation.  Additionally, the flow
     rate was reduced 40,000 gallons per day. However, due to their earlier experience with
     employee backsliding after implementation, the facility developed an employee training
     program that ensured a proper understanding of equipment operation and emphasized
     the benefits of water conservation.  This maintained the impetus of the source reduction
     and recycling measures.

               Adapted from:  Cutting the Cost of Complying wftji Electroplating
                    Water Regulations  Through Conservation, EPA, 1982.
How is an Employee Training Program Created?

       The first stage in developing a training program is  analyzing training needs.  Generally,

training needs to be conducted during the planning and development phases of the BMP plan, and

as follow-up to BMP implementation for selected areas of concern. In all three cases, it is important

to analyze training needs and develop appropriate training tools to use during conduct of the training.


       The initial BMP development session educates employees of the need for, objectives of, and

projected impact of the BMP plan.  As would be expected, this initial training should be conducted

at the onset of the BMP development.  The message portrayed at this session should be the positive

impacts of'the BMP plan including  ease in locating materials and equipment;  improved employee

morale; improved manufacturing and production efficiency; lessened raw, intermediate and final

product losses due to releases; fewer health and safety problems arising from unmitigated releases

and/or poor placement of materials  and equipment; environmental benefits resulting from reduced
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releases of pollution; and overall cost savings. When providing this message, it is essential that the
benefits for employees as well as the company itself be stressed.

       While it is important to point out the reasons that lead to the decision to implement a BMP
plan, it is also important to provide a realistic picture of the changes and impacts which will result.
These modifications should be discussed in terms of their positive impact to help maintain a high
level of enthusiasm.

       After the  BMP plan is developed,  the BMP implementation training sessions should be
developed.  The training sessions should review the BMP plan and associated procedures, such as
the following:
       •  Any of the industry-specific BMPs selected from examples in  Chapter 3 or developed
          based on facility-specific considerations
       •  The good  housekeeping  program  including the use  of labeling (signs,  color  coding,
          stenciling,  etc.) to assign areas and procedures to return materials to assigned areas
       •  The PM program, including new PM schedules and procedures
       •  Integration of the security plan with the BMP  plan
       •  Inspection  programs
       •  Responsibilities under the recordkeeping and reporting system.

       In some cases, it may be appropriate to  provide a general session explaining BMP plan
implementation followed by  specialized training for each area.. For example, since  all employees
shou.ld be aware of the good housekeeping program, this program should be discussed at the general
session.  Training for the selected facility-specific BMPs may be necessary only for employees in
the production and manufacturing .areas.  PM information could be presented only to the personnel
conducting maintenance,  while security  personnel need  only be  briefed  of security-related
responsibilities under the BMP plan.

       Targeting the audience and determining training needs dictate many of the remaining aspects
of employee training,  including the following elements:
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       •  Determination of meeting room sizes which will seat the audience comfortably.
       •  Selection of speakers qualified to discuss the topics to be presented.
       •  Determination  of seating  arrangement to best accomplish the goal of the  training.
          Classroom style seating is best for lecture type sessions, while round tables will  stimulate
          interactive type sessions.
       •  Selection of audiovisual  aids such as podium mikes,  lavaliere  mikes, blackboards,
          standing  overhead and/or slide  projectors, video cassette recorders,  and  television
          monitors.
       •  Development of materials that convey training session information in a highly  readable,
          yet creative format.
       •  Development of agendas that require consideration of all topics to ensure that the chosen
          topics can be discussed in the time allotted.
       •  Determination  of training materials which must be prepared.
       Training sessions are only as effective as the level of preparation.  It is vital that workshop
materials  are technically accurate,  easily read, and well organized.   More  importantly, training
materials must leave a strong impression such that their message is remembered and  any distributed
training materials are consulted in the  future.  The use of audiovisual  aids supplemented with
informational handouts is one of the best methods of conveying information.  Including copies of any
slide or overhead helps avoid distractions during presentation caused by employees' copying contents
of overheads.   Other techniques which assist in effectively conveying  information include the
following:
        •   Providing aesthetically pleasing covers and professional looking handouts
        •   Developing detailed tables of contents with well numbered pages
             /
        •   Frequently assimilating graphics into presentations
        •   Integrating break-out sections and exercises
        •   Incorporating team play during exercises
        •   Allowing for  liberal question/answer  sessions  and  discussions  during  or  after
           presentations
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        •  Providing frequent breaks
        •  Integrating field activities with class room training.

        The use of qualified personnel to conduct training presentations also supports the facility's
 commitment to BMP  plan  implementation.  Speakers should be identified in the initial training
 preparation stages based on their expertise in the topics to be presented. However, expertise is not
 the  only consideration.   Expertise  must be  supplemented with  a well executed, interesting,
 enthusiastic presentation.  Preparation prior to the training event will allow speakers to organize
 presentations, establish timing, and develop tone and content.  Speakers should consider undergoing
 a dry run during which the speaker provides the full presentation including use of audio/visual aids.

        Proper planning should ensure the execution of an effective training event. Once the training
 event has been conducted, some follow-up activities should be conducted.  For example, evaluation
 forms requesting feedback on the training  should  be  distributed to  employees.  These evaluation
 forms can be used to identify presentation areas needing improvement, ideas needing clarification,
 and future training activities. Ultimately, information gathered from these forms can help direct the
 employee training program in the future.

        Once BMP plan implementation is underway, training should be conducted both routinely and
 on an as need basis.  Special training sessions may also be prompted when new employees are hired,
 environmental release incidents occur, recurring problems are noted  during inspections, or changes
 in the BMP plan are necessary.

 Employee Training - What to Do
        •  Show strong  commitment and periodic input from top  management to the employee
          training program to create the necessary interest for a successful program.
        •  Ensure that  announcements of training events are posted well in advance and include the
          times and dates of the sessions, the names and positions of the instructors, the lesson
          plans, and the subject material covered.
        •  Make the training. sessions interesting.   Use  film and  slide presentations.  Bring in
          speakers to  demonstrate the use of cleanup materials'or  equipment.  Contact the State
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          health  and environmental  agencies or the regional EPA  office for  films, volunteer
          speakers, or other training  aids.
       •  Use employee incentive programs ,or environmental  excellence awards to reinforce
          training programs.
       •  Conduct demonstrative hands-on  field training to show the effectiveness  of good
          housekeeping, PM, or inspection programs.
       •  Give frequent refresher courses and consider pop quizzes to keep employees sharp.
Employee Training - What Not to Do
       •  Do not provide training to permanent facility employees only.  Overlooking temporary
          and contractor personnel can increase the possibility of environmental releases.
       •  Do not allow training session attendance to be optional.  Employees in the positions that
          incur the most stress in terms of meeting schedules should be reminded to avoid taking
          shortcuts when handling toxic or hazardous chemicals.
       •  Do not become too standardized.  Reusing an annual employee training session will be
          tedious to employees. Integrate new information and improve on old information.
2.3.2.6 Recordkeeping and Reporting
What Is Recordkeeping and Reporting?
       As part of a BMP plan, recordkeeping focusses on maintaining records that are pertinent to
actual or potential environmental releases.  These records may include the background information
gathered as part of the BMP plan, the BMP plan itself, inspection reports, PM records, employee
training materials, and other pertinent information.

       Maintenance of records is ineffective unless a program for the review of records is set forth.
In particular, a system of reporting actual or potential problems to appropriate personnel must be
included. Reporting, as it relates to the BMP plan, is a method by which appropriate personnel are
kept informed of BMP plan implementation such that appropriate actions may be determined and
expeditiously taken. Reporting may be verbal or follow a more formal notification procedure. Some
examples of reporting include the following:
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        •  Informational memos distributed  to upper management or employees to keep them
           updated on the BMP plan
        •  Verbal notification by BMP inspectors to supervisors concerning areas of concern noted
           during inspections
        •  Corrective  action reports from the BMP committee to the plant manager which cite
           deficiencies with BMP plan implementation
        •  Verbal and written notification to regulatory agencies of releases to the environment.

 How Does a Recordkeeping and Reporting Program Function?
        A recordkeeping and reporting program effectively functions through the following three step
 procedure:
        •  Developing records in a useful format
        •  Routing records  to appropriate personnel for review and determination of actions to
           address deficiencies
        •  Maintaining records for use in future decision making processes.

        Recordkeeping  and  reporting play an  overlapping  role with  the  programs  previously
 discussed.  In general, these programs will involve the development, review, maintenance, and
 reporting of information  to  some degree.   For  example, an inspection program may include the
 development  and use of  an  inspection  checklist, submittal  of the completed checklist to relevant
 personnel,  evaluation of the inspection information, and determination of appropriate corrective
 actions.  This may, in some  cases, involve the development of a corrective action report to submit
 to appropriate persons (which may  include regulatory agencies where necessary/required).  The
 checklist and the corrective action reports should be maintained in organized files.

       As part of the BMP plan, a recordkeeping and reporting program will primarily be developed
 for the PM (Section 2.3.2.2) and inspection (Section 2.3.2.3) programs.   However, effective
communication  methods  can also be useful in the  development of the release identification and
assessment portion of the BMP plan as discussed in Exhibit 2-14.  A discussion of the step-by-step
procedure for the development of an effective recordkeeping and reporting program follows.
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       EXHIBIT 2-14: EXAMPLE OF AN EFFECTIVE REPORTING PROGRAM
               DESIGNED TO PREVENT ENVIRONMENTAL RELEASES

            West Point Pepperell, a textile manufacturing organization, established a Toxic
      Chemicals Committee consisting of a medical doctor,  an industrial hygienist, three
      research  chemists,  an  engineer,  an  attorney,  a safety  officer,  a  production
      representative, and an information specialist  The committee is  designed to review
      chemical use at 40 manufacturing facilities across the country. Their reviews evaluate
      the chemical use danger to human health and the environment, and the availability of
      alternative chemicals.                                 li .       /   -—,  /

            The committee set forth notification procedures aimed  at controlling  new
      chemicals prior to the advent of use. These procedures required facilites to report
      potential chemical use to the committee for prior review and approval.  Through these
      internal reporting procedures, the  committee has been kept abreast of potentially
      discharged pollutants.  Recommendations from  the committee have resulted in the
      rejection  of requests to  use  materials  with  potential -to form benzidenes  and
      bis(chloromethyl)ether.  Additionally, the company attributes low levels of hazardous
      waste production to the work of the committee.
                                                     ^  V   -" r            f       ^
        Adapted from:  D. Huisingh, L. Martin, N. Hilger, N. Seldman, Proven Profits
         from Pollution Prevention: Case Studies in Resource Conservation and Waste
             Reduction, Institute for Local  Self-Reliance, Washington, D.C., 1985.
How Is a Recordkeeping and Reporting Program Created?

       A recordkeeping and reporting program must be developed in an organized manner. This

ensures both the efficient use of resources and the compliance with regulatory requirements. Thus,
a three step procedure involving development, review and reporting, and maintenance of records is

suggested.


       The  first  step  to  ensuring  an  effective  recordkeeping  and  reporting program is  the

development of records in a useful format.  The use of standard formats (i.e., checklists) can help
to ensure the completion of necessary information, thoroughness in reviews, and understanding of

the supplied data.  For example, a standard inspection format may specify a summary of findings,

recommendations, and requirements on the first page; then, detailed information by geographical area

(e.g., materials storage area A, materials storage area B, the north loading and unloading zone) may
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 be discussed.  With a standard format, an inspection report reviewer may quickly review the findings
 summary to determine where  problems exist, then refer to the detailed discussion of  areas of
 concern.    Ultimately, the use  of a  standard  format minimizes  the  review time, expedites
 decisionmaking concerning corrective actions, and simplifies reporting.

       Despite the recommended use of standard formats, inspectors should not feel constrained by
 the format.  Sufficient detail must be provided in order for the report to be useful. Narratives should
 accompany  checklists where necessary to provide detailed information on materials  that have been
 released or have the potential to be released; nature of the materials involved; duration of the release
 or potential release; potential or actual volume; cause; environmental results of potential or actual
 releases; recommended countermeasures; people and agencies notified; and possible modifications
 to the BMP plan, operating procedures, and/or equipment.

     ,  The second step to ensuring an effective recordkeeping and reporting system involves routing
 information to appropriate personnel for review and determination of actions to address deficiencies.
 Regardless of whether the system for recordkeeping and reporting is structured or informal, the BMP
 plan should  clearly indicate:  (1) How information is to be transferred (i.e., by checklist, report, or
 simply by verbal notification); and (2) to whom the information is to be transferred  (i.e., the plant
 manager, the supervisor in charge, or the BMP committee leader).

       Customarily, formal means to transfer information would be more appropriate in larger more
 structured companies. For example, reviews of findings and conclusions as part of inspection reports
 may be conducted by supervisory personnel and .the information may be routed through the chain of
 command to  the  responsible personnel such as  shift  supervisors  or foremen.   Less  formal
 communication methods such as verbal notification may be appropriate for smaller facilities.

       The  key to ensuring a useful communication  system is identifying one person (or, at  larger
 facilities, several persons) to  receive and dispense records and information.  This person will be
 responsible for ensuring that designated individuals review records where appropriate,  that corrective
 actions are identified, and that appropriate personnel are notified of the need to make corrections.
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Additionally, this person will ensure that information is maintained on file for use in later evaluations
of the BMP plan effectiveness.

       It should be noted that the recordkeeping  and  reporting system is designed to help, not
hinder, the communications process. Verbal communications of impending or actual releases should
be made regardless of whether a formal communications process has been set forth.

       A communications system for notification of potential or actual release should be designated.
Such a  system could  include telephone or radio contact between  transfer operations, and alarm
systems that would signal the location of a chemical release. Provisions to maintain communication
in the event of a power failure should be addressed.   Reliable communications  are essential to
expedite immediate action and  countermeasures to  prevent incidents  or to  contain and mitigate
chemicals released.

        A reporting system should include procedures for notifying  regulatory agencies.  A number
of agencies may require reporting of environmental releases including, Department of Transportation,
Department of Energy, miscellaneous Department  of Interior agencies,  and the EPA.  It is outside
the scope of this manual to provide a summary of  all necessary reporting requirements.  However,
reporting requirements specified under the NPDES permitting program  include, at  a minimum, the
following:
        •   Releases in excess of reportable quantities which are not authorized by an NPDES permit
        •   Planned changes which
           -   subject the facility to new source requirements
           -   significantly change the nature or quantity of pollutants discharged
           -   change a facility's sludge use or disposal practices
               may result in noncompliance
        •  Notification within 24 hours of any unanticipated discharges (including bypasses and
           upsets) which may endanger human health  or the environment, and the submission of a
           written report within five days
        •   The discharge of any toxic or hazardous pollutant above notification  levels.
        •   Any other special notification procedure or reporting requirement specified in the NPDES
            permit.
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        Reports maintained in the recordkeeping system can be used in evaluating the effectiveness
 of the BMP plans, as well as when revising the BMP plan. Additionally, these records provide an
 oversight mechanism which allows the BMP committee to ensure that any detected problem has been
 adequately resolved.  As such, the final step in developing a recordkeeping and reporting program
 involves the development and maintenance of an organized recordkeeping system.

        In general, an organized filing system  involves selecting an area for maintaining files,
 labelling files appropriately, and filing information in an organized manner.  A single location should
 be designated for receiving the data generated for and related to the BMP plan.  At larger facilities,
 several locations may be appropriate (e.g., maintenance records in one location, other BMP related
 documentation  in another). A centralized location will help to consolidate materials for later review
 and  consideration.  Without  a designated location, materials  may become dispersed throughout a
 facility and subsequently lost.

        Filing information by subject and date is a practice followed by most facilities.  The most
 effective  filing system usually includes hard copies of the information on a file.  Additionally,
 keeping inventory lists of documents  maintained  in file  folders assists in quick reviews of  file
 contents.  Small facilities may be able to file  all BMP-related information in the same folder in
 chronological order; larger facilities may have to  file information by subject.  For example, PM
 information may be filed by equipment type in separate folders, while good housekeeping information
 and related oversight and evaluation information may be filed based on facility area. In some cases,
 larger facilities may find it convenient to develop  an automated  tracking system (e.g., a database
 system) for efficiently maintaining records.

 Recordkeeping and Reporting - What to Do
        •  Clearly designate review and filing responsibilities for BMP related materials.
        •  Designate a file copy of any BMP correspondence.
        •  Set-up procedures for materials release notification that include those plant personnel to
          be immediately notified, in order of priority, including backups, and then the appropriate
          governmental regulating agencies (Federal, State, and local). Include the fire department,
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          police, public water supply agency, fish and wildlife commission, and municipal sewage
          treatment plant, where appropriate.

       •  Develop a standard form for submitting a report for and the internal review of a release
          or near release.

       •  Share knowledge gained through BMP implementation with others. Report successes of
          BMP plan implementation in the Pollution Prevention Information Clearinghouse (see
          Chapter 4), magazines, or corporate newsletters.


Recordkeeping and Reporting - What Not to Do

       •  Do not keep the details of a materials release a secret known only to the facility
          management.  Share the information learned from incidents so that all employees may
          benefit from the experience.

       •  Do not forget to keep employees informed. Continually provide updates (e.g., quarterly
          memo, newsletter) of BMP committee initiatives and progress. Lack of communication
          with employees may be interpreted as lack of continuing  interest in the BMP plan's
          implementation.


2.3.3  BMP Plan Evaluation and Reevaluation

2.3.3.1 Plan Evaluation

       Planning, development,  and implementation  of the BMP plan require  the  dedication of
important resources by company management. The benefits derived, however, serve to justify the
costs and commitments made to the BMP plan.  To  illustrate the plan's benefits, it may be
appropriate and even necessary in some cases to  measure the plan's effectiveness.


       An evaluation can be performed by considering a number of variables, including:  (1) benefits
to  the employees; (2) benefits to  the  environment; and (3) reduced expenditures. Methods of
measuring these areas are discussed below.


       Benefits to the employees can be assessed in terms of health and safety, productivity,  and
 other factors such as morale.  Comparisons before and after plan implementation can be made to
 determine trends that show BMP plan effectiveness.  The following information can be utilized in
 this determination:
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       •   Time off due to on-the-job injury or illness resulting from exposure to chemicals
       •   Production records which track worker productivity.

       Benefits to the environment can be measured by several factors.  First, pollutant monitoring
prior to the inception of the BMP plan may show significant quantities of pollutants and or wastes
that are minimized or eliminated after plan implementation.  Discharge monitoring report records
may show reductions in the quantity or variability of pollutants in the discharges.  In addition, the
reductions in volumes of and/or hazards posed by solid waste generation and air  emissions may
demonstrate the success of the BMP plan.

       Other derived environmental benefits  may  include reduced releases to the environment
resulting from  spills, volatilization, and  losses  to storm water  runoff.  These benefits may be
measured through reductions  in the number and severity of  releases  and of lessened losses of
materials.

       Reduced expenditures are the bottom line  in substantiating the need for the BMP plan.  Cost
considerations can be easily tracked through expense records  including chemicals usage, energy
usage, water usage,  and employee records. The  development of production records on product per
unit cost before  and after BMP plan  implementation  may  show a significant  drop, thereby
demonstrating the effectiveness of the plan.

2.3.3.2 Plan Revaluation
       The operations at an industrial facility are expected to be dynamic and therefore subject to
periodic change.  As such, the BMP plan can not remain effective without modifications to reflect
facility changes. At a minimum, the BMP plan should be revisited annually to ensure that it fulfills
its stated objectives and  remains  applicable. This time-dated approach allows for the consideration
of new perspectives gained through the implementation of the BMP plan, as well as the reflection
of new directives,  emerging technologies, and other such factors.  However, plan revisions should
not be limited to periodic alterations. In some cases, it may be appropriate to evaluate the plan due
to changed conditions such as the following:
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       •  Restructuring of facility management
       •  Substantial growth
       •  Significant changes in the nature or quantity of pollutants discharged
       •  Process or treatment modifications
       •  New permit requirements
       •  New legislation related to BMPs
       •  Releases to the environment.

       Many changes at a facility may warrant modifications to the BMP plan. Growth may require
more frequent employee training or a redesign of the good housekeeping program to ensure the site
is maintained in a clean and orderly fashion. An evaluation of or modifications to existing process,
treatment, and chemical handling methods may substantiate the need for additional facility-specific
BMPs.

       Where new permit  requirements or legislation focus on a specific pollutant, process, or
industrial technology, it may be appropriate to  consider establishing  additional controls.  These
permit  requirements or legislative  changes do  not  necessarily have to be directly related to
environmental issues. For example, new OSHA standards may result  in modification of the BMP
plan to include procedures that address the protection of worker health and safety.

        If there has been a spill or other unexpected chemical release, the reasons for the release and
corrective actions taken should be investigated. This investigation should include evaluation of all
control programs including good housekeeping, PM, inspections, security, employee training, and
recordkeeping and reporting. Additionally, facility-specific BMPs should be evaluated at that time
to determine their effectiveness.

        Ultimately, the BMP plan reevaluation may pinpoint areas of the facility not addressed by
the plan, or activities  that would benefit from further  development  of facility-specific BMPs or
revision of the general programs contained in the BMP plan. It is useful to bear in mind that as the
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BMP plan improves, costs can continue to be minimized as a result of reduced waste generation, less
hazardous or toxic materials use, and prevented environmental releases.
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CHAPTER 3
             3. INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES


3.1 PURPOSE OF THIS CHAPTER

      Chapter 2 discussed the planning, development, and implementation of a best management

practice (BMP) plan, including the scope of the BMP applicability and the components of an effective

plan.   The intent of this chapter is to illustrate through examples how plan components are

implemented in various industries. Examples of BMPs are provided on an industry-specific basis.

Exhibit  3-1 presents three basic steps to  follow in selecting from among the BMPs provided as

examples.
                      EXHIBIT 3-1,  BMP SELECTION PROCESS

      1»     Review the industry profiles to determine the industrial processes that apply.
            Associated with each process are examples of BMP applications.  These
            examples are based on commonly implemented pollution prevention practices,
            actual case studies, and demonstrations.  While this chapter identifies BMP&
            for a specific industry category, some of the information may also be
            transferable to  other types of industries*

      2.     Evaluate whether the BMP would help to achieve the environmental
            objectives of the industry.  Objectives may include reducing discharges of a
            particular chemical, reducing losses of raw material to the environment,
            reusing/reprocessing a process solution or material, or minimizing employees*
            exposure to pollution.

      3.     Consult the  references of the document from which the example was
            obtained.  Tables  summarizing BMPs refer to the source of the information,
            Generally, the  documents cited were obtained either through the Pollution
            Prevention Information Clearinghouse (PPIC) or the National Technical
            Information  System (NTIS). A supplementary appendix containing a
            bibliography describes sources further.
       This chapter gives the reader specific examples of effective best management and pollution

 prevention practices, as well as instances where facilities  have successfully implemented  such

 practices.  The results, including pollution reductions and cost savings, are highlighted for several
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industries.  Most of the information on effective best management and pollution prevention practices
is provided in table form. Each listing in the table contains the following:

       • The BMP:  The approach taken by the industry to eliminate or reduce a targeted waste.
       • Targeted processes:  The industrial activities that generate a targeted waste or releases the
         waste into the environment.
       • Targeted wastes:  Product(s) or byproduct(s) of industrial activity  that pose a threat to
         human health and/or the environment.  The targeted waste(s) will be described in the most
         specific terms possible (i.e., chemical name, elemental components).
       • Benefits to water:  Qualitative and qualitative descriptions showing reductions in the water
         usage or pollutants sent  to water media.
       • Benefits to other media: Quantitative and qualitative descriptions showing reductions in
         pollutants sent to other media.
       • Incentives:  Other positive results of the BMP such as financial savings and improvements
         in safety.                   v
       • Data sources and page numbers: Citations to the bibliography contained in Appendix D
         that list the document title, the organization that created the document, and the date.

3.2  INDUSTRY CATEGORY SELECTION
       Opportunities for pollution prevention through the implementation of BMPs are available for
a multitude of industries. Since all industries cannot be addressed in this chapter, the scope has been
narrowed to address industries that discharge the greatest quantities of the  17 priority  pollutants
targeted by EPA's Pollution Prevention Strategy of  1991 based on data contained in the Toxics
Release Inventory data  base.  EPA acknowledges that other methods are available for targeting
industries.  However, this method was chosen as the best approach after careful evaluation of the
information that various methods would provide.  EPA believes that this targeting method identifies
opportunities where BMPs may be most  effective in preventing the  greatest quantity of water
pollution by the pollutants of greatest concern.

       Although this  chapter  is limited to BMP identification for nine industry  categories, the
processes identified may be applicable for control of similar processes or pollutants by industries not
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discussed in this manual. Users of this manual are encouraged to examine all industry categories'
information presented in light of other industries possibly having similar processes or pollutants.

3.3 METAL FINISHING
3.3.1 Industry Profile
      The category of metal finishing includes manufacturers that take raw metal stock and subject
it to various treatments to produce a product at, or closer to, its finished stage.  Manufacturers
classified as metal finishers perform similar operations that fall under a variety of standard industrial
classification (SIC) codes, including industries in major groups 34 (fabricated metal products),  35
(machinery, except electrical), 36 (electrical and electronic machinery, equipment, and supplies), 37
(transportation equipment),  38 (measuring, analyzing,  and controlling instruments:  photographic,
medical, and optical goods; watches and clocks), and 39 (miscellaneous manufacturing industries).

        The processes used  to treat raw metal stock and, correspondingly, the wastes produced are
the common link among the metal  finishing category members.  Some of these  processes are
especially amenable to BMPs; that is, implementation of  BMPs is relatively easy and results in a
significant reduction in the discharge of pollutants. Listed below are processes common among metal
finishers and the targeted pollutants that enter wastewater  streams:
       • Electroplating:   Typical  wastes  produced include spent process solutions containing
         copper, nickel, chromium, brass, bronze, zinc, tin, lead, cadmium, iron, aluminum, and
         compounds formed from these metals.
       • Electroless plating:  The most common wastes  produced are spent process solutions
         containing copper and nickel.
       • Coating:   Depending on  the coating material that is being applied,  wastes of concern
         include spent process solutions containing hexavalent chromium, and active organic and
         inorganic solutions.
       • Etching and  chemical milling:   Typical solutions used in etching and milling that
         ultimately  enter the wastestream  and are of concern include  chromic acid and cupric
         chloride.
       • Cleaning: Various  organic and inorganic compounds enter the wastewater stream from
         cleaning operations.
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       The source of the targeted pollutants are process solutions and raw materials that enter the
wastewater stream primarily through rinsing or cleaning processes.  A work piece that is removed
from a process or cleaning solution is typically subjected to rinsing directly afterwards and carrying
excess process contaminants, referred to as dragout, into the rinse tank.  The dragout concentrates
pollutants in the rinse tank, which is typically discharged into the sewer system.

       Another pathway by which targeted pollutants enter the wastewater stream is through the
disposal of spent batch process solutions into the sewer system.  Spent solutions consist of aqueous
wastes and may contain accumulated solids as well. Spent solutions are typically bled at a controlled
rate into the wastewater stream.  Other sources of pollutants in wastewater streams include clean-up
of spills and washdown of fugitive aerosols from spray operations.

3.3.2 Effective BMPs
       Numerous practices have been developed to eliminate or minimize discharges of pollutants
from the metal finishing industry. Successful source reduction measures have been implemented to
eliminate cyanide plating baths,  as well as substitute more toxic solvents with less toxic cleaners.
In many cases, cleaning with solvents has been eliminated altogether through the use of water-based
cleaning supplemented with detergents, heating, and/or agitation.  Other source reduction measures
have been implemented to minimize the discharges of toxic materials. For example, drain boards
and splash plates have been commonly installed to prevent drips and spills.  Additionally, the design
of immersion racks or baskets and the positioning of parts on these racks or baskets have also been
optimized to prevent trapping of solvents, acids/caustics, or plating baths.

       The utilization of recycle and reuse measures have also been commonly used.  Many facilities
have been able to minimize  water  use and conserve rinsewaters and plating baths by measures
including the following:

       •  Utilizing  a dead rinse resulting  in the concentration of plating bath  pollutants.  This
         solution may be reused directly or further purified for reuse.
       •  Conserving waters through countercurrent rinsing techniques.
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       •  Utilizing electrolytic recovery, customized resins, selective membranes, and adsorbents to
         separate  metal  impurities from plating  baths,  acid/caustic dips,  and solvent  cleaning
         operations.

       These operations and measures not only extend the useful life of solutions, but also prevent
or reduce the discharge of pollutants from these operations.

       Two industries highlighted in this section have implemented best management practices that
resulted  in substantial cost savings  and  pollutant reductions.  For example, Emerson Electric
implemented  a program that resulted in savings of more than $700,000 per year and reductions in
solvents, oxygen-demanding pollutants, and metals.  Best  management practices implemented by a
furniture manufacturer in the Netherlands resulted in a reduction in metals discharged from 945 to
37 kilograms per year and a decrease in water use from 330,000 to 20,000 cubic meters per year.
A detailed discussion of these programs is provided  in  the following  paragraphs.  Exhibit 3-2
provides a summary of other examples of demonstrated BMPs.

       Emerson Electric, a manufacturer of power  tools, implemented a Waste and Energy
Management Program to identify opportunities for pollution prevention.  An audit resulted in the
following actions:

       •  Development of an automated electroplating system that reduced process chemical usage
         by  25 percent, process batch dumps by 20 percent, and wastewater treatment cost by 25
         percent.
       •  Installation of a water-based electrostatic immersion painting system to replace a solvent-
         based painting system. The water-based system resulted in a waste solvent reduction of
         more man 95 percent.
       •  Installation  of an ultrafiltration system  that  recovers  65 Ibs per  day of waste oil and
         purifies 2,500 Ibs per day of alkaline  cleaning solution for reuse, which resulted  in a
         reduction of 5-day biochemical oxygen demand loadings to the treatment system of 370 Ibs
         per month.  This avoided the need for installation of additional treatment.
       •  Installation of an alkaline and detergent and steam degreasing system, which  resulted in
         a reduction  in waste  solvents by 80 percent.
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      In addition to the reduction of pollutants, Emerson realized annual costs savings of $642,000
in reduced raw material use, $2,200 in reduced water use, and $52,700 in reduced waste  disposal.
      A furniture manufacturer in the Netherlands reduced metals in its effluent by switching to
cyanide-free baths, allowing for longer drip times, using spray rinsing,  reusing water, and
implementing a closed cooling system.  These best management practices, complemented by the
installation of treatment technology, reduced metals in the effluent from 945  to 37 kilograms per
year.  Water use also decreased from 330,000  to 20,000 cubic meters per year.

3.4 ORGANIC CHEMICALS,  PLASTICS,  AND SYNTHETIC FIBERS (OCPSF)
3.4.1 Industry Profile
      The OCPSF industry manufactures more than 25,000 different organic chemical, plastic, and
synthetic fiber  products.   It includes both those facilities whose primary products are organic
chemicals,  plastics, and synthetic fibers and  the facilities that use or produce these chemicals
ancillary to their primary production.  OCPSF manufacturers have two types  of facilities — those
with chemical synthesis as their  primary function and those that recover organics, plastics, and
synthetic fibers as byproducts of other unrelated manufacturers.

      OCPSF manufacturers include SIC code 2821 (plastic materials, synthetic resins, and non-
vulcanizable elastomers),  SIC code 2822 (cellulosic manmade fibers), SIC 2823 (synthetic organic
fibers except cellulosic),  SIC code 2824 (cyclic crudes and intermediates, dyes, and  organic
pigments), and SIC code 2869 (industrial organic chemicals not elsewhere classified).  All OCPSF
products are derived from the same raw materials (methane, ethane, propene, butane, higher aliphatic
compounds, benzene, toluene, and xylene).   As a result of the variety and complexity of the
processes used  and of products manufactured,  there is an exceptionally wide  variety of pollutants
found in the wastewaters of this industry including conventional pollutants, metals, and miscellaneous
organics resulting from product and byproduct formation.

      Contaminated wastewater  generation occurs  at a number of points, mainly as  direct and
indirect contact processes, equipment cooling, equipment cleaning, air pollution control systems, and
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storm water.  Direct contact during manufacturing or processing is found in the use of aqueous
reaction media.  When water is used as a medium for OCPSF chemical processes, a high-strength
process wastewater is produced. After the primary reaction has been completed and the final product
has been separated from the water media, some residual product and unwanted byproducts remain.
Indirect contact process wastewaters include the recovery of solvents and volatile organics from the
chemical reaction kettle. Vacuum jets utilize streams of water used to create a vacuum which draws
off volatilized solvents and organics from the reaction kettle  into solution.   Later,  recoverable
solvents are typically separated and reused while unwanted volatile organics remain in solution  in
the vacuum water.  This wastewater is discharged as process wastewater. Steam ejector systems are
similar to vacuum jets, but steam is used instead of water.   The steam  is then  drawn off and
condensed, forming a source of process wastewater.  Batch processing may require repeated and
extensive equipment clean-up between batches,  which  is usually  accomplished with water.
Additionally, water scrubbers on emission control devices, and leaks and spills through the plant
which  contaminate  storm water are two  other contributors  of potentially high concentration  of
pollutants to discharges.

3.4.2 Effective BMPs
       Due  to the individuality of many organic  manufacturing operations, pollutant and process-
specific source reduction and recycle/reuse measures may only be useful in relation to one facility.
However, OCPSF manufacturing facilities are similar in that their organic chemicals  comprise their
raw materials and final products, and the generation  and discharge  of significant quantities  of
pollutants result during cleaning processes. Thus, much of the source  reduction and recycle/reuse
measures have focussed on reducing pollutants lost to wastewater during clean-up.

       Dedicated equipment has been purchased by. many batch processors to avoid  the loss  of
valuable materials and to prevent the  generation of wastewater during clean-up activities.
Additionally, many batch processors have provided for the capture of washdown waters for later
recycle/reuse. Alternate cleaning methods such as manual wipe down with squeegees also have been
shown to help recover organics products which would otherwise be lost during equipment clean-up.
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       Many OCPSF facilities have implemented programs that use a variety  of techniques to
minimize pollutant discharges from their plants, save money, and reduce health risks. For example,
a paint manufacturer underwent a  waste assessment to identify opportunities for implementing
pollution prevention practices.   Lab experiments that  were conducted to test the feasibility of
eliminating clean-up steps determined that each 10 percent decrease of waste volume saved $6,000
per year in disposal costs. In response to this finding, the plant rescheduled production to disperse
pigments only before batch formulation, which eliminated the need for intermediate storage, reduced
the need for solvents such as methyl ethyl ketone, and allowed for cleaning with a small amount of
compatible solvent.  A process redesign included the development of a production plan that produces
paint from light to dark batches, eliminating intermediate clean-up steps which generate wastewater.
Ultimately,  savings were realized due to reductions in raw materials use, water use, and waste
disposal.

       Atlantic Industries' Nutley, New Jersey facility reduced water use from 750,000 to 300,000-
400,000 gallons per day and also have lessened discharges of organics and other pollutants.  One
measure that assisted the facility in achieving these reductions involved the simultaneous increase in
process chemical concentration, lowering of reaction temperatures, and adoption of new methods for
combining dye components.  Ultimately,  these and other improvements have reduced the amount of
organics and inorganics in the  wastewater by 50,000 and 250,000 gallons per year, respectively.
Other demonstrated BMPs are summarized in Exhibit 3-3.

3.5 TEXTILE MILLS
3.5.1  Industry Profile
       Textile mills are manufacturing facilities  that transform  fiber into  yarn, fabric, or other
finished textile products.  Those mills that fall under SIC major group 23 (apparel and other textile
mill products) use dry processes that normally do not result in wastewater discharges.  Some of the
mills that fall under SIC major  group 22 (textile mill products), however,  use wet processing.
Characteristics of the major wet manufacturing processes and pollutants in the wastewater discharges
that may be targeted for BMPs are listed below:
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         Raw wool scouring is the first treatment performed on wool, in which the wool is washed
         to remove the impurities peculiar to wool fibers. These impurities are present in great
         quantities,  and include grease, sweat, dirt, feces, vegetable matter, disinfectants,  and
         insecticides.  It has been estimated that for every pound of fibers obtained, ll/2 pounds of
         waste impurities are produced, mostly dirt, grit, and grease.

         Scouring is employed to remove natural and acquired impurities from fibers and fabric.
         The nature of the scouring operation is highly dependent on the fiber type.  For example,
         cotton fabric is sometimes loaded into  a pressure vessel containing a solution of sodium
         hydroxide, soap, and sodium silicate, after which it is completely rinsed to clean the fibers
         and remove residual alkali.  Synthetics, on the other hand, require only light scouring.

         Carbonizing removes burrs and other vegetable matter from loose wool or woven wool
         goods to prevent unequal absorption of dyes.  The  overall  water requirements for the
         carbonization of wool may be substantial.  For example, wool is carbonized using sulfuric
         acid,  then  rinsed  to remove the  acid.   The wool is then neutralized using  a sodium
         carbonate solution. A final rinse  removes the alkalinity.

         Fulling gives woven woolen cloth a thick, compact,  and substantial feel, finish,  and
         appearance.  To accomplish this, the cloth is mechanically worked in fulling machines in
         the presence of heat, moisture, and sometimes pressure.  This allows the fibers to felt
         together, which causes shrinkage, increases the weight, and obscures the threads  of the
         cloth.  Fulling is  performed by, either alkali or acid methods.  Fulling is followed by
         extensive washing to remove process chemicals and prevent rancidity and wool spoilage.
       • Desizing removes the sizing compounds applied to the yarns and is usually the first wet
         finishing operation performed on woven fabric.  It consists  of soaking the fabric in a
         solution of mineral acid or enzymes and thoroughly washing the fabric.

       • Mercerizing increases the tensile strength, luster, sheen, dye affinity,  and abrasion
         resistance of cotton goods.  It is accomplished by impregnating fabric with cold sodium
         hydroxide solution, an alkali solution that causes swelling of cotton fibers.  In many mills,
         the sodium hydroxide is reclaimed in caustic recovery units and concentrated for reuse.

       • Bleaching is a finishing process used to whiten cotton, wool,  and synthetic fibers.  In
         addition, bleaching dissolves sizing, natural pectins and waxes, and small particles of
         foreign matter.   It is primarily accomplished with hydrogen  peroxide,  although
         hypochlorite, peracetic acid, chlorine dioxide, sodium perforate, or reducing agents may
         be used.

       • Dyeing and printing are the most complex of the wet processing operations in textile mills.
         Many mechanisms and many types of dyes are used in coloring  textile fibers.  Acid dyes
         are sodium salts, usually of sulfonic acids or carboxylic acids.  Azoic dyes, are insoluble
         pigments anchored within the fiber by padding with a soluble coupling compound, usually
         naphthol. In addition, common salt and surface active compounds are usually necessary
         to speed the reaction.  Basic dyes are usually hydrochlorides of salts or organic bases and
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         are most effective with acrylic fibers.  Direct dyes resemble acid dyes in that they are
         sodium salts of sulfonic acids and are almost invariably azo compounds.  Disperse dyes
         use several carriers such as acetic acid to color cellulose acetate.  Mordant dyes have no
         natural affinity for textile fibers, but dye well when applied to cellulosic or protein fibers
         that have been mordanted with a metallic oxide such as chromium.  Reactive dyes include
         many methods and chemicals such as sodium chloride, urea,  sodium carbonate, sodium
         hydroxide, and tri-sodium phosphate. Sulfur dyes are complex organic compounds that
         are insoluble in water but dissolve  in a solution of sodium sulfide to  which sodium
         carbonate has been added. Vat dyes, among the oldest natural coloring matters used, are
         insoluble in water, but become soluble when treated with reducing agents and used with
         chemicals such as sodium hydroxide.  Final washing of the fabric to  remove excess dyes
         and print paste, along with the cleanup of mixing tanks, applicator equipment, and belts,
         contributes wastewater associated with the dyeing and printing processes.  This cleaning
         process often involves the use of solvents.
       In the production of textile products, pollutants generally enter the wastestream during rinsing
or cleaning operations.  These pollutants may include acids  and alkalis such as those used in
scouring,  carbonizing,  fulling, and mercerizing processes.  Solvents used for cleanup are
predominant at times. Zinc may present a wastewater problem in yarn spinning and manufacturing.

3.5.2  Effective BMPs
       BMPs have  been  successfully applied in the textile industry and range from  wastewater
recycling  and reuse and  chemical  substitution to process modification  and computerization of
controls.  American Enka, a yarn and thread mill, and United Piece  Dye Works, a textile dye and
finishing company, have achieved substantial cost savings, reduced pollutant levels in the wastewater
effluent, and met permit  effluent limits by the successful implementation of best management and
pollution prevention practices. A discussion of their successes  is presented below. A summary of
other proven BMPs in the textile industry is provided in Exhibit 3-4.

       For its rayon yarn manufacturing process, American Enka redesigned and implemented a
precipitation system to remove and recycle zinc. The redesigned precipitation system involves a two-
stage process where, in the second stage, zinc precipitates onto  an existing slurry of zinc hydroxide
crystals.  Sulfuric acid is then used to convert the zinc hydroxide to zinc sulfate.  Zinc sulfate is
recycled back to the yarn spinning bath. This two-stage process-has  achieved an estimated savings
of $383,000 per year, and removes zinc from the wastewater and solid wastestreams.
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      United Piece Dye Works was able to meet its effluent limits for phosphorus by materials
substitution in the production process, without any capital expenditure. A detailed evaluation of the
production processes,  process  chemistry,  and the chemicals used identified the  sources of
phosphorus.  Process modifications to reduce the use of phosphate chemicals, such as
hexametaphosphate, and substitution of chemicals not containing phosphate were made.  The use of
phosphoric acid was eliminated.  The  level of phosphorus in the wastewater effluent was reduced
from 7.7 to less than 1 mg/1 through this pollution prevention practice of source reduction.

3.6 PULP AND PAPER PRODUCTS
3.6.1  Industry Profile
      Paper and allied products (SIC major group 26) includes manufacturers of pulp, paper and
paperboard, and paper  products.  The six  primary  subcategories include pulp mills  (SIC group
number 261), which manufacture pulp from wood (hardwoods or softwoods) or from other materials
such as rags,  linters,  waste  paper,  and  straw; paper mills (SIC group  number 262), which
manufacture paper and paper  products; paperboard mills (SIC group number 263), which
manufacture paperboard and paperboard-related products; companies covered under SIC group
number 264, which produce converted paper and paperboard products, such as envelopes, non-textile
bags, die-cut paper, pressed and molded pulp goods, sanitary paper products, stationary and tablets;
manufacturers of paperboard containers and boxes (SIC group number 265), which produce folding
paperboard boxes, corrugated and solid fiber boxes, sanitary food containers, fiber cans, tubes,
drums  and similar products; and companies covered by SIC group number 266, which includes
manufacturers of building paper  and board from wood pulp and other fibrous materials.

       The production of pulp, paper, and paperboard involves four major processes: raw material
preparation, pulping and recovery, bleaching, and papermaldng.  A discussion of each  process and
its associated wastes is provided below.
       •  Raw material preparation includes log washing, bark removal, and chipping and screening
         processes.  These processes can require large volumes of water, but the use of dry bark
         removal techniques or the recycle of washwater or water used in wet barking operations
         reduces water consumption.
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       •  Pulping and recovery reduces raw material into pulp suitable for further processing. Pulp
         production results in relatively large quantities of wastewater and wastewater pollutants.
         The wood entering the pulping process consists of cellulose fibers, lignin, semi-cellulose,
         and other compounds. Lignin, a complex polymer that binds and strengthens wood fibers,
         is believed to contain dioxin precursors.  Pulping processes vary from basic mechanical
         action, such as groundwood pulping, to complex chemical digesting sequences, such as in
         the alkaline (soda or kraft), sulfite, or semi-chemical  processes.

         Mechanical pulping does not involve use of chemicals; little or none of the wood material
         is dissolved.  Thus, softwoods, which are easier to tear and grind, are typically used in
         this pulping process.  The resultant pulps are generally used in manufacturing newsprint,
         catalogues, and toweling.

         Chemical pulping removes lignin to enhance fiber flexibility, resulting in a stronger paper
         product but lower fiber yields (40  to 50 percent).  .Sulfite pulp may be blended with
         mechanical pulps as a strengthener and is commonly used in production of viscose rayon,
         acetate fibers and films, plastic fillers, and cellophanes.   Semi-chemical pulping is often
         used  for newsprint, containers, and computer cards.  Kraft pulping accounts for
         approximately 75 percent of the pulp produced for paper and paperboard due to the
         number of wood types that can be processed.  Also, extracts released during the process
         such as turpentine, tall  oil, and resin can be sold separately as commodity chemicals.
         Pulping process wastes  include pulp rejects, cellulosic fines, white water, and chemical
         recovery wastes.

       •  Bleaching results in the  removal of color caused by lignins and resins, or by spent cooking
         liquor from the pulp left by inefficient washing.  Therefore, multi-stage  bleaching
         processes are performed to produce light colored  or  white products.   Conventional
         bleaching involves five stages wherein chlorine is used as the dominant chemical in a series
         of alternating  acid  and alkaline bleaching  and washing phases.   Dioxins, furans,
         hexachlorobenzene, and hundreds of organochlorine byproducts (acidic, phenolic,  and
         neutral compounds) result from the bleaching process.

       •  Papermaking  follows pulp preparation  processes and encompasses further mixing  and
         blending with non-cellulosic materials  occur to create the furnish for paper making.
         Further preparation steps may include dyeing, sizing, and starching to  increase water
         resistance.  The furnish  involves a dilute water suspension of pulp, from which a layer of
         fiber is deposited on a fine screen.  Finally, this layer is  removed, pressed, dried, and, if
         desired, coated to form final products.  Chemicals used may include titanium, zinc sulfate,
         lithophone  pigments,  waxes, starches,  sodium silicate, glues, resins, rubber  latex,  and
         hydrocarbons.  Coating operations typically involve  use of chemicals such as polyvinyl
         chloride, polypropylene, saran lacquer, rubber, acrylic latex, styrene-butadiene latex,
         polyvinyl acetate, polyvinyl alcohol, and carboxymethyl cellulose.
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3.6.2 Effective BMPs
      Due to their toxicity and persistence in the environment, chlorinated organics such as dioxins
and furans produced by the paper industry  are often targeted  for pollution prevention.  Common
practices have included:

       • Discontinuing the use of pitch dispersants and defoamers which may contain chlorinated
         dioxin and chlorinated furan precursor compounds
       • Maximizing delignification in the pulping process
       • Maximizing brownstock pulp-washing efficiency
       • Optimizing bleaching processes through process control monitoring and automation which
         introduces limited amounts of bleach at specific times
       • Utilizing chlorine dioxide or hydrogen peroxide as alternatives to bleach, or in some cases
         eliminating bleaching altogether.

       Although much of the focus has been on source reduction measures targeted at dioxin and
dioxin precursor formation, recycle and reuse opportunities are also being utilized. More and more
facilities are finding the benefits of recapturing pulp by in-process and final discharge treatment
techniques.  Facilities are also finding it more economical to utilize dirty water and treatment plant
effluent for washing and other miscellaneous processes.  In some cases, closed-loop systems  can be
achieved. Wood slivers and chips screened  out  during raw material preparation processes  can be
dewatered  in a press  and burned in  a  bark boiler. This process eliminates  solid waste while
generating power.

       Source reduction and recycle methods used by the pulp and paper manufacturing industry have
resulted in lessened wastewater and pollutant discharges, which in turn minimizes costs  associated
with treatment and water usage. Two specific examples of how industry implemented BMPs in the
pulp  and paper industry  are highlighted below.  Exhibit 3-5 summarizes BMPs that have been
successfully demonstrated in the U.S. and abroad.

       One paper mill in England modified the bleaching stage of pulp manufacturing to reduce water
usage and reduce the coloration of wastes.  This was accomplished by preceding the chlorine,  caustic
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soda, and chlorine dioxide bleaching with oxygen bleaching, which reduced the quantities of reagents
and water used in the conventional bleaching process.  Rinsewater from the oxygen bleaching can
be used to wash cooked pulp, thus reducing the coloration of wastes. The mill reduced water usage
by 50 cubic meters per ton of manufactured pulp.  Use of caustic soda, chlorine and, chlorine
dioxide was also reduced.

       A closed-cycle, effluent-free bleached kraft mill in Canada reduced the amount of fresh water
needed in the system by 50 percent. Technology innovations include modifications to the bleaching
sequence; countercurrent washing to reduce the amount of fresh water needed; reuse of all bleach-
plant effluents in the pulp mill; removal of sodium chloride from the white liquor; use of an effluent-
free process for generating chlorine dioxide; and installation of spill tanks and other minor changes
to facilitate  collection and reuse of water throughout the system. The estimated cost to  install the
system would be $4.5 million (in 1975 dollars) for a 725-ton-per-day mill, where annual savings
were reported to be $2.2 million.

3.7  PESTICIDES
3.7.1  Industry Profile
       The formulation of pesticides and  agricultural chemicals falls into SIC code 2879, and
includes companies that formulate and prepare agricultural pest control chemicals or pesticides.  In
pesticide formulation, highly  concentrated organics manufactured  elsewhere are  converted into
pesticide products such as insecticides, herbicides, and fungicides that are ready for use by farmers
and gardeners.
       There are three types of pesticide formulations: solvent-based, water-based, and solid-based.
Solvent-based formulations use a solvent or a solvent-water emulsion as the carrier solution for the
active pesticide ingredient.  Typical solvents are light aromatics such as xylene, chlorinated organics
such as 1,1,1-trichloroethane, and mineral spirits. With water-based formulations, water serves as
the carrier for the active pesticide ingredient.  Both solvent- and water-based formulations are applied
directly in liquid form or propelled as an aerosol. Solid-based pesticide formulations are prepared
by blending solid active ingredients with inert solids such as clay or sand. Some dry formulations
are prepared by absorbing liquid active ingredients into solid carrier materials. Examples of common
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solid-based formulations are dusts, wettable powders, granules, treated seed, and bait pellets and
cubes.

       Pesticide formulating facilities generate wastes during such operations as cleaning of mixing
and storage equipment, housekeeping, and laboratory testing for quality assurance.  Commonly
generated wastewaters include those from equipment clean-up gathered as a result of raw materials
left over in containers; pesticide dust and scrubber water from air pollution control equipment; off-
specification products; laboratory wastes; spills; waste sands or clays;  laundry wastewater; and
contaminated storm water runoff.

       The significant pollutant parameters in the pesticide industry  include organic  pollutants,
suspended solids, pH, nutrients, the pesticides specific to the product manufactured, metals, phenol,
and cyanide.   The active  ingredients in insecticides include inorganic compounds, organic
compounds, chlorinated hydrocarbons, carbamates, and  organophosphates.  Herbicide formulations
include phenoxy, metal organic compounds, triazine, urea, amide, benzoic,  and other organic and
inorganic compounds.  Fungicides utilize organic and inorganic compounds.

3.7.2  Effective BMPs
       Many of the circumstances surrounding the individuality of OCPSF manufactured products
is shared by pesticide  formulators.   As such, much of the focus of pesticides formulation source
reduction and recycle/reuse measures have been on pollutants released to water during equipment
clean-up. Some of the commonly used practices have included:

       •. Use of dedicated  equipment for batch processing to avoid losses of raw materials and
          products, thereby preventing the generation of wastewater during clean-up activities
       •  Capturing of washdown waters in tanks for later reuse
       •  Adoption of cleaning methods such as squeegee  wipe down which helps recover pesticide
          products which would otherwise be lost during equipment washdown.
       Other  effective source reduction measures have also  been practiced in  the pesticides
 formulation industry including the use of dry air pollution control devices and more controlled,
 efficient batch sequencing.
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       Dow Chemical reduced chlorinated hydrocarbons in the wastewater effluent by 98 percent and

hydrocarbon emissions by 92 percent.   They also reduced the  volume of packaging wastes by

implementing practices such as material substitution, equipment modification, process modification,

housekeeping improvements, and periodic assessments of employee performance.  Some of the

measures implemented by Dow include the following:


       • Packaging the pesticide Dursban in 4-ounce water-soluble packages instead of the 2-pound
         metal cans previously  used.  This reduces  packing waste volume, and eliminates the
         disposal problem associated with the empty metal cans.

       • Shipping the active pesticide ingredient in tank cars instead of 55-gallon drums.  This
         reduces packing wastes and allows tank cars to be rinsed using a solvent present in the
         ingredient's formulation.

       • Adding the drying agent utilizing computers and instream analyzers instead of manual feed
         and lab analysis.  This  reduces the wastewater discharged by 37 percent, the chlorinated
         hydrocarbon in wastewater by 98 percent, and  the hydrocarbon emissions to air by 92
         percent.

       • Implementing other waste minimization measures such as process changes, recycling and
         reuse programs,  and  statistical analyses performed  on data representing employee
         performance to pinpoint problem areas and minimize waste.

       Other examples of demonstrated BMPs in the pesticides industry are provided in Exhibit 3-6.


3.8 PHARMACEUTICALS

3.8.1  Industry Profile

       The pharmaceutical manufacturing  industry encompasses the manufacture, extraction,

processing, purification, and packaging of chemical materials to be used as medication for humans

and animals.   Industry  products include  natural  substances extracted  from plants and animals,

chemically modified natural substances, synthetic organic chemicals, metal-organics, and inorganic

materials.
      The pharmaceutical industry's SIC codes include 2833 (medicinal chemicals and botanical

products), 2834 (pharmaceutical preparations), 2841 (soaps and  other detergents, except specialty

cleaners), and 2844 (perfumes cosmetics and other toilet preparations).  Pharmaceuticals may be

manufactured  by  batch,  continuous, and semi-continuous manufacturing  operations, but batch
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production is the most common  of these manufacturing techniques.   Fermentation, extraction,
chemical synthesis, and mixing/compounding/formulating are the processes used in these operations.
The pollutants resulting from the manufacturing "of Pharmaceuticals are described below:
       •  Fermentation:  Solvents such as methylene chloride, benzene, chloroform, acetone, ethyl
         acetate, and methanol are most often used in this process.  Copper and zinc also are used
         in fermentation recovery processes. Chemical disinfectants such as compounds containing
         phenols are used for equipment sterilization.
       •  Biological  and natural extraction:  Most waste from this subcategory  is solid waste.
         Detergents  and disinfectants are also normally found in wastewater, as are solvents such
         as phenol, benzene, chloroform, 1,2-dichloroethane, acetone, and 1,4-dioxane. Ammonia
         is used to control pH.
       •  Chemical synthesis:  Benzene and toluene  are found in the majority  of the process
         wastestream.  Other solvents used include xylene, cyclohexane, pyridine, chloroform, and
         methylene chloride. Chemical synthesis also generates acids, bases, cyanides, metals, and
         other pollutants.                 •
       •  Mixing/compounding/formulating: Various wastes are generated by these operations and
         include those pollutants found in the previous operations.
      The wastestreams generated during these various processes result from cleaning and sterilizing
equipment,  chemical spills,  rejected products, and the processes  themselves.   The primary
wastewater source is equipment waterwash.   Another source is small amounts of non-recyclable
waste dust that may be generated during mixing or tableting  operations.

3.8.2 Effective BMPs
      The pharmaceutical point source category is characterized by a low ratio of finished products
to raw materials, especially among drugs produced by fermentation and natural extraction.  Disposal
and management of the large volumes of raw material waste present both a logistical and a financial
burden. Therefore, BMPs that minimize waste generation are important in reducing the release of
pollutants  into water, air, and soil.  By implementing BMPs, many pharmaceutical companies have
taken advantage of the dual benefits of reduced waste generation and more cost efficient operations.
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      As with the OCPSF manufacturing and pesticide formulation industries, pharmaceutical
manufacturing is characterized by significant quantities of pollutants and wastewater resulting from
equipment clean-up. Many of the source reduction and recycle/reuse discussed in Sections 3.4.2 and
3.7,2 are also applicable to these facilities.  Two successfully implemented BMPs are described
below; others are presented in Exhibit 3-7.

      A pharmaceutical factory producing sophisticated biochemicals, bulk pharmaceutical
compounds, and immunochemicals by batch production has considered waste minimization and
management a high priority.  This plant has enjoyed the benefits of carefully planned BMPs that have
improved wastewater discharges and, working conditions and have saved money.  BMPs successfully
established at this plant include the following:

      •  Wherever possible, the plant recovers and recycles used solvents.  This process saves $292
         per batch.
      •  Butyl acetate vapors are recovered through the dedication of a separate source of vacuum
         for drying product crystals. Savings from this recovery amount to $26 per batch.

      The Merck Rahway, New Jersey, facility has implemented measures which have resulted in
the recovery of 229,600 pounds of acetone per year which would normally  be discharged. Outside
of savings which can be attributed to lessened raw material expenditures, this reuse practice resulted
in a reduction in sewer fees of $47,750 per year.
3.9  PRIMARY METALS
3.9.1 Industry Profile
      SIC major group 33, primary metal industries, includes facilities involved in smelting and
refining of metals from ore,  pig,  or  scrap; rolling,  drawing, extruding, and  alloying metals;
manufacturing castings, nails,  spikes, insulated wire, and cable; and production of coke.   Major
subcategories include blast furnaces, steel works, rolling and  finishing mills (SIC  group number
331); iron and steel foundries (SIC group number 332); primary and secondary smelters and refiners
of nonferrous metals  such as copper, lead, zinc, aluminum, tin, and nickel (SIC group numbers 333
and 334); establishments engaged in rolling, drawing, and extruding nonferrous metals (SIC group
number 335); and facilities involved in nonferrous castings (SIC group number 336) and related
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fabricating operations. The main processes common to metal forming operations and the wastes that

are typically generated are discussed below:


       • Sintering:  This process agglomerates iron bearing materials (generally fines) with iron
         ore, limestone, and finely divided fuel such as coke breeze.  The fine particles consist of
         mill scale from hot rolling operations and dust generated from basic oxygen furnaces, open
         hearth furnaces, electric arc furnaces, and blast furnaces.  These raw materials are placed
         on a traveling grate of a sinter machine.  The surface of the raw materials is ignited by a
         gas and burned. As the bed burns^ carbon dioxide, cyanides, sulfur compounds, chlorides,
         fluorides, and oil and grease are released as gas. Sinter may be cooled by air or a water
         spray  at the discharge end  of the  machine, where it is then crushed, screened, and
         collected for feeding into blast furnaces. Wastewater results from sinter cooling operations
         and  air scrubbing devices which utilize water.

       • Iron making: Molten iron is produced for steel making in blast furnaces using coke, iron
         ore, and  limestone.  Blast furnace  operations use water for noncontact cooling of the
         furnace, stoves, and ancillary facilities and to clean  and cool the furnace top  gases.  Other
         water,  such as floor  drains  and  drip legs, contribute a lesser portion of the process
         wastewaters.

       • Steel making:  Steel is an iron alloy containing less  than 1 percent carbon. Raw materials
         needed to produce steel include hot metal, pig iron, steel scrap, limestone,  burned lime,
         dolomite fluorspar, and iron ores.  In steel making operations, the furnace charge is melted
         and  refined by oxidizing  certain constituents, particularly carbon in  the molten bath, to
         specified  levels.  Processes include the open hearth furnace, the electric hearth furnace,
         the electric arc furnace, and the basic oxygen furnace, all of which generate fumes, smoke,
         and  waste gases. Wastewaters are generated when semi-wet or wet gas collection systems
         are  used  to cleanse the furnace off gases.   Particulates and  toxic metals  in the gases
         constitute the main source of pollutants in process wastewaters.

       • Casting operations: This subcategory includes both ingot casting and continuous casting
         processes. Casting refers to the procedure of molten metal into a specified shape. Molten
         metal is distributed into an oscillating, water-cooled  mold, where solidification takes place.
         As the metal  solidifies into  the mold, the cast product is typically cooled  using water,
         which is subsequently discharged.

       • Forming operations:  Forming is achieved by passing metal through cylindrical rollers
         which apply .pressure  and reduce the thickness of  the metal.  Rolling reduces ingots to
         slabs or blooms.  Secondary operations reduce slabs or blooms to billets, plates, shapes,
         strips, and other forms. Cooling and lubricating compounds are used to protect the rolls,
         prevent adhesion, and aid in maintaining the desired temperature.  Hot rolling generates
         wastewaters laden with toxic organic compounds,  suspended solids,  metals, and oil and
         grease. Cold rolling operations, occurring at temperatures below the recrystallization point
         of the metal, require more lubrication.  The lubricants used  in cold rolling  include more
         concentrated oil-water mixtures, mineral  oil, kerosene-based lubricants (neat oils),  or
         graphite-based lubricants,  which are typically recycled to  reduce oil use  and pollutant
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         discharges.  Subsequent operations may include drawing or extrusion to manufacture tube,
         wire, or die casting operations.  In these operations,  similar pollutants  are discharged.
         Contaminated wet scrubber wastewaters may also be generated from extrusion processes
         but to a lesser degree than in iron and steel making and sintering operations.

       • Acid pickling:  Steel products are immersed in heated acid solutions to  remove surface
         scale during pickling operations.  This generates wastewater from three sources: (1)
         rinsewater used to clean the product after immersion in pickling solution; (2) spent pickling
         solution or liquor; and (3) wastewater from wet fume scrubbers. The first source accounts
         for the largest volume of wastewater but the second source is very acidic and contains high
         concentrations of iron and heavy metals.

       • Alkaline cleaning: This process is used when vegetable, mineral, and animal fats and oils
         must be removed from the metal surface  prior to further processing.  Large-scale
         production or situations where a cleaner product is required may use electrolytic cleaning.
         The alkaline  cleaning bath typically contains a solution  of water, carbonates,  alkaline
         silicates, phosphates, and  sometimes wetting agents to aid cleaning.  Alkaline cleaning
         results in the discharge of wastewaters from the cleaning  solution tank,  and subsequent
         rinsing steps. Potential contaminants include dissolved metals, solids, and oils.
3.9.2 Effective BMPs

      Primary metals manufacturing operations have experienced source reduction and recycle/reuse

benefits similar to those available to metal finishing operations including conserving waters through
countercurrent rinsing  techniques, and utilizing electrolytic recovery, customized resins, selective
membranes, and  adsorbents to separate metal impurities from acid/caustic dips and rinsewaters to

thereby allow for recycle and reuse.


      Some very unique opportunities are also exclusively available to the primary metals industry.
For example, the use of dry air control devices and dry cast  quench operations have been adopted

at some facilities  to avoid the generation of contaminated wastewater.  Additionally, many facilities
are finding markets for byproducts (e.g., sulfides resulting from nonferrous smelting operations can

be converted to  sulfuric acid and subsequently sold) which avoids the need to discharge these

contaminants.


       California Steel Industries, Inc., located in Fontana, California reclaimed wastes to increase

profits and address water use issues.  The facility,  a steel mill, is situated in an area that does not

have a ready supply of process water.  Also, the offsite recycling facility used to dispose of spent
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process pickle liquor was soon to become unavailable.  As a result of these concerns, the company
constructed an onsite recycling facility designed to recover ferrous chloride for resale and to reuse
water and hydrogen chloride for use in steel processing operations. Environmental benefits include
the recovery and resale  of 20 to 25  tons per day  of  ferrous chloride, 3,550  gallons per day of
hydrogen chloride, and  13,000 gallons  per  day of water.   In addition,  corporate liability was
minimized because spent liquor was no longer sent to a disposal facility.

       Exhibit 3-8 provides a summary of other effective BMPs for the primary metals industry.

3.10  PETROLEUM REFINING
3.10.1  Industry Profile
       The petroleum refining industry uses chemical reactions and physical separation processes to
create gasoline, residual fuel oil, jet fuel, heating oils and gases, petrochemicals, and a wide variety
of other products from crude petroleum.  Businesses classified as petroleum refining facilities are
represented by SIC group number 2911.

       A petroleum refinery is  a complex cpmbination  of interdependent operations engaged in
separating  crude molecular constituents, molecular cracking,  molecular  rebuilding,  and solvent
blending and finishing to produce petroleum-derived products.  More than 150 separate processes
have been identified for the  refining of crude petroleum and its products. Each unit of operation may
be associated with  quite different water  usages.  The  types and quantities of contact wastewater
produced are directly related to the nature of the various processes.  Some major petroleum refining
processes and associated wastewater pollutants are described below.

       • Crude oil and product storage: Crude oil, intermediate, and finished products are stored
         in tanks of varying sizes to provide adequate supplies for various refining processes.
         Operating schedules usually permit sufficient detention  time  for settling of water and
         suspended solids.  Pollutants are mainly in the form of emulsified oil and suspended solids.
         Wastes are also a result of spills, leaks, and tank cleaning.
       • Ballast water storage:  Tankers which  are used to  ship  intermediate and final products
         generally discharge ballast.  Ballast waters are contaminated with product materials that
         are the crude feedstock in use at the refinery, ranging from water  soluble alcohol to
         residual fuels, and brackish water.
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       •  Crude desalting: Salts are separated from oil using emulsifiers and settling tanks.  The
         wastewater stream from a desalter contains emulsified oil, ammonia, phenol, sulfides,
         suspended solids, and chlorides.   Thermal  pollution is  also  a problem  in that the
         wastewater often exceeds 95° Celsius.

       •  Crude oil fractionation:  Fractionation  serves as the basic refining process for the
         separation of crude petroleum into intermediate fractions of specified boiling point ranges.
         Wastes include sour water drawn off from overhead accumulators prior to recirculation,
         which contains sulfides, ammonia, oil, chlorides, mercaptans, and phenols.  Discharge
         from oil sampling lines also may contribute pollutants to wastewaters.

       •  Catalytic cracking:  Catalytic cracking breaks heavy fractions such as oils into  lower
         molecular weight fractions.  This process produces large volumes of high-octane gasoline
         stocks, furnace oils, and other middle molecular weight distillates.  Pollutants generally
         come from steam strippers and overhead accumulators on fractioners.  Major pollutants
         resulting from catalytic cracking are oil, phenols, sulfides, cyanides, ammonia, and carbon
         monoxide.

       •  Solvent refining:   Solvents are used to extract  contaminants from stock.  The  major
         pollutants from solvent refining are the solvents themselves.  Under ideal conditions the
         solvents are continually recirculating with  no  losses to the  sewer.  Unfortunately, some
         solvent is always lost through pump seals, flange leaks,  and elsewhere.   Solvents are
         mostly lost from the  bottom of fractionation towers  and  include phenol, glycol,  and
         amines.
3.10.2  Effective BMPs

       The petroleum refining industry is unique in that its raw materials, wastes, and products are

the same. Thus, source reduction measures such as materials substitution for crude oil  are not

realistic. Some facilities have, however, begun only accepting crude oil which meets certain quality
specifications. Other facilities have implemented source reduction measures involving the use of less

toxic catalysts and additives.


       Recycle and reuse opportunities for the petroleum refining operations  are  plentiful.  Tank

bottoms, slop oil, dissolved air flotation float, and American Petroleum Institute  separator sludge are
commonly recycled to the crude unit and, in some cases, the coker for further  onsite processing  to
recover hydrocarbons. Many other by-products also can be recovered and  reused onsite. For

example, recovered acids and caustics can be used for wastewater neutralization. Other recovered

materials (i.e., spent catalyst)  are often shipped offsite for reuse in the paper industry or for further
 3-22
                  NPDES Best Management Practices Manual

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INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
CHAPTER 3
 reclamation of precious metals such as vanadium. The proven use of BMPs by one industry is
 highlighted below.  Exhibit 3-9 provides a summary of other effective BMPs.

       A large petroleum refining operation installed a Stretford Chemical Recovery Process (SCRP)
 unit to recover active sulfurs in wastewaters.  By recovering these sulfurs, the frequency of solution
 dumping decreased from every 2 l/i months to once per year, with a reduced disposal volume of
 225,000 to 25,000 gallons per year.  Thus, releases of sulfur to the wastewater and the need for
 dumping and offsite disposal  of sulfur were also reduced.  This helped minimize risks of soil
 contamination at disposal sites.  Ultimately, the savings including $60,000 per year in disposal costs
 and $120,000 per year in raw  materials resulted.

 3.11  INORGANIC CHEMICALS
 3.11.1  Industry Profile
       The inorganic chemicals industry is very large and diversified. Thirty-five major categories
 of inorganic chemicals known to generate polluted wastewater are listed in Exhibited 3-10.   The
 major industries included manufacturers of alkalies and chlorine (SIC group number 2812), industrial
 gases (SIC group number 2813), inorganic  pigments  (SIC group number 2816), and  industrial
 inorganic chemicals not elsewhere classified (SIC group number 2819).
       Inorganic chemicals are manufactured for captive  or merchant use in four or more  steps
moving from raw material to  final product.   Two or more different  products may use the same
process, but the raw materials used, process sequence, control, recycle potential, handling, and
quality control varies among products, as .does the quality of wastes.

       Plant process wastewaters from the inorganic chemicals industry often contain toxic metals
such as mercury, zinc, chromium, lead, arsenic, cadmium, nickel, silver, copper, and cyanide. Very
few organic toxic pollutants are found in process wastestreams, and those found tend to be present
in low-level concentrations.  All of the processes tend to have discharges of acids such as sulfuric,
hydrofluoric and hydrochloric.  Other substances often present in the wastewater are salts, asbestos,
total residual chlorine, and iron.
NPDES Best Management Practices Manual
        3-23

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CHAPTER 3
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
                EXHIBIT 3-10. TYPES OF INORGANIC CHEMICALS
      Chlor-Alkali
      Hydrofluoric Acid
      Titanium Dioxide
      Aluminum Fluoride
      Chrome Pigments
      Hydrogen Cyanide
      Sodium Dichromate
      Copper Sulfate
      Nickel Sulfate
      Sodium Bisulfite
      Sodium Thiosulfate
      Sulfur Dioxide
  Hydrochloric Acid
  Nitric Acid
  Sodium Carbonate
  Sodium Metal
  Sodium Silicate
  Sulfuric Acid
  Carbon Dioxide
  Carbon Monoxide
  Silver Nitrate
  Ammonium Chloride
  Sodium Hydrosulfite
  Hydrogen Peroxide
Boric Acid
,."•-    -"     T-T
Calcium Carbonate
Cuprous Oxide
Manganese Sulfate
Strong Nitric Acid
 _s;oi^x_ i_i,-  -,  -.
Oxygen and Nitrogen
Potassium Iodide
Sodium Hydrosulfide
jfodium
SiHcpfluoride
 ~£^f£' " f ^ - "* ", : * -
Ammonium Hydroxide
Barium Carbonate
3.11.2 Effective BMPs

      BMPs directed at reducing wastewater consumption have greatly reduced costs in the
inorganic chemical manufacturing industry.  While treatment technologies have been most often used
to reduce the levels of toxic metals and other pollutants in  the wastewater, source reduction and
recovery/reuse practices have also been employed.

      Many of the most effective  pollution prevention mechanisms in the inorganic chemicals
manufacturing industry have employed the reclamation of byproducts, which had previously been
considered wastes, and the development of saleable products.  Additionally, as with the OCPSF
manufacturing industry, the inorganics manufacturing industry has found success in substituting less
toxic catalysts and in exhibiting better reaction controls, thus  minimizing or eliminating excess toxic
and hazardous wastes.

      One industry's success  in implementing BMP programs is discussed below.  Other effective
BMPs hi the inorganic chemicals industry are summarized in Exhibit 3-11.
 3-24
                 NPDES Best Management Practices Manual

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INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
CHAPTER 3
      A European manufacturer of industrial inorganic chemicals instituted recycling for desalination
water produced during the production of hydrazine.  This resulted in a reduction in wastewater
effluent generation by more than 90 percent.  In addition, chemicals such as hydrogen peroxide and
ammonia are recovered and recycled and mineral residues are recovered and sold to a cement works.
After the introduction  of the BMPs, process water usage was reduced by 90 percent, energy used
was reduced by 60 percent.  Ultimately, this contributed to operating costs being 40 percent lower.
NPDES Best Management Practices Manual
        3-25

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CHAPTER 3
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
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 3-26
              NPDES Best Management Practices Manual

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INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
                                                      CHAPTER 3
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NPDES Best Management Practices Manual
                                                            3-27

-------
CHAPTER 3
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES


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3-28
             NPDES Best Management Practices Manual

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INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
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NPDES Best Management Practices Manual
                         3-29

-------
CHAPTER 3
          INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
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3-30
                       NPDES Best Management Practices Manual

-------
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
                             CHAPTER 3
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NPDES Best Management Practices Manual
                                    3-31

-------
 CHAPTER 3
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3-32
            NPDES Best Management Practices Manual

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INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
           CHAPTER 3
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 NPDES Best Management Practices Manual
                  3-33

-------
CHAPTERS
             INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
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3-34
                          NPDES Best Management Practices Manual

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INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
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 NPDES Best Management Practices Manual
        3-35

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CHAPTER 3
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
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3-36
             NPDES Best Management Practices Manual

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ITSIDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
CHAPTER S
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 NPDES Best Management Practices Manual
        3-37

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CHAPTER 3
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
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When the product resin needs to
be washed several times,
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low quantities of wastewater



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phenolic resins
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By reusing resin washwater from
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Eliminates toxic catalyst residuals
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pigments
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measurement of chemicals
based on the stoichiometric
formulation of process
batches
3-38
             NPDES Best Management Practices Manual

-------
 INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
                                                       CHAPTER 3
s
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  NPDES Best Management Practices Manual
                                                               3-39

-------
 CHAPTERS
    INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
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serves water, reduces am
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ulfide in effluent
mit
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ontact
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ng the heated no
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3-40
                  NPDES Best Management Practices Manual

-------
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
CHAPTER 3
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available. This bypasses the city
water line and reduces the need
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automated control to reuse
water

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computer programs to
accurately control dye
absorption

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wastestream may be easily
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multistage countercurrent
wash system to produce a
more concentrated effluent
stream for recycling


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By designing washers to use only
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a particular step or operation,
water use decreases. Up to 85
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with new washers.



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of washers

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chemical biocides which would
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Source Reduction:
Replacement of alkyl
phenol ethoxylates with
linear alcohol ethoxylate
compounds
 NPDES Best Management Practices Manual
       3-41

-------
CHAPTER 3
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
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chemicals and dye hi the
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water discharge

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dyes with less toxic
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jet dyeing and low li
dyeing
3-42
             NPDES Best Management Practices Manual

-------
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
                                                CHAPTER 3
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                                                       3-43

-------
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Source Reduction:
Extended delignification
using the kraft cooking or
polysulfide cooking
processes
3-44
             NPDES Best Management Practices Manual

-------
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
                                                CHAPTER 3
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NPDES Best Management Practices Manual
                                                       3-45

-------
 CHAPTER 3
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
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Eliminates the need for fresh water
addition during pulping and
facilitates pulp recovery from
wastewater




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rich white water for stoc
preparation and dilution
prior to treatment



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Allows white water to be sent to
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can be recovered and collected for
reuse as shower water
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Recycle/Reuse: Use of
vacuum boxes and rolls
equipped to facilitate was
segregation



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Eliminates the need for pressing
and bark thawing. These
modifications eliminate bark
removal process discharges.

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Installation of a dry
barking system



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Allows extract from screening and
cleaner rejects from bleachable
grade pulp mills to be returned to
the process rather than discharged
to the sewer system

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Separation of chlorine
bleaching activities from
refining and cleaning



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Disposable solids can be washed
over a small filter to recover and
reuse filtrates and reusable
chemicals. Eliminates a source of
biochemical oxygen demand in the
wastewater.

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screen filtering and
rewashing techniques



£
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-------
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
                                          CHAPTERS
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                                                3-47

-------
CHAPTER 3
                  INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
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the discharge of
contaminated with
wa
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rinse th
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Installatio
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Source Reducti
Recycle/Reuse:
of high pressure
equipment clean
nozzles on all h
3-48
                               NPDES Best Management Practices Manual

-------
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
CHAPTER 3
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equipment allows for easier
recovery of materials. These
methods of cleanup also reduce
wastewater volume associated w
cleanup, and lessen contaminatu
of wastewater.

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Recycle/Reuse: For spill
cleanup, the use of
dedicated vacuums for dry
spills and dedicated mops
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water where water is
needed for cleanup



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Longer manufacturing sequence!
of the same product or family oi
products reduces the amount of
cleanout required and thus
minimizes wastewater discharge
quantities

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Extension of production
runs of the same product
for as long as possible



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use of reused rinsewater as
the initial rinse when more
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rinsewater as make-up
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Rinsing of drums using
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NPDES Best Management Practices Manual
       3-49

-------
CHAPTER 3
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
§1
P£
Other Incentives

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Will reduce the estimated
disposal costs of filter cakes at
full-scale production of
approximately $250,000 per
year



Use of filter cakes as a soil
additive eliminates the disposal
into the sewer

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Recycle/Reuse: Use of
waste filter cakes as a soil
additive

3
Based on a cost of $1.78 per
gallon of raw solvent, saves
I $3,520 to $5,290 in raw
material costs per harvest



Recovery operations result in the
reuse of more than 99 percent of
solvents processed, which
minimizes disposal needs

1*8 I §

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equipment of spent solvent
solutions operations

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some value as a soil additive,
efficient collection of filter
cake may be financially
beneficial



New equipment will reduce
disposal loads

&

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Source Reduction:
Installation of guides
beneath rotary vacuum
filters that direct filter cake
into the center of the
conveyor belt

S
Company saved 1,000 gallons
of fuel oil per year ($2,800).
Eliminated offsite disposal
costs.



Eliminated disposal of alcohol-
based wastes
,
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Reclamation of alcohol-
based wastes and mixing
them with fuel oil, which
can be used as fuel for a
boiler

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New process saves $70,000
annually in treatment costs



Recovered and reused 70 percent
acetone by weight from
wastewater



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Recycle/Reuse: Installation
of a separation process to
recover and reuse acetone
from wastewater

S




Vacuum collection devices reduce
the amount of clean-up water
needed and lessens the pollutant
load and the volume of water
entering the wastestream
I
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Recycle/Reuse: Use of
vacuum systems for routine
clean-up of dry chemical
spills rather than water

S




Vacuum collection devices and
squeegees when cleaning up
reduce the amount of clean-up
water needed. This lessens the
pollutant load and the volume of
water entering the wastestream.
i
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a. s

It

&
Source Reduction and
Recycle/Reuse: Use of
squeegees and vacuum
collection devices rather
than water to clean up
spills
3-50
             NPDES Best Management Practices Manual

-------
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
                                        CHAPTER 3

     -52
     
          .§ •§ .2 £
          SP *a £ "O
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          co a -5 
-------
CHAPTER 3
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
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Other Incentives
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Beneflts to Water

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Added $18,744 per year in
operation and maintenance
costs. Saves $13,000 per year
in feedstock reduction,
$21,000 per year due to waste
reduction, and $.25 per ton
produced including water and
energy costs.
| ||
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of the total process water has to 1
treated. Also reduces capital cos
for the pretreatment facility by 5'
to 75 percent.

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Reduced water and sewer rates
by $5,400 per month








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Comprehensive wastewater syste;
produces finished water suitable
for recycle and reuse in the
manufacturing process, thereby
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             NPDES Best Management Practices Manual

-------
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
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                                      3-53

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CHAPTER 3
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
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INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
                                  CHAPTER 3


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3-56 NPDES Best Management Practices Manual

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                                                   CHAPTER 3
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3-58
              NPDES Best Management Practices Manual

-------
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
CHAPTER 3
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3-60
             NPDES Best Management Practices Manual

-------
INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES
CHAPTER 3
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 NPDES Best Management Practices Manual
       3-61

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-------
RESOURCES AVAILABLE FOR DETERMINING
BEST MANAGEMENT PRACTICES
CHAPTER 4
                  4.  RESOURCES AVAILABLE FOR DETERMINING
                          BEST MANAGEMENT PRACTICES
       A wide variety of resources can help industry to identify BMPs.' Often these resources are
the same as those supporting pollution prevention efforts. This chapter contains information about
publicly and privately sponsored programs that provide support ranging from onsite assistance to
dissemination of information about BMPs.  This chapter is based in large part on information
contained in an Environmental Protection Agency manual entitled Pollution Prevention Resources
and Training Opportunities in 1992.  Some of the major programs discussed therein are examined
in greater detail as part of this manual.

4.1  PURPOSE OF THIS CHAPTER
       This chapter provides brief overviews  of some of the major sources of information on best
management  and pollution prevention practices.  Most of the resources presented are available
through public programs.   The organizations that administer these programs may be contacted
directly by the user in order to gain access to the program's resources. To assist in this process, this
chapter lists each program's address and contact persons as exhibits in each of the subsections on
national and international, regional, State, and other programs.

       The resources available through these  programs vary, with dissemination of fact sheets and
 case study materials being the predominant form of assistance.  The reader should be aware that the
 assistance provided by some of the programs may be limited.  Limitations can include restrictions
 or the geographical area served, limitations on the subject area, and restrictions on the types of
 assistance provided.  The summary of each program indicates and describes any such restrictions or
 any costs.                                                    v

 4.2 NATIONAL AND INTERNATIONAL RESOURCES
        National  and  international  programs  supporting  both  pollution prevention  and  the
 determination of BMPs are accessible to potential  users across the United  States.  The programs
 discussed in this section include the Pollution Prevention Information Clearinghouse, the International
 NPDES Best Management Practices Manual
          4-1

-------
 CHAPTER 4
RESOURCES AVAILABLE FOR DETERMINING
             BEST MANAGEMENT PRACTICES
 Cleaner Production Information Clearinghouse, the Waste Reduction  Institute for  Training and
 Applications Research, Inc., and the National Technical Information Service.  These programs cover
 a wide variety of topics and provide general information and assistance.  Other programs that are
 limited to a specific region/area of assistance are discussed in Section 4.3.

 4.2.1  Pollution Prevention Information Clearinghouse (PPIC)
        PPIC is a component of EPA's Pollution Prevention Office program to facilitate pollution
 prevention information transfer. PPIC is dedicated to reducing or eliminating industrial pollutants
 through technology transfer, education, and public awareness.  PPIC contains technical, financial,
 programmatic, legislative, and policy information concerning source reduction and recycling efforts
 in the United States and abroad. PPIC is a free, non-regulatory service of the EPA and is accessible
 by personal computer, telephone, fax, or mail.  The primary components of PPIC  are the PPIC
 repository, the Pollution  Prevention Information Exchange System (PIES),  and an information
 hotline.  Exhibit 4-1 provides contact information for PPIC.

        The PPIC repository is a reference library that includes the most current pollution prevention
 information in the form of case studies, fact sheets, programmatic and legislative  information, and
 training materials.  More  than 2,000 documents and reference materials are available through the
 repository. Information on materials in the repository as well as access to materials in the repository
 can be obtained by  contacting PPIC through the PIES network or the PPIC hotline, both of which
 are described below. Additionally, interested parties can request information on the contents of the
 repository by fax or by mail.

        PIES is a 24-hour electronic  network consisting of a message center, a bulletin board
 including issue-specific "mini-exchanges,"  a calendar of events, an online bibliography of materials
 distributed by PPIC, policy and technical data bases, and a document ordering service.  The message
 center  enables users to interact with individual users, EPA, and system  operators,  or  the entire
 network.   Communications  can include asking questions, responding to questions, and  sharing
 information and ideas.  Some examples  of the message  center's usefulness include requesting
 solutions to specific pollution problems, requesting participants in studies,  and  adding notifications
4-2
       NPDES Best Management Practices Manual

-------
RESOURCES AVAILABLE FOR DETERMINING
BEST MANAGEMENT PRACTICES
                                                                           CHAPTER 4
of  upcoming  events not  listed on the
calendar of events. EPA also uses the PIES
message center to interact with users as part
of information exchange efforts.

       The PIES bulletin board provides
information on  specific  topics.   Current
bulletins  available  in the  PIES  system
include PPIC news  and announcements,
Federal policy  statements,  Federal  grant
announcements,  feature articles,  newsletter
updates from national and regional pollution
prevention  newsletters,  and  a keyword
directory.    In  addition, several  of the
regional and State programs (e.g., Northeast
Multimedia Pollution Prevention Program,
discussed in Section 4.3.1) operate mini-
                                               ;EXPBIT 44*; PPIC CONTACT
                                              I >'% '^'INFORMATION^ -
                                                         iiie: "EPA HeaMmrters Library. _
                                                 <*£
                                                          Rot?
                                                         , sV
                                                            (202) 260-1023
                                                                  %
                                                    ^     %  --     _^ -** ?     ^
                                                    Prevention Mormatkax
                                           BfA HesKlquarters. Library. --
exchanges from the bulletin board system.     '401 ^ Street, S,W.
                                         ,%Washington; &C> 20460
        The calendar of events contained in
 PIES  lists upcoming  training events conducted at the international,  national, regional, and State
 levels. The information contained in the calendar includes topics, dates and times, costs, and contact
 information for each event.  PIES does not provide a registration service; to register for these
 training events, users must contact training event representatives directly.

        The online bibliography contains a list of the materials available in PIES.  Generally, the
 bibliography  provides title,  author, reference citation, an  annotated  description, .a contact or
 publication source, and document ordering information.  Users can review this material and order
 the documents through PIES or the hotline automated ordering system.
  NPDES Best Management Practices Manual
                                                                                      4-3

-------
 CHAPTER 4
     RESOURCES AVAILABLE FOR DETERMINING
                  BEST MANAGEMENT PRACTICES
        Policy and technical data bases contained in PIES allow users to obtain online summaries of
 information by using a keyword search.  These data bases include summaries of Federal and State
 pollution prevention program descriptions, as well as pollution prevention case studies. The Federal
 and State summaries contain discussions of program objectives and activities, applicable legislation,
 grants and research projects, and contact information.  The case study summaries provide industry
 profile information followed by a description of pollution prevention program implementation.  These
 descriptions  may  include  materials,  chemicals,  and feedstocks; initial  and final technology
 descriptions; affected wastes and wastestreams; environmental media involved; costs incurred and
 costs recovered; and reference information including available facility contact information.  Where
 users wish to gather more detailed information, online summaries can be downloaded directly  or
 ordered using document ordering information provided at the conclusion of .each PIES case study
 summary.
       PIES enables the  user  to
access  the  repository  and   the
document ordering service, and to
contact the PPIC  technical  staff.
Instructions for using PIEs appear in
Exhibit  4-2.     A  user   who
experiences any difficulties  entering
the PIES system should consult the
PIES  technical   support  service,
which is  part of the information
hotline discussed below.

       The PPIC hotline  is a user-
friendly   automated  voice   mail
telephone   system.    Through the
automated  system,  the  user  can
direct any PIES access problems to
 -  EXHIBIT 4-&  INSTRUCTIONS FOR FmS USE
 ,11 "Use a CQsaiJqferjor dumb lermiaajl equipped witfe a
.~ vJbtaja f200"or 2400^atid.  *  "'^J.  ,    ~ 7 -
      -,•,•.-*:•*•,'*'•            •• •.        »*• 	 .- ,
 2. Set  appropriate  eonrnunicatikts  software £
    ^r^s&IR) at $ data bk$,, m parity, and= '1 stop bit,
 ,% ,-<;,'*   :-"''"',  ^--   „,  ",>sw   "-  -•»="-, -  _f-   '  /•,'
 '3. Call (703)5064025 for access.
                                               iocaJ
acc«M
                     eater C2Q356JL31 at tbe
                 on on ho^ to. subscribe to
 5. ,If a user has access|
-------
RESOURCES AVAILABLE FOR DETERMINING
BEST MANAGEMENT PRACTICES
CHAPTER 4
onsite user support personnel. Additionally, the hotline system can provide PIES access to users who
do not have access to a computer.  In response to hotline requests, technical support personnel will
access messages or bulletins and conduct data searches. Finally, the hotline provides a user-friendly
automated system to order documents.

       Three restrictions are associated with the use of Clearinghouse services:
       • Users of the PIES services are limited to 1 hour daily of online access.  This ensures that
         all users of PIES will be granted access.
       • Not all case studies summarized in PIES are available through the PPIC document ordering
         service. Often, the complexity of a document or distribution/copyright restrictions set out
         by the author or publishing company prevent materials from being available through PPIC.
         In all cases,  however, PPIC users can be referred to the respective author, publishing
         company, or document distribution center.
       • Orders are limited to 1.0 documents.

4.2.2 International Cleaner Production Information Clearinghouse  (ICPIQ
       ICPIC is PPIC's  sister  clearinghouse operated by the  United  Nations  Environment
Programme (UNEP).  ICPIC provides information to the international community on low- and non-
waste producing technologies.  ICPIC was developed to coordinate the international exchange  of
information with an emphasis towards technology transfer to developing countries.

       ICPIC has functions and components similar to PPIC, including an electronic information
exchange system that is directly accessible to PPIC PIES users. ICPIC contains a message center,
bulletins, a calendar of events, case studies, program summaries, an online bibliography, and a
directory of contacts.  See Exhibit 4-3 for ICPIC access information.

       In addition to these components, ICPIC offers a unique resource in that it sponsors working
 groups that act as forums for exchanging pollution prevention information.  Recognized pollution
 prevention specialists  comprise these working groups, which meet regularly to  share and gather
 information on the latest technologies.  Working groups have been formed in such industries as
 NPDES Best Management Practices Manual
          4-5

-------
 CHAPTER 4
                                        RESOURCES AVAILABLE FOR DETERMINING
                                                    BEST MANAGEMENT PRACTICES
 textiles,  halogenated solvents,  leather tanning,
 biotechnology, and electroplating, and a pulp and
 paper working group is being formed.

       A final unique component  of ICPIC is the
 OzonAction program. OzonAction was established
 by  the  United  Nations  Environment Programme
 under the Interim Multilateral Ozone Fund (IMOF)
 of the Montreal Protocol Agreements.  OzonAction
 relays technical and programmatic information on
 alternatives  to  all  ozone-depleting  substances
 identified by the IMOF.   OzonAction  provides
 pollution prevention  information to  five industry
 sectors that generate or utilize  solvents, coatings
 and  adhesives; halons;  aerosols  and  sterilants;
 refrigerants; and foams.  As part of its  technical
 support, OzonAction provides data bases on solvent
 substitutes  for  ozone-depleting  substances  as
 compiled by the Industry Cooperative  for Ozone
Layer  Protection.     Information  contained  in
OzonAction can be accessed via ICPIC.
                                                             4-3J ICPIC CONTACT
                                                           INFORMATION
                                                                PHONE
                                                     • \
The Director'
indqstry
Activity
United
                                                                Btivlro.nment , Progrm
                                                 France
   Use
                                                              _ ,«*«.   ,   .
                                                               MODEM
                                                                         wllh
                                                    Capabilities^ e^uipged^with a modem
                                                    i&ftwarejfca| operates at 1200 or |400 ,
                                                   vbaad< ^ r r     "     ,           -   ^
                                                   '  ' ,  'As. ' '  '
                                                , 2, Set communications s»ifo??ar& tq 8 data
                                                         no"paritj?,and 1 stop bit.
                                                >:
                                                ^,"
                                                 4,
                          .   /,,' -••"",,--•
                          vtf   jpf
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RESOURCES AVAILABLE FOR DETERMINING
BEST MANAGEMENT PRACTICES
                                                                            CHAPTER 4
to sponsors. The extent of these limitations can be determined by contacting WRITAR as described
in Exhibit 4-4.   ..                               -'* "           44?" WRITAR CONTACT

                                                                    >or A
                                                               \ PHONEr

                                                 (WRifAR
                                                 '"I'm 5th
                                                                   55414-450SI
       WRITAR  primarily  provides   pollution
prevention assistance for training related activities
and policy analyses.   Since  WRITAR  has  both
public  and private roots, it can borrow from  an
extensive  network of  knowledgeable individuals
who work in private firms, public agencies, and
nonprofit   organizations   to   support   pollution
prevention  projects.     WRITAR   utilizes  this
expertise and  its  capabilities  to conduct in-depth
research to design and deliver pollution prevention
training to  Federal, State, and local  regulators,
inspectors,  and  administrative  staff as well  as
Corporate  and  public  audiences.     Generally,   mmmmmmmmmmmmmmaimmmmffmmmmmmmmmam
WRITAR emphasizes the importance of management's approach to successfully implement pollution
prevention.  WRITAR also conducts industry-specific pollution prevention training for more narrowly
defined audiences.   Additionally, WRITAR  tracks and publishes State legislation that relates to
pollution  prevention, and analyzes draft legislation and policies for States and localities that are
 starting their own pollution prevention programs.

 4.2.4  National Technical Information Service (NTIS)
        NTIS, an agency of the U.S.  Department of Commerce, is the central source for the public
 sale of research, development, engineering, and business reports. The NTIS collection of more than
 2 million works covers current industries, business and management studies, foreign and domestic
 trade, environment and energy, health and the social sciences, translations of foreign reports, general
 statistics, and many other areas.  Approximately 70,000 new technical reports from 200 agencies are
 added to the NTIS data base annually  with nearly one-third of the new additions coming from foreign
 sources.
  NPDES Best Management Practices Manual
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 CHAPTER 4
RESOURCES AVAILABLE FOR DETERMINING
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        The NTIS document service generally is  limited to documents created or sponsored by
 government agencies, including EPA. When government agencies forward reports to NTIS, these
 items are entered into the NTIS computerized bibliographic database and become part of the
 archives.

        Since an average of 1,300 titles are added to the NTIS collection weekly, NTIS produces a
 number of printed and electronic awareness services for interested parties. In the environmental
 field, the NTIS  Alert on Environmental Pollution and Control is  a twice-monthly bulletin which
 summarizes recently published environmental-related  manuals, reports, and studies.  NTIS is a
 valuable document  ordering organization, but does not  act  as a technical information hotline.
 Document ordering may be done by mail, phone, or fax.  There is a  cost associated with each
 document distributed by NTIS.  For the most rapid service, NTIS recommends having the NTIS
 document number available when ordering  documents.   Exhibit 4-5 contains NTIS contact
 information.
 4.2.5    Nonpoint  Source  (NPS)  Information
 Exchange Bulletin Board System (BBS)
       The  Nonpoint Source (NPS)  Information
 Exchange Bulletin Board System  (BBS) provides
 federal,   state  and   local  agencies,   private
 organizations  and  businesses,   and  concerned
 individuals with timely, relevant NPS information,
 a  forum for open discussion, and the  ability to
 exchange computer text and files.  The NPS BBS
 can be used to:  read, print, or save to computer
 disk,  current  NFS-related articles, reviews  and
 factsheets; exchange computer data including data
 files,  spreadsheets, word processing files  and
 software; post articles and comments on-line for
            EXHIBIT 4-5f$TIS CONTACT
        ^ Springfield, VA'' 2
         j.' "<.   ',    ,    ..
4-8
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RESOURCES AVAILABLE FOR DETERMINING
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                                                                         CHAPTER 4
others; ask questions and conduct discussions directly with NFS experts; and, exchange private letters

and file with others.


       To access the NFS BBS, the user will need:

       • A PC or terminal
       • Telecommunications software (such as Cross Talk or Pro Comm)
       • A modem (1200, 2400, or 9600 baud)
       • A phone line that can accommodate modem telecommunication


       To assist in accessing  and using the NFS BBS system, a comprehensive user's guide is

 available. This guide also describes the various BBS  features, and can be obtained by writing to,the

 address shown in Exhibit 4-6.
4.2.6 Office of Water Resource Center

       The Office of Water Resource Center is

an information clearinghouse for  publications

and resources available through the U.S. EPA
Office of Water.  The Resource Center offers:
         Complete Database of Publications
         Document Reference File
         Publication Distribution Management
         NTIS and ERIC Submission Services
         On-Lihe Ordering for Warehouse
         Data Searches
         Publication Call Referrals
         One  Location   for  Publication
         Shopping
                                                               4-fc  NFS BBS
                                                  **V
                                                            tfiqn 'Exchange (WH-5531
                                                         -40i M &&&, SW     -  ^
                                                                 I, DC 20460 s
        This  service  is  available  to anyone
  seeking information regarding U.S. EPA Office of Water publications. (See Exhibit 4-7 for contact

  information.)
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                                                                                    4-9

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 CHAPTER 4
                                        RESOURCES AVAILABLE FOR DETERMINING
                                                    BEST MANAGEMENT PRACTICES
                                               ^EXHIBIT 4-7*  OFFICE OF WATER
                                               "s RESOURCE' CENTER CONTACT
                                                         of Water Rfisource Center ,
                                                "iJ* -";V^ :'- PHONE *   '"
 4.3 REGIONAL RESOURCES
        Regional resources are also available for
 consultation when determining available BMPs
 and pollution prevention practices.  As noted in
 the following text, many of these resources
 support limited  geographic  regions.    The
 regional resources discussed in  this  section
 include  the  Northeast  Multimedia Pollution
 Prevention  Program,  the Waste Reduction
 Resource Center for the Southeast, the Pacific
 Northwest   Pollution   Prevention  Research  	-,   '-'' ' ^/...".'r...'.". ~v",    :C^i   -^
 Center,  and  EPA's   network  of pollution
 prevention  contacts and libraries  at the regional and headquarters levels.

 4.3.1  Northeast Multimedia Pollution Prevention Program  (NEMPP)
       NEMPP was established in 1989 to help State environmental officials  in New England
 (Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont), New Jersey,
 and New York implement effective source reduction programs.   Technical staff and  regulatory
 officials  concerned with air,  water, and waste programs participate in  the working groups that
 comprise NEMPP program. The  NEMPP program was designed as a resource only to State officials
 and thus obtaining NEMPP program resources should be coordinated through State officials.  (See
 Exhibit 4-15 in Section 4.4.3 for  information on State contacts.)

       NEMPP's  program provides two components:  (1) a clearinghouse of information  on
pollution prevention/best management practices including technical data, case studies, and a list of
pollution prevention experts; and  (2) the conduct of training sessions for State officials and industry
representatives on source reduction strategies, policies, and technologies.

       Additional information on the NEMPP program can be obtained from the NEMPP quarterly
newspaper and the  NEMPP program mini-exchange established on PIES (see Section 4.2.1 for a
4-10
                                             NPDES Best Management Practices Manual

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RESOURCES AVAILABLE FOR DETERMINING
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                               CHAPTER 4
description of PIES).  To be added to the quarterly newspaper mailing list, the NEMPP program
may be contacted as described in Exhibit 4-8.  The mini-exchange provides a list of materials in the
NEMPP program clearinghouse, a list of experts  on pollution prevention in the Northeast, and
region-specific articles and newsletters.   It also identifies upcoming meetings,  conferences, and
general source reduction training opportunities.
                                        —*>> EXHIBIT ffcjNEMPI* CONTACT  ,  ~~
4.3.2 Waste Reduction Resource Center  '"v\s',  :^x    INFORMATION
for the Southeast (WRRO      .  •       ^^^/^^ "    -.'•/'_
       WRRC was established in 1988 by
the Tennessee Valley  Authority and EPA
Region  4  to  provide multimedia  waste
reduction  support for the States in EPA
Region  4:    Alabama, Florida,  Georgia,
Kentucky,  Mississippi,  South Carolina,
North Carolina, and Tennessee. The Center
has a collection of technical waste reduction
information  from  Federal  Government
agencies,   all  fifty  States,  and  private
sources.    WRRC  consists  of  several
different components including  technical
assistance  by  phone  and by conducting  ^^
onsite  waste  reduction  assessments,  a
repository, an information network, and training.
                                                            PHONE '
                                                              367-8558
                                                           f     •: v
                                                           w.1* •« » A »*
                                                             MAIL
85
                                                       Street
                                           Boston, MA '02114
        WRRC provides technical support in developing pollution prevention evaluations, preparing
 industry-specific reports on  waste  reduction,  and conducting free, onsite  non-regulatory  site
 assessments.   In these assessments, WRRC personnel  draw on their technical experience  and
 knowledge of industrial pollution prevention options.
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 CHAPTER 4
                                        RESOURCES AVAILABLE FOR DETERMINING
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        More than 3,000 pollution prevention documents in the form of journal articles, case studies,
 technical reports, and books are maintained in the hard copy repository. This includes more than
 500 case summaries  that describe the application  of pollution prevention techniques to many
 industrial categories and processes. These documents specifically cover economic and technical data,
 process descriptions, pollution prevention techniques, and implementation strategies, and are often
 consulted when completing pollution prevention reports.

       WRRC also maintains lists of important waste reduction program contacts including persons
 at EPA Headquarters, EPA Regions, industry trade  organizations, universities,  other experts, and
 equipment vendors in the field of pollution prevention for referral and consultation.

       While WRRC focuses on supporting groups in EPA Region 4, it offers its assistance to any
 interested parties.  These  services are all provided  free  of charge.  WRRC can  be  contacted  as
 described in Exhibit 4-9.                   m
                                                EXHIBIT 4-9: WRRC CONTACT
                                             V, V* -: f ^ INFORMATION^
                                                      *' -CONTACT;
                                              Z&m "  ; ,   ' ,_~ __%,  "
                                                        , „ <3ary Hunt
4.3.3     Pacific  Northwest  Pollution
Prevention Research Center (PNPPRC)
       PNPPRC  is  a  nonprofit public-   [
private partnership dedicated to furthering
the   goal  of   multi-media   pollution
prevention,  and  to  reducing   significant
waste streams in the Pacific  Northwest.
                                          sV i '••   *•     •*-»=S=i_,  -.^     -. v. *
PNPPRC  is  supported  through  technical    Waste Reduction' Resource  Center  Ibr  'Uhe"
                                          •Southeast
assistance grants by industry, environmental
and civic organizations,  Federal and State    Raleigh^ NC 2?6^" ,
governments, and  academia.   PNPPRC 's  •— «"W*-«M— nMMi'i^^
                                                                 m
program is built around the identification of pollution prevention research gaps, the conduct of
research, and the communication of research results.  PNPPRC activities generally revolve around
its pollution prevention grants program.
4-12
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                                                                           CHAPTER 4
                                                                     i PNPPRC
                                                      CQWfACT INFORMATION
                                                      :. v Cv1 °"       _         f
                                                      "C
                                                               f-S>
       PNPPRC primarily analyzes  technologies  and disseminates information based on grant-
sponsored research.  An information network, another PNPPRC component, connects PNPPRC to
associations, industries, small businesses, government, and information sources in the Northwest and
to State, regional, and Federal resources.  The PNPPRC network educates the public on pollution
prevention by providing a pollution prevention research database, a library, in-house publications,
and technical and financial referral services. PNPPRC also generates publications and hosts seminars
dealing with pollution  prevention.   PNPPRC performs its services free  of charge.   However,
PNPPRC is limited to providing assistance to facilities located in the  States  of Alaska, Idaho,
Oregon, and Washington, and to the Province of  ^
British Columbia. PNPPRC can be accessed using  ,
the information provided in Exhibit 4-10.
4.3.4 EPA Offices and Libraries
       Each EPA Regional office has identified a
contact  for pollution prevention. The names and
addresses of these contacts are given in Exhibit 4-
1 1 . These pollution prevention contacts can provide
guidance  on programs  and  associated  resources
including upcoming regional activities, work group
development, industry associations, and a wealth of
other references. Such information can be useful to
industries seeking  assistance  in developing  a best
management or pollution prevention  practice plan.
                                                                f     ^. _, ,
                                                                FHONT
                                                                        *OX«C.'
                                                                         n
                                                  Research Center     --
                                                                Street, Suite 1.252
                                                              9810$, / '   -"
        EPA's  library  system is  another  resource for those seeking information on pollution
 prevention and BMPs.  Many EPA libraries have specific collections devoted to these areas. These
 libraries are open to visitors for  the conduct of onsite research and frequently allow visitors to
 generate their own copies for a small copying charge.  However, these libraries do not function as
 photocopying and information dissemination centers. The information contained in Exhibit 4-12 may
 be used to contact EPA library representatives.
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 CHAPTER 4
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EXHIBIT 4-11. EPA REGIONAL POLLUTION PREVENTION CONTACTS
<&nte^,, WarkMafcoatt^Sfttf Afcby&Wafee- •. s ' -.
Address: U.S. EPA Region I
John F. Kennedy Federal Building
Boston, MA 02203
Phone: (215) 597-8327
 ( ' •. , J
Address: U.S. EPA Region HI
841 Chestnut Building (3ES43)
Philadelphia, PA 19107
Phone: (215) 597-8327
CMMttt &tfe «&&*,.,* "*"" - "*v~*" ""
Address: U.S. EPA Region V
77 West Jackson Boulevard
Chicago, IL 60604-3590
Phone: (312) 353-6148
Contort: f&sxt Wa&rassw x^ , ' *
5 •$;•••• •*•. •>
Address: U.S. EPA Region VD
726 Minnesota Avenue
Kansas City, KS 66101
Phone: (913) 551-7336
C*ttW«*v *** **&&au ^Ll,' ' - -
;• ; ASs»C«eaw ^^k
Address: U.S . EPA Region K
75 Hawthorne Street
San Francisco, CA 94105
Phone: (415) 744-2038/2189
CftnteBfc JimslSapsdm , ir _ '',7""';
Address: U.S. EPA Region JJ
26 Federal Plaza
New York, NY 10278
Phone: (212) 264-1925
Contacts ' 
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CHAPTER 4
EXHIBIT 4-12. EPA LIBRARY CONTACT INFORMATION
Confasft tofoRanTpenit JJbjSHireR
Address:
Phone:
Library
U.S. EPA Headquarters
401 M Street, S.W. (PM 21 1A)
Washington, DC 20460
(202) 260-3561
<3oniBBfc BsgNelsoH, Libtsriaa'
Address:
Phone:
U.S. EPA Region I
John F. Kennedy Federal Building
Boston, MA 02203
(617) 565-3300
Coniaeti £Sttt» M, MeCteaiy,. L8>«ttia#
Address:
Phone:
'CqnfaSfft
Address:
Phone:
Contact;
Address:
Phone:
U.S. EPA Region ffl
841 Chestnut Building (3PM 52)
Philadelphia, PA 19107
(215) 597-7940
' Ms' Lflft W> -Tilfey, Litocaoaft
U.S. EPA Region V
12th Floor, 77 West Jackson Boulevard
Chicago, IL 60604
(312) 886-9506
JBatbara MacKinnaa, Libiariaa
U.S. EPA Region VH
726 Minnesota Avenue
Kansas City, KS 66101
(913)551-7358
d?iSasti $af4H Stfttdhelm, tJh{ariai»
Address:
Phone:
U.S. EPA Region IX
li Hawthorne Street, 13th Floor
San Francisco, CA 94105
(415) 744-1518
CM*. S^WHa«>Lib™ ~ „
Address: Center Library
Risk Reduction Environmental Laboratory
U.S. EPA Headquarters
26 W. Martin Lulher King Drive
Cincinnati, Ohio 45268
Phone: (513)569-7707 .
Contact* EvatoGoodmaVLtbrariaa " ^".
Address: U.S. EPA Region H
26 Federal Plaza
New York, NY 10278
Phone: (212)264-2881
Contact* frisoitttt Pads, Htnariait ' % " \
Address: U.S. EPA Region IV
345 Courtland Street, NE
Atlanta, GA 30365-2401
Phone: (404) 347-4216
Contact* t^WMTwl****^
Address: U.S. EPA Region VI
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
Phone: (214) 655-6444
Contest t Barbara Wagner,. Ltbrarisn. \ v
Address: U.S. EPA Region VHI
999 18th Street, Suite 500
Denver, CO 80202-2405
Phone: (303)293-1444
Contest* luKertflfi Seats, 1Lih*ada« " " /
Address: U.S. EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
Phone: (206) 553-2969
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 4.4 STATE, UNIVERSITY, AND OTHER AVAILABLE RESOURCES
        Several other available resources can be used to identify applicable pollution prevention and
 best management practices.  These include environmental organization programs, trade association
 programs, industry-specific programs, and  State and university-affiliated programs;  This section
 discusses some of these other resources, including the Center for Waste Reduction Technologies, the
 Solid  Waste Information  Clearinghouse, and State  and university-affiliated pollution prevention
 training and information programs.

 4.4.1  Center for Waste Reduction Technologies (CWRT)
        CWRT was established in 1989 by the American Institute of Chemical Engineers to support
 industry efforts in meeting the challenge of waste reduction through a partnership between industry,
 academia, and government. CWRT provides research, education, and information exchange through
 funding provided by sponsors. CWRT is developing an integrated research program based on the
 identification of  target processes  and  waste streams and  the  development of a hierarchy of
 technologies to address pollutant  release reductions or pollutant release elimination.

        CWRT is committed to transferring technology and related information to the user community
 through CWRT-developed how-to publications, training events and conferences, continuing education
 courses, and links with organizations having related interests.  In many cases, a small fee is required
 for  attending  training  events  sponsored  by CWRT or  for obtaining materials developed  and
 disseminated by CWRT.

       CWRT's technology transfer committee works  to  identify and prioritize waste reduction
 projects, including BMPs in .several technology areas. CWRT's research and development committee
 targets -research to create less polluting technologies  such as substitution and process design
 innovations. CWRT is also developing course materials for graduate and undergraduate engineering
 curricula and student internship programs as well as continuing education courses for practicing
 engineers.  Contact information for CWRT is provided in Exhibit 4-13.
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                                                                           CHAPTER 4
                                                 '"EXHIBIT 443: CWRT CONTACT
                                                         "
                                                                     ^ R0SS
                                                                     •"•      % v
                                                               **  «- ^     v^-
                                                               PHONE w ;"

                                                                     i-7487  -
                                                 .       for Waste Redaction Technologies",
                                                 ^American lastltajb <£ Chemical Engineer*-
                                                         "
                                                                 10017
4.4.2  Solid Waste Information Clearinghouse
(SWICH)
       SWICH is an  information clearinghouse
operated by  the Solid Waste Association of North
America (SWANA) and funded by EPA's Office of
Solid Waste, and the Association of Solid Waste
Management Professionals. SWICH was developed
to help increase the availability  of information in the
field  of  solid  waste   management.    SWICH
components  include an electronic  bulletin board
(EBB),  a  library,  and  a  hotline.     Contact
information  for these components is described in
Exhibit 4-14.

       EBB functions similar  to PIES (see Section
4.2.1 for information on PIES).   EBB allows the
user to search and order documents from a wide range of solid waste topics including source
reduction, recycling, planning, education, public participation, legislation and regulation, waste
combustion, composting, collection, waste disposal, and special wastes. EBB also provides updated
information on solid waste issues including meeting and conference information, message inquiries,
case studies, new technologies, new publications, contact information, and regulatory changes.

       Onsite library access is also provided as part of SWICH services, but prior appointments are
mandatory.  The library contains journals, reports, periodicals, case studies, films, and video tapes,
all focusing on solid waste issues. The library also includes a computer work station for access to
the EBB. Information in the SWICH library is available for viewing free of charge. There is a per-
page charge for photocopying of ordered documents.

       Many of the  resources available from these programs are free  of charge, but not all; the
 existence of charges should be determined by the user when consulting the program.
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                                              £?pHB;If 44# SWiP* CONTACT
                                               "'-' '   INFORMATION   _
                                                          ;Lori Swan

                                                           PHONE
                                                           t f s f s;V. f
                                                          \ •.'?   *•   f
                                                           <•   -•  ,
                                                              671-9424
                                                      *  W) 585-0297
                                          Solid Was^
                                          Solid Wa$fe Association of ^North America
                                         -P.O. '§ox 7219
                                          Silver Spring, MD~ 20^10
                                          "  '    -     , /  "•3.'?  "     ••,••'..
4.4.3 State Resources
       State programs are another valuable
source  of   information   on  pollution
prevention and best management practices.
In addition to grants, technical information,
information  transfer,  and  many  other
integral components  of State programs,
many States offer  training  courses  and
onsite technical assistance to industry either
directly  or through extension services  and
academic centers.

       The  number  of  State  programs
prohibits a  detailed  discussion  of  each
program. Therefore,  Exhibit 4-15 presents
the formal  name of each program  and
related  contact  information.   Generally,
services are limited  to facilities  located
within the State.

4.4.4 University-Affiliated Resources
       University-affiliated  resources  are
primarily centers for  research and training
in pollution prevention and BMPs that are  ^^^^^^
supported by the particular university and/or
industry and State and Federal funds.  Since there are too many programs to describe individually,
a listing of these programs by State including the contact person is prdvided in Exhibit 4-16.  Many
of the resources available from these programs are free of charge, but not all; the existence of
charges should be determined by the user when consulting the program.
                                          L Use  art IBM cojnpatMe computer or
                                            terminal  equipped  wilfea  modem
      appropriate
           es 'at 1200 or
                                                                                    ^
                                                                                 tfcat
                                          2, Set communications sofhvareto 3 data bits, .no
                                          /^parity, and t stop bit.
                                         fjf ff fff  fffff f ff^ff       jf     f    " , J:''i_.i_    v<-     •' fff
                                         X5S imys&Mw.          *1 "ti~   c
                                          4
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CHAPTER 4
EXHIBIT 4-15: STATE PROGRAM INFORMATION
STATE
Alabama
Alaska

Arizona
Arkansas
California
Colorado
PROGRAM NAME AND SPONSORING
AGENCY
Alabama Waste Reduction and Technology
Transfer (WRA'IT) Program
Alabama Department of Environmental
Management
Pollution Prevention Office
Alaska Department of Environmental
Conservation
Waste Reduction Assistance Program
(WRAP) and Small Business Hazardous
Material Management Project (HMMP)
Alaska Health Project
Arizona Waste Minimization Program
Arizona Department of Environmental
Quality
Arkansas Pollution Prevention Program
Arkansas Department of Pollution Control
and Ecology
Biomass Resource Recovery Program
Arkansas Energy Office
Department of Toxic Substances Control
Department of Toxic Substances Control
Local Government Commission
Pollution Prevention and Waste Reduction
Program
Colorado Department of Health
CONTACT INFORMATION
Contact: Daiitsl E, Coager
Address: 1751 Congressman William L. Dickinson Drive
Montgomery, AL 36130
Phone: . (205) 271-7939
fiotttihtti tJavkf Wiggfesworfh
Address: P.O. Box O
Juneau, AK 99811-1800
Phone: (907) 465-5275
, Contact; Kristin.* "Benson " " 	 .,, 	
Address: 1818 West Northern Lights Boulevard, Suite 103
Anchorage, AK 99517
Phone: (907) 276-2864
^(Mflactsi 5tej)in3(&S Wilson •• ' V™"
Dr> f.AndS'Swsifo 	
Address: 2005 North Central Avenue
Phoenix, AZ 85004
Phone: (602) 257-2318/6995
Contacts" Robert lufitaa
Address: P.O. Box 8913
Little Rock, AR 72219-8913
Phone: (501) 570-2861
Coflmr Bf$ Davis •" ' 	
Address: 'One State Capital Mall
Little Rock, AR 72201
Phone: (501) 682-7322
Contact-, Ut: Ritn Mlbefm
Address: 400 P Street
P.O. Box 806
Sacramento, CA 95812-0806
Phone: (916)324-1807
Contest; ^onyEulo
Address: 909 12th Street, Suite 205
Sacramento, CA 95814
Phone: (916)448-1198
CiMitacif JfeiJRolwey •*"- •" ,,
Address: 4210 East 1 1th Avenue
Denver, CO 80220
Phone: (303)331-4830
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STATE
Colorado
(Continued)
Connecticut
Delaware
District Of
Columbia
Florida
Georgia
Hawaii
EXHIBIT 4-15: STATE PROGRAM INFORMATION
PROGRAM NAME AND SPONSORING
AGENCY
Pollution Prevention and Waste Reduction
Program
Colorado Public Interest Research Group
(COPJRG)
Connecticut Technical Assistance Program
(CONNTAP)
Connecticut Hazardous Waste Management
Service
Connecticut Department Of Environmental
Protection
Delaware Pollution Prevention Program
Delaware Department of Natural Resources
and Environmental Control
Office Of Recycling
D.C. Department of Public Works
Waste Reduction Assistance Program
(WRAP)
Florida Department of Environmental
Regulation
Georgia Multimedia Source Reduction and
Recycling Program
Georgia Department of Natural Resources
Hazardous Waste Minimization Program
State of Hawaii Department of Health

CONTACT INFORMATION

.C.pirtacfc MieSiswif Nanwscek
Address: 1724 Gilpin Street
Denver, CO 80218
Phone: (303) 355-1861
Cbn*K«i fetthfcfl
Address: 2600 Blair Stone Road
Tallahassee, FL -32399-2400
Phone: (904) 488-0300
Contact: S»BaaBs»fJrictef 	
Address: Floyd Tower East, Suite 1154
205 Butler Street, S.E.
Atlanta, GA 30334
Phone: (404) 656-2833
Contact! JajtelMtoH ' '
Address: Five Waterfront Plaza, Suite 250
500 Ala Moana Boulevard
Honolulu, HI 96813 '
Phone: (808) 586-4226
4-20
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RESOURCES AVAILABLE FOR DETERMINING
BEST MANAGEMENT PRACTICES
CHAPTER 4
EXHIBIT 4-15: STATE PROGRAM INFORMATION
STATE
Idaho
Illinois
Indiana
Iowa
Kansas
Louisiana
Maine
Maryland
PROGRAM NAME AND SPONSORING
AGENCY
Division Of Environmental Quality
Idaho Department of Health and Welfare
Office of Pollution Prevention
Illinois Environmental Protection Agency
Office of Pollution Prevention and
Technical Assistance
Indiana Department of Environmental
Management
Waste Management Authority Division
Iowa Department of Natural Resources
State Technical Action Plan (STAP)
Kansas Department of Health and
Environment
Kentucky Partners-State Waste Reduction
Center
Louisiana Department of Environmental
Quality
Bureau of Oil and Hazardous Materials
Control
Maine Department of Environmental
Protection
Office of Waste Minimization and
Recycling
Maryland Department of the Environment
CONTACT INFORMATION
Contacts: Joyl&fowsr ,, , -•"- --•- .
Katie Sewstl "" " "
Address: 1410 North Hilton Street
Boise, ID 83720-9000
Phone: (208) 334-5879
CojfesrtsT Mite Hayw5
,.., , MMiael Wechva&d 	 ' 	
Address: 2200 Churchill Road
P.O. Box 19276
Springfield, IL 62794-9276
Phone: (217) 785-0533/8604
Cojrtsctst Joanne Tofe* ..„ -•; " ,,,,,,,,
Charles Sullivan
Address: 105 South Meridian Street
P.O. Box 6015
Indianapolis, IN 46225
Phone: (317) 232-8172
CoittactsT' Tom Blewefc ?'
Ssofl Cab.aU
Address: Wallace State Office Building
DesMoines, IA 50319
Phone: (515) 281-8941
Cotttsae Totftt-rfoss:
Address: Forbes Field, Building 740
Topeka, KS 66620
Phone: (913)296-1603
(See Kentucky University Programs)
£fettf»at: <3acy lahttson
Address: P.O. Box 82263
Baton Rouge, LA 70884-2263
Phone: (504)765-0720
Ctofscis $wtt Wbtffter .
Address: State House Station #17
Augusta, ME 04333
Phone: (207) 289-2651
Contact: Harry Benson
Address: 2500 Broening Highway, Building 40
Baltimore, MD 21224
Phone: (301) 631-3315
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       4-21

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CHAPTER 4
RESOURCES AVAILABLE FOR DETERMINING
          BEST MANAGEMENT PRACTICES
EXHIBIT 4-15: STATE PROGRAM INFORMATION
STATE
Maryland
(Continued)
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
PROGRAM NAME AND SPONSORING
AGENCY
Maryland Environmental Services
Office of Technical Assistance for Toxics
Use Reduction
Massachusetts Department of
Environmental Management
Office of Waste Reduction Services
Michigan Department of Commerce and '
Natural Resources
Minnesota Pollution Control Agency
(MPCA)
Mississippi Technical Assistance Program ,
(MISSTAP) and Mississippi Solid Waste
Reduction Assistance Program
(MISSWRAP)
Waste Reduction/Waste Minimization
Program
Mississippi Department of Environmental
Quality
Waste Management Program (WMP)
Missouri Department of Natural Resources
Environmental Improvement and Energy
Resources Authority (EIERA)
CONTACT INFORMATION
Contact? George »

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RESOURCES AVAILABLE FOR DETERMINING
BEST MANAGEMENT PRACTICES
CHAPTER 4
EXHIBIT 4-15: STATE PROGRAM INFORMATION
STATE
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
PROGRAM NAME AND SPONSORING
AGENCY
Solid and Hazardous Waste Bureau
Montana Department of Health and
Environmental Sciences

Hazardous Waste Section
Nebraska Department of Environmental
Control
Nevada Energy Conservation Program
Office of Community Services
New Hampshire Pollution Prevention
Program
New Hampshire Department of
Environmental Services
New Jersey Office of Pollution Prevention
New Jersey Department of Environmental
Protection
New Jersey Technical Assistance Program
(NJTAP)
Center for Environmental and Engineering
Sciences
Municipal Water Pollution Prevention
Program
New Mexico Environment Department
Bureau of Pollution Prevention
New York State Department of
Environmental Conservation
New York State Environmental Facilities
Corporation
New York State Department of
Environmental Conservation
CONTACT INFORMATION
Contact? Bsft Potts "" , "" . ..." ' ..""'
Address: Cogswell Building
Helena, MT 59620
Phone: (406)444-2821
CtttttBati 'Tfcii Swgfjs
Address: 301 Centennial Mall South
P.O. Box 98922
Lincoln, NE 68509
Phone: (402) 471-4217
Contest: Cunts 'Fwmftt
Address: Capitol Complex
201 South Fall Street
Carson City, NV 89710
Phone: (702) 885-4420
Contest: V5jK«at R, Perst!) "
Address: 6 Hazen Street
Concord, NH 03301-6509
Phone: (603) 271-2902
CiMitaCji Jaaft Sfefb 
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CHAPTER 4
RESOURCES AVAILABLE FOR DETERMINING
          BEST MANAGEMENT PRACTICES
EXHIBIT 4-15: STATE PROGRAM INFORMATION
STATE
New York
(Continued)
North Carolina
North Dakota
Ohio
Oklahoma
PROGRAM NAME AND SPONSORING
AGENCY
Erie County Office oOf Pollution
Prevention (ECOPP)
Erie County Office Building
Pollution Prevention Program
North Carolina Department of
Environment, Health, and Natural
Resources
North Dakota Department of Health and
Consolidated Laboratories
Ohio Technology Transfer Organization
(OTTO)
Ohio Department of Development
Ohio's Thomas Edison Program
Ohio Environmental Protection Agency
Ohio Department of Natural Resources
Division of Litter Prevention and Recycling
Environmental Health Services
Oklahoma State Department of Health
CONTACT INFORMATION
Contact: Thomas Heresy
Address: 95 Franklin Street
Buffalo, NY 14202
Phone: (716) 858-6231
€»at#*f 0ary Bant
Address: P.O. Box 27687
Raleigh, NC 27611-7687
Phone: (919) 571-4100
Cottwiaat Nell KnaitiTud ' "
T«jri)Umde
Address: P.O. Bos 5520
1200 Missouri Avenue, Room 302
Bismarck, ND 58502-5520
Phone: (703)221-5166
CbtitiMtSi JetfShiefc , >~ ' ^
	 Iwk>« RiKfolf 	
Address: 77 South High Street, 26th Floor
Columbus, OH 43255-0330
Phone: (614) 644-4286
Contacts fiat* Serglvtnd
Address: 77 South High Street, 26th Floor
Columbus, OH 43215
Phone: (614) 446-3887
COX«SC<;ST RflgefJfo-Bnaft*
Mfefcasl W, KsBs? - ,"
Anthony Sassmi
Address: P.O. Box 1049
Columbus, OH 43266-0149
Phone: (614) 644-3469
Confacj: Hsfcn I/. BtfrtbHrt ~ ' '"
Address: Fountain Square Court, Building F2
Columbus, OH 43224-1387
Phone: (614)265-6333
Contacts;. BBefi ^assert ^ % """ , / •.
Mary Jaite Cah>*y > "
Address: 1000 North East 10th Street
Oklahoma City, OK 73117-1299
Phone: (405) 271-7353
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RESOURCES AVAILABLE FOR DETERMINING
BEST MANAGEMENT PRACTICES
CHAPTER 4
EXHIBIT 4-15: STATE PROGRAM INFORMATION
STATE
Oklahoma
(Continued)
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
PROGRAM NAME AND SPONSORING
AGENCY
Pollution Prevention Technical Assistance
Program
Oklahoma State Department of Health
Waste Reduction Assistance Program
(WRAP)
Oregon Department of Environmental
Quality
Pennsylvania Department of Environmental
Resources
Hazardous Waste Reduction Program
Rhode Island Department of Environmental
Management
Center for Waste Minimization
South Carolina Department of Health and
Environmental Control
Waste Management Program
South Dakota Department of Environment
and Natural Resources
Waste Management Program
South Dakota Department of Environment
and Natural Resources
Department of Health and Environment
CONTACT INFORMATION
Contact,-: Chris VBrga 	 '" 	 '.' 	 ~.~ 	
Address: 1000 Northeast 10th Street
Oklahoma City, OK 73117-1299
Phone: (405) 271-7047
w. ' % v, *• % s s
<:ntiMti StfeVfeWfltt*
Address: Joe Foss Building
523 E. Capitol Avenue
Pierre, SD 57501-3181
Phone: (605) 773-3153
Cofitactt James AsSt-. -.•.-.•.•. v •.-.-. •vm
Address: 150 9th Avenue, North
Nashville, TN 37219-3657
Phone: (615) 742-6547
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CHAPTER 4
RESOURCES AVAILABLE FOR DETERMINING
          BEST MANAGEMENT PRACTICES
EXHIBIT 4-15: STATE PROGRAM INFORMATION
STATE
Tennessee
(Continued)
Texas
Utah
Vermont
Virginia
Washington
West Virginia
PROGRAM NAME AND SPONSORING
AGENCY
Waste Reduction Assessment and
Technology Transfer Training Program
(WRATT)
Tennessee Valley Authority
Office of Pollution Prevention and
Conservation
Texas Water Commission
Utah Department of Environmental Quality
Pollution Prevention Division and Solid
Waste Division
Vermont Agency of Natural Resources
Waste Reduction Assistance Program
Virginia Department of Waste Management
Waste Reduction, Recycling and Litter
Control Program
Washington Department of Ecology
Pollution Prevention and Open Dump
Program (PPOD)
West Virginia Department of Natural
Resources
CONTACT INFORMATION
Contact: Carol Bugai* " '"
Address: HB 2G-C
311 Broad Street
Chattanooga, TN 37406
Phone: (615) 751-4574
Cones* Steve H*ltenteeitH$
Address: Mail Code OCH 2B-K
602 West Summit Hill Drive
Knoxville.TN 37902
Phone: (615) 632-2101
<0«frvtvi prf^ftte$^8imsph.t:>t
RK&wt} Crai£
Robert C, StecEEy 	
Address: P.O. Box 13087
Capitol Station
Austin, TX 78711-3087
Phone: (512) 463-7761 .
fff sst t : S,f fff<
CotfUis&t Rpsty kundbwg
Soaia WaDace ' 	
Address: 288 North 1460 West Street
Salt Lake City, UT 841 14-4880
Phone: (801) 538-6170
^oauhjti Qa^&ui&a. " ' ' , , "
Pw) Msrfcowjffc
Address: 103 South Main Street
Waterbury, VT 05676
Phone: (802)244-8702/7831
Contact: Sharon Kenncally-Baxter
Address: Monroe'Building, 1 1th Floor
101 N. 14th Street
Richmond, VA 23219
Phone: (804) 225-2581
^Aff"fff f, f ' , ,,
Contacts'; Sfan Springer
Toy St. 
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RESOURCES AVAILABLE FOR DETERMINING
BEST MANAGEMENT PRACTICES
CHAPTER 4
EXHIBIT 4-15: STATE PROGRAM INFORMATION
STATE
West Virginia
(Continued)
Wisconsin
Wyoming
PROGRAM NAME AND SPONSORING
AGENCY
Generator Assistance Program
West Virginia Department of Natural
Resources
Hazardous Pollution Prevention Audit
Grant Program
Wisconsin Department of Natural
Resources
Solid Waste Management Program
Wyoming Department of Environmental
Quality
CONTACT INFORMATION
'" ' ' ,
;C«ntasSsx Ra*K(¥ BttfftnBn.
" E(at« Mottaw ™*TO
Address: 1356 Hansford Street
Charleston, WV 25301
Phone: (304) 348-4000
NC>Q!tt&fc HiSJAtbftrt. ' / -"" -- *
Address: 123 West Washington Avenue
P.O. Box 7979
Madison, WI 53707
Phone: (608) 266-3075
m# ::*.:
Coateefc i,yjitt?,0
-------
CHAPTER 4
RESOURCES AVAILABLE FOR DETERMINING
          BEST MANAGEMENT PRACTICES
EXHIBIT 4-16. UNIVERSITY AFFILIATED RESOURCES
STATE
Alabama
California
Colorado
Connecticut
Delaware
District Of
Columbia
Florida
PROGRAM NAME AND AFFILIATED
UNIVERSITY
Hazardous Materials Management and
Resource Recovery Program (HAMMARR)
University of Alabama
Environmental Hazards Management
Program
University of California
Center for Waste Reduction Technologies
University of California - Los Angeles
Waste Minimization Assessment Center
(WMAC)
Colorado State University
Industrial Environmental Management (IEM)
Program
Waterbury State Technical College
Delaware Pollution Prevention Program
University of Delaware
The Great Lakes and Mid-Atlantic
Hazardous Substance Research Center
(GLMA-HSRC)
Howard University
Research Center for Waste Utilization
Florida Institute of Technology
Gulf Coast Hazardous Substance Research
Center (GCHSRC)
University of Central Florida
CONTACT INFORMATION
y*- ' ^\
Cofltacfc fi*. 1&ttt$  DaVtS Alfen ' f / mf '
Address: University of California at Los Angeles
Los Angeles, CA 90024
Phone: (213) 206-0300
'*,.'••' "" s V ~
Contact! tfr. KfetiT Edwards
Address: Mechanical Engineering Department
Fort Collins, CO 80523
Phone: (303)491-5317
Contact '"Cyishia fronitldsort '
Address: 750 Chase Parkway
Waterbury, CT 06708-3089
Phone: (203) 596-8703/575-8089
£tmteat: Hsrft Allen ' ' *" '..'
Address: Department of Civil Engineering
Newark, DE 19716
Phone: (302) 451-8522/8449
•. ' ff' ' '
Cpnfsclj Dr> James if< JohncOa, Jr<
Address: Department of Civil Engineering
Washington, DC 20059
Phone: (202) 806-6570
Contact! Edwin Korean ' -'••>>, f,~ ;
Address: 150 West University Boulevard
Melbourne, FL 32901-6988
Phone: (305) 768-8000
See Lamar University, Texas
4-28
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RESOURCES AVAILABLE FOR DETERMINING
BEST MANAGEMENT PRACTICES
CHAPTER 4
EXHIBIT 4-16. UNIVERSITY AFFILIATED RESOURCES
STATE
Florida
(Continued)
Georgia
Illinois
Indiana
Iowa
Kansas
Kentucky
PROGRAM NAME AND AFFILIATED
UNIVERSITY
Center for Training, Research, and
Education for Environmental Occupations
University of Florida
Environmental Science and Technology
Laboratory
Georgia Institute of Technology (Georgia
Tech)
Industry Waste Elimination Research Center
(IWERC)
Illinois Institute of Technology
Hazardous Waste Research & Information
Center (HWRIQ
University of Illinois
Pollution Prevention Program
Purdue University
Iowa Waste Reduction Center
University Of Northern Iowa
Hazardous Substance Research Center
(HSRC)
Kansas State University
Center for Environmental Education and
Training
University of Kansas
Kentucky Partners - State Waste Reduction
Center
University of Louisville
CONTACT INFORMATION
..Contact;'' X>r, Jams* (X Bryant* Jr,
Address: 3900 S.W. 63rd Boulevard
Gainesville, FL 32608-3848
Phone: (904) 392-9570
fitttttfcMi Cdfdf Ifojfcy *
Address: Georgia Tech Research Institute
Atlanta, GA 30332
Phone: (404) 894-3806
Contest; Kr, 'Kenneth E, Noll ,,,,
Address: Pritzker Department of Environmental Engineering ITT
Center
Chicago, IL 60616
Phone: (312) 567-3536
Contact; ,...J>r< £h»vir, Larry fi, Briekson
Address: Durland Hall, Room 105
Manhattan, KS 66506-5102
Phone: (913) 532-5584
Ctmtitte Laid flsjiflgafdnet-
Address: 6330 College Boulevard
Overland Park, KS 66211
Phone: (913) 491-0810
"Contest: Toysft'Stc' Glair ' ~ ~ ""
Address: Ernst Hall, Room 312
Louisville, KY 40292
Phone: (502) 588-7260
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CHAPTER 4
RESOURCES AVAILABLE FOR DETERMINING
          BEST MANAGEMENT PRACTICES
EXHIBIT 4-16. UNIVERSITY AFFILIATED RESOURCES
STATE
Kentucky
(Continued)
Louisiana
Massachusetts
Michigan
PROGRAM NAME AND AFFILIATED
UNIVERSITY
Waste Minimization Assessment Center
University of Louisville

Hazardous Waste Research Center (HWRC)
Louisiana State University

Gulf Coast Hazardous Substance Research
Center (GCHSRC)
Louisiana State University
Technical Extension Service
University of Maryland
Center for Technology, Policy and Industrial
Development
Massachusetts Institute of Technology
Tufts Environmental Literacy Institute
CTELD
Tufts University
The Center for Environmental Management
Tufts University
Toxics Use Reduction Institute
University of Lowell
Waste Reduction and Management Program
(WRMP)
Grand Valley State University School of
Engineering
CONTACT INFORMATION
f f f v" ,• «* *• •, \ j
Contact: Marvte.l'teijielmiafl v '.^...
Address: Department of Chemical Engineering
Louisville, KY 40292
Phone: (502) 588-6357
Cj&ttfiMfe Jkvisif Constant ' '
Address: 3418 CEBA Building
Baton Rouee, LA 70803
Phone: (504) 388-6770
See Lamar University, Texas
£$ffiitc!t! IftffiVis 'Waltaft
Address: Engineering Research Center
College Park, MD 20742
Phone: (301) 454-1941
CteJfftsli JohaEnhrenfyd
Address: E40-241
Cambridge, MA 02139
Phone: (617) 253-7753
dotitect: !&f, AttihrniyCotfesfe "' ,„ 	 > 	
Address: Office of Environmental Programs
474 Boston Avenue, Curtis Hall
Medford, MA 02155
Phone: (617) 627-3452
Contact- t>r, Wilfiam U, Moomaw
Address: 474 Boston Avenue, Curtis Hall
Medford, MA 02155
Phone: (617) 381-3486
•, *. *. f
Contact* Jack LBsfcln.
Address: 1 University Avenue
Lowell, MA 01852
Phone: (508) 934-3275
Contact: J}r, Paul Jotesaa '
Address: 301 W. Fulton, Room 617
Grand Rapids, MI 49504
Phone: (616)771-6750
 4-30
      NPDES Best Management Practices Manual

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RESOURCES AVAILABLE FOR DETERMINING
BEST MANAGEMENT PRACTICES
CHAPTER 4

• STATE
Michigan
(Continued)
Minnesota
Mississippi
Nevada
New Jersey
New Mexico
EXHIBIT 4-16. UNIVERSITY AFFILIATED RESOURCES
PROGRAM NAME AND AFFILIATED
UNIVERSITY
Environmental Engineering Center For
Waste And Waste Management
Michigan Technological University
Pollution Prevention Center for Curriculum
Development and Dissemination
University of Michigan
The Great Lakes And Mid-Atlantic
Hazardous Substance Research Center
(GLMA-HSRC)
University of Michigan
Minnesota Technical Assistance Program
University of Minnesota
Mississippi Technical Assistance Program
And Mississippi Solid Waste Reduction
Assistance Program
Mississippi State University
Gulf Coast Hazardous Substance Research
Center (GCHSRC)
Mississippi State University
Nevada Small Business Development Center
University of Nevada - Reno
Hazardous Substance Management Research
Center
New Jersey Institute of Technology

Waste-Management Education And Research
Consortium (WERC)
New Mexico State University

CONTACT INFORMATION
CoHtaefe Na8 Hatetec., ,.. "' ' %
Address: Environmental Engineering Center
1400 Townsend Drive
Houghton.MI 49931
Phone: (906) 487-2098
€««80jt E*> Oissswy A. Kieteian - s """ """"""'
Address: School of Natural Resources
Dana Building, 430 E. University
Ann Arbor, MI 48109-1115
Phone: (313) 764-1412
fiemiffitt $Jsr , Walter ^feber
Address: Suite 181 Engineering 1-A
Ann Arbor, MI 48109-2125
Phone: (313)763-2274
Ctmfwsfc JBavSa SteHnoas, Cindy MffC«na&s- "N" """" ..
Address: 1315 5th Street, S.E., Suite 207
Minneapolis, MN 55414
Phone: (612) 627-4646
^oafeKiis; J^lfjdftlRft, , -, '"_
,£r> Cwdltes-HiU '"'-""
' "' Dr," June- Caxpenfer
Address: P.O. Drawer CN
Mississippi State, MS 39762
Phone: (601) 325-8454
See Lamar University, Texas
.Coatact^ t&viaBkk
Address: Reno, NV 89557-0100
Phone: (702)784-1717
£o»feet: Or, jfevia 
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CHAPTER 4
RESOURCES AVAILABLE FOR DETERMINING
          BEST MANAGEMENT PRACTICES
EXHIBIT 4-16. UNIVERSITY AFFILIATED RESOURCES
STATE
New York
.
North Carolina
Ohio
Oregon
Pennsylvania
PROGRAM NAME AND AFFILIATED
UNIVERSITY
Hazardous Waste and Toxic Substance
Research and Management Center
Clarkson University

Waste Management Institute
Cornell University

EPA Research Center for Waste
Minimization and Management
North Carolina State University

EPA Research Center for Waste
Minimization and Management
University of North Carolina - Chapel Hill
American Institute For Pollution Prevention
(AIPP)
University Of Cincinnati
RCRA Generator Training Program
University Of Fihdlay
Waste Reduction Assistance Program
Oregon State University
Pennsylvania Technical Assistance Program
(PENNTAP)
Pennsylvania State University
National Technology Applications
Corporation
University of Pittsburgh (NET AC)
CONTACT INFORMATION
$ f •,'•, '• f .,-, ffSf^ %,.".
Contacts •TJiomaa'L, Thei»
Address: Rowley Laboratories
Potsdam, NY 13699
Phone: ^315)268-6542
&«&#
Address: 313 Hollister Hall
Ithaca, NY 14853
Phone: (607) 255-8674
Contacts: £>r, Mtofaaat Qvereash
' , , Dr. Cliff Kaufman
Address: Box 7905
Raleigh, NC 27695-2325
Phone: (919) 515-2325
C»»$M*r tor> "V?iHJaro H» CfeSte
Address: Department of Environmental Science & Engineering
Chapel Hill, NC 27514
Phone: (919) 966-1024
Contact? feflft Bttdr, KBI» WiHiarason
Address: Civil Engineering Department
Apperson 206
Corvallis, OR 97331-2302
Phone: (503)754-2751
Contacts lackGido
Address: 248 Calder Way, Suite 306
University Park, PA 16801
Phone: (814) 865-1914

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RESOURCES AVAILABLE FOR DETERMINING
BEST MANAGEMENT PRACTICES
CHAPTER 4
EXHIBIT 4-16. UNIVERSITY AFFILIATED RESOURCES
STATE
Pennsylvania
(Continued)
Rhode Island
South Carolina
Tennessee
Texas
PROGRAM NAME AND AFFILIATED
UNIVERSITY
Center For Hazardous Materials Research
(CHMR)
University oOf Pittsburgh
Chemical Engineering Department
University of Rhode Island
Hazardous Waste Management Research
Fund
Clemson University
Hazardous Waste Management Research
Fund
University of South Carolina
Waste Reduction Assessment and
Technology Transfer Training Program
University of Tennessee
Waste Minimization Assessment Center
University of Tennessee
EPA Research Center for Waste •
Minimization and Management
Texas A & M University
Gulf Coast Hazardous Substance Research
Center (GCHSRC)
Lamar University
Gulf Coast Hazardous Substance Research
Center (GCHSRC)
University of Houston
CONTACT INFORMATION
Coatactsi ••£*. Sdgar 8«rkey " " " "•"*" '
Roger Price •• ' "' '
Address: 320 William Pitt Way
Pittsburgh, PA 15238
Phone: (412) 826-5320 or (800) 334-CHMR
Costs?!;;. Prsl Stanley J& .Esrntfr - ' ""C"'
Address: Crawford Hall
Kingston, RI 02881
Phone: (401) 792-2443
Contest: Eric Snider, PhtX.'P.E. «
Address: Continuing Engineering Education
P.O. Drawer 1607
Clemson, SC 29633
Phone: (803)656-3308
CCroffciK UottfiDabson " '
Address: Institute of Public Affairs
Gambrell Hall, 4th Floor
Columbia, SC 29208
Phone: (803) 777-8157
Coiitacti CamMfciesff
Address: Center for Industrial Services
226 Capitol Boulevard Building, Suite 606 Nashville,
TN 37219
Phone: (615) 242-2456
:•. Contest: Bit , jKrchaflJ I. fendfttafes
Address: Department of Engineering, Science and Mechanics
3 10 Perkins Hall
Knoxville, TN 37996-2030
Phone: (615) 974-7682
< "•
eonfce't;- Br, Kirk Brown -
Address: Department of Soil and Crop Science
College Station, TX 77843
Phone: (409) 845-5251
eetttetti Ot. Wiitei {Jawiey
Address: P.O. Box 10613
Beaumont, TX 77710
Phone: (409) 880-8707
See Lamar University, Texas
NPDES Best Management Practices Manual
      4-33

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CHAPTER 4
RESOURCES AVAILABLE FOR DETERMINING
          BEST MANAGEMENT PRACTICES
EXHIBIT 4-16. UNIVERSITY AFFILIATED RESOURCES
STATE
Texas
(Continued)
Utah
Wisconsin
PROGRAM NAME AND AFFILIATED
UNIVERSITY
Gulf Coast Hazardous Substance Research
Center (GCHSRC)
University of Texas - Austin
Center For Environmental Technologies
Texas Tech University
Environmental Institute for Technology
Transfer (EITT)
University Of Texas - Arlington
Department of Chemical Engineering
University of Utah
Safety Office
Utah State University
Engineering Professional Development
Program
University oOf Wisconsin - Madison
Solid aAnd Hazardous Waste Education
Center
University of Wisconsin
CONTACT INFORMATION
See Lamar University, Texas
CftntfMtt 3f?f - Johij $U J*$dfottJ
Address: P.O. Box 43121
Lubbock,TX 79409-3121
Phone: (806) 742-1413
CoHtecte: l>r, r, Yielofto A*tttnt& 	 .. .
Address: Box 19050
Arlington, TX 76019
Phone: (817) 273-2300
Contest* JoAnaS. UsW ' " 	 ". 	 *.....".
Address: 3290 MEB
Salt Lake City, UT 84112
Phone: (801) 581-5763
£
-------
BEST MANAGEMENT PRACTICES
PLAN DEVELOPMENT CHECKLIST
APPENDIX A
APPENDIX A — BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT CHECKLIST
' ^"' - ^BEBMFCO«OTEE^- *> " ,! „
I.

II.






III.


IV.




















Has a best management practices (BMP) committee been
created to develop the BMP plan?
Is a discussion of the BMP committee provided in the
BMP plan?
A. Is there a complete list of persons chosen to serve on
the BMP committee in the BMP plan?
B. Are backup people listed with phone numbers?
C. Are other individuals, non-committee members,
available for technical input when necessary?
Has development of the BMP committee as part of an
existing committee performing similar functions been
considered to reduce duplicity of efforts?
Have personnel selections and responsibility designations
been determined to ensure the committee's effective
function?
A. Has a lead committee member been chosen to chair the
BMP committee?
1. Do qualifications of the lead committee member
include managing large projects?
2. Is the lead committee member highly motivated to
develop and implement the BMP plan?
3. Is the lead committee member familiar with all
committee members and their area of expertise?
B. Is the BMP committee made up of company personnel
that are knowledgeable in the BMP areas of concern?
1. Do employees of sufficient expertise comprise the
BMP committee?
2. Are the BMP committee members familiar with all
pertinent Federal, state and local regulations?
C. Do committee members include individuals from the
company structure that are in decision-making
positions so that the committee will be able to make
decisions without spending time waiting for approvals?
D

n

n

n
n

n


n


n

n

n

'n

n

n

a

a



yes

yes

yes

yes
yes

yes


yes'


yes

yes

yes

yes

yes

yes

yes

yes



a

n

a

n
n

a


a


a

a

n

n

a

n

a

n



no

no

no

no
no

no


no


no

no

no

no

no

no

no

no



a

a

6

a
n

a


n


a

n

a

n

a

a

a

a



n/a

n/a

n/a

n/a
n/a

n/a


n/a


n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a
.


NPDES Best Management Practices Manual
        A-l

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APPENDIX A
    BEST MANAGEMENT PRACTICES
   PLAN DEVELOPMENT CHECKLIST
THE BMF €OMMmm''<«dni*e
-------
BEST MANAGEMENT PRACTICES
PLAN DEVELOPMENT CHECKLIST
APPENDIX A
" X ';„ *TliEBMPPOOC1fSTATEMENT ASSESSMENT"
I.
II.


Has a release identification and assessment been performed
to determine the need for specific BMPs and to ascertain
areas to which the BMP plan should focus?
Are details of the release identification and assessment
summarized in the BMP plan?
A. Has existing information been reviewed for relevance
to release identification and assessment (e.g., spill
prevention control and countermeasure plans;
preparedness, prevention, and contingency plans;
storm water pollution prevention plans; and the
NPDES permit application)?
B. Have pollutant sources been adequately identified?
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no P n/a
 NPDES Best Management Practices Manual
        A-3

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APPENDIX A
     BEST MANAGEMENT PRACTICES
    PLAN DEVELOPMENT CHECKLIST
; ^ ' ' f ' xBELEASE IDEMIFICATION AHD ASSOBSSMBm fconinwfi)
1. Has a standard form been developed for recording
currently and potentially released substances on the
site?
a. Are areas noted in which the chemicals are
present or may be present?
i. Are currently released amounts noted?
ii. Are amounts of materials which may be
potentially released also noted?
b. Where potential for release exists, are methods
of control for materials also noted (i.e., dikes,
pumps)?
i. Are controls for potential releases adequate
to discount consideration?
ii. Have factors been assigned based on the
confidence of those measures in controlling
releases?
2. Have maps and drawings been used to describe the
facility?
a. Are outfall locations and drainage patterns shown
on these maps?
i. Is the contour of the land considered in
predicting the direction of flow?
ii. Is the receiving water in the area clearly
shown and named on the maps?
b. Are the plant features (i.e., locations of materials
and pollutant controls) clearly marked on the site
map?
3. Are the locations of outfalls, chemicals and plant
features clearly marked on the site map and
referenced?
4. Has an inspection been conducted to verify
information gathered through data review?
C. Have currently and potentially discharged pollutants
been prioritized based on the amount of discharge and
their hazards to human health and the environment?
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D h/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
A-4
NPDES Best Management Practices Manual

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BEST MANAGEMENT PRACTICES
PLAN DEVELOPMENT CHECKLIST
APPENDIX A
Y • BElMSE NOTIFICATION AND (Contoed) 	 ~










III.
IV.
V.
1. Has the Material Safety Data Sheet for the potential
pollutants been reviewed?
2. Have sources of available exposure limits to protect
human health been reviewed (e.g., NIOSH
Handbook, and the handbook of industrial standards
from ACGIH)?
3. Have health and safety personnel been consulted for
an accurate assessment of potential health risks?
D. Have pathways been identified through which
pollutants found at an area/site might reach
environmental and human receptors?
1. Has the materials inventory been examined in
combination with areas of actual or potential release
to identify release mechanisms and receptor media?
2. Has a description of releases and pathways for each .
pollutant source been prepared?
3. Have all logical alternative pathways been
considered? .
E. Have both actual and potential releases been
prioritized?
1 . Has information about the release been combined
with information about the toxicity or hazards
associated with each pollutant found at the facility?
2. Have actual and potential releases been ranked as to
high, medium, or low probability for both current
and potential releases?
Has the use of non-company representatives with expertise
in conducting a release identification and assessment been
considered?
Is a release identification and assessment conducted prior
to the implementation of a new process or the use of a
new material?
Has materials compatibility been considered in this
evaluation?
D yes P no D n/a
P yes P no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes P no D n/a
D yes D no D n/a.
D yes D no D n/a
D yes D no P n/a
D yes P no D n/a
P yes P no P n/a
P yes P no P n/a
P yes P no P n/a
 NPDES Best Management Practices Manual
         A-5

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 APPENDIX A
     BEST MANAGEMENT PRACTICES
    PLAN DEVELOPMENT CHECKLIST
, ' -; EE1EASE IDEplFtCATJOlsf AKB ASS^SMEOT 
-------
BEST MANAGEMENT PRACTICES
PLAN DEVELOPMENT CHECKLIST
APPENDIX A
"':;: "' ,r wxm HOUSEKEEPING (Centjunea) "" * *:"
a. Are walkways and passageways easily accessible,
safe, and free of protruding objects and
equipment?
B. Is the facility maintained in a clean fashion?
1. Is there any evidence of drippings from equipment
or machinery?
2. Is there evidence of dust in the air or on the floor?
C. Are released materials regularly and easily mitigated?
1. Are recycle and waste disposal areas located close
to waste generation areas to prevent inappropriate
disposal of waste?
a. Where disposal is the current option, have
recycle measures been considered?
b. Is the material involved in small incidents
recovered, rather than cleaned/flushed with
water?
2. Are physical and mechanical cleanup equipment
readily available and properly stored away in
appropriate locations?
3. Are floors and ground surfaces kept dry and clean
by using brooms, shovels, vacuum cleaners, or
cleaning machines?
D. Have procedures been developed to maintain good
housekeeping measures and ensure that all materials
and equipment be returned or replaced in their
designated areas?
1. Are all employees aware of the importance of good
housekeeping through training?
2. Are publicity posters, bulletin boards, and employee
publications used for good housekeeping programs?
3. Are written instructions distributed detailing good
housekeeping procedures?
D
D
D
D
D
D
D
D
D
D
D
D
n
D
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
D no
D no
D no
D no
D no
D no
D no
D no
D no
D no
D no
D no
D no
D no
D
D
n
D
n
n
n
n
n
n
n
n
n
n
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a .
n/a
n/a
 NPDES Best Management Practices Manual
        A-7

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APPENDIX A
    BEST MANAGEMENT PRACTICES
   PLAN DEVELOPMENT CHECKLIST

GOOD HOUSEKEEPING (Continued)


IV.
4. Do shift supervisors and other personnel in
positions of authority uphold the good housekeeping
procedures to demonstrate by example to their
employees?
E. Are there regular housekeeping inspections to check
for good housekeeping problems?
Have materials compatibility issues been considered in the
storage, clean-up, recycle/reuse, and disposal aspects of
the good housekeeping program?
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
PREVENTIVE MAINTENANCE
I.
II.
III.
IV.






Are preventive maintenance (PM) procedures covered in
the BMP plan?
Is the PM program focused on the areas identified during
the release identification and assessment stage as having
the highest potential for environmental releases?
Can the PM program as part of the BMP plan be
incorporated into the existing PM program?
Is the PM plan adequate to prevent environmental releases
resulting form poor maintenance activities?
A. Has an equipment inventory system been set up?
1. Does it provide the equipment location and
identification information?
2. Has equipment been labelled with assigned names
or numbers and identification information?
3. Are index cards, prepared forms or checklists, or
computer programs used to record inventory
information?
4. Is an inventory kept of all maintenance materials
needed?
a. Does this include the materials/parts description,
number, item specifications, ordering
information, vendor addresses and phone
numbers, storage locations, maximum order
quantities, and costs?
D yes D no D n/a
D yes 'D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
A-8
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BEST MANAGEMENT PRACTICES
     DEVELOPMENT CHECKLIST
APPENDIX A
FKEWmrVE MAINTENANCE (Centlauea) '
b. Has a system been considered to track the items
needed to make simple repairs, parts that are
vulnerable to breakage, and parts with long
delivery times or that are difficult to obtain?
c. Is the stockpile of spare parts adequate?
i. Does it include parts that are hard to obtain?
ii. Does it include specialized tools?
B. Have preventive maintenance requirements been
determined (e.g., recommended schedules and
specifications for lubrication, parts replacement,
equipment testing, and/or maintenance of spare parts)?
1. Have manufacturer's references, pamphlets, and
guidebooks been consulted?
2. Have maintenance schedules and specifications for
all equipment been summarized for easy review and
understanding (i.e. , in tabular form or on index
cards for each piece of equipment)?
3. Are maintenance personnel aware of the schedules
and specifications (i.e., by placing on a
blackboard)?
C. Are PM activities conducted at frequencies and
specifications at least as stringent as the manufacturer's
recommendations?
1. Are methods set forth to ensure that maintenance
activities have been conducted?
a. Are there records of preventive maintenance
schedules, tests, inspections, repairs,
lubrications, etc.?
b. Are periodic inspections conducted to determine
if schedules are being met or work is being
completed?
2. Do PM activities include the periodic testing for
structural soundness (e.g., making sure that storage
tanks are solid and strong enough to hold
materials)?
D yes
D yes
D yes
D yes
D yes
D yes
D yes
D yes
D yes
D yes
D yes
D yes
D yes
D no D n/a
D no D n/a
D no D n/a
D no D n/a
D no D n/a '
D no D n/a
D no D n/a
D no D n/a
D no D n/a
D no D n/a
D no D n/a
D no tl n/a
D no D n/a
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        A-9

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APPENDIX A
     BEST MANAGEMENT PRACTICES
    PLAN DEVELOPMENT CHECKLIST
' /< \ ^)FRETENTITE MAINTENANCE (Centimued)'
















.


V.






i.
ii.

in.


rv.

3. Has special attention been given to equipment that
frequently breaks down (i.e., more frequent PM,
making sure that spare parts are always in supply)?
D. Has a system been developed for keeping records of
PM activities?
1. Has a tracking system been developed to monitor
upkeep PM activities and cost?
a. Can the preventive maintenance records be used
in determining whether equipment should be
repaired or replaced?
b. Has a replacement program been considered for
equipment, including vessels and tanks, based on
age and shape of equipment?
2. Is the tracking system well organized and easy to
use?
a. Can specifications and schedules for PM be
easily recognized?
b. Can PM activities be easily verified based on
records?
Is there down-time associated with conducting PM?
A. Are PM activities requiring down-time scheduled to
prevent disruptions to plant operations?
B. Are individuals affected by the down-time notified in
advance?
C - ,„, INSPECTIONS
	 - 	 - 	 > 	 LL,
Is an inspection program addressed in the BMP plan?
Can the inspection program, as part of the BMP plan, be
incorporated into current standard operation procedures?
Is the inspection program focused on the areas identified
during the release identification and assessment stage as
having the highest potential for environmental releases?
Is the inspection program adequate such that current and
potential releases are controlled?
n


n

n

n


n


n

n

n

n
n

n



n
n

n


n

yes


yes

yes

yes


yes


yes

yes

yes

yes
yes

yes

'

yes
yes

yes


yes

D


n

n

n


n


n

n

n

n
n

n



n
n

n


n

no


no

no

no


no


no

no

no

no
no

no


...-:....
no
no

no


no

D


D

n

n


n


n

n

n

n
n

n'



n
n

n


n

n/a


n/a

n/a

n/a


n/a


n/a

n/a

n/a

n/a
n/a

n/a



n/a
n/a

n/a


n/a

A-10
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BEST MANAGEMENT PRACTICES
PLAN DEVELOPMENT CHECKLIST
APPENDIX A
', - ': WSmcnam (Cont*™*®' w \ """
A.
B.




C.




D.


Does the inspection program include the identification
of different inspections with various scopes (e.g.,
security scan, walk-through, site review, BMP plan
oversight inspection, and BMP plan re-evaluation
inspection)?
Is a schedule developed for conducting inspections?
1. Is a comprehensive inspection performed at least
once per year?
2. Are inspection designed to overlap to provide
oversight mechanisms?
3. Are inspection conducted more frequently in areas
of highest concern?
4. Are inspectors alternated and/or is a team approach
used during inspections to conduct a more thorough
review?
Are inspections conducted by qualified personnel (e.g.,
security-, technical personnel, supervisors)?
1 . Are areas reviewed for evidence of pollutants
releases (i.e., spills, discolorations, odor)?
2. Are areas of concern inspected with greater
intensity?
3. Are site maps used to ensure that potentially
released materials and drainage patterns are
evaluated?
4. Is a list of personnel responsible for inspections
indicated in the BMP plan (i.e, foreman, area
supervisor, department manager, safety coordinator,
environmental control coordinator) provided?
Has an inspection form been developed including a
space for a narrative report and/or checklist of areas to
inspect?
1. Are checklists available for each type of inspection,
as necessary?
2. Are narrative discussions provided with each
checklist, as necessary?
n
n
n
n
n
n
n
n
n
n
- n
n
n
n
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
n
D
n
n
n
n
n
n
n
n
n
n
n
n
no
no
no
no
no
no
no
no
no
no
no
no
no
no
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
NPDES Best Management Practices Manual
       A-ll

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APPENDIX A
    BEST MANAGEMENT PRACTICES
   PLAN DEVELOPMENT CHECKLIST






V.
VII

I.
II.
III.
IV.


V.

I.

-* - - fMoiwprn/w* /r f
*-s x ilNbFlid lONa {{Joituxtttea) „„,
E. Are reports prepared summarizing inspection results D yes
and detailing follow-up actions?
1. Is some method of reporting each inspection D yes
provided (i.e., verbal notification, written report)?
2. Are reports reviewed by designated personnel for D yes
the necessity for quick response or remedial action?
Are employees encouraged to periodically conduct D yes
informal visual inspections?
Has the use of non-regulatory support from EPA, States, D yes
or universities when conducting inspections, particularly
the BMP plan oversight and evaluation/re-evaluation
inspections, been considered?
\ * ' V * SECURITY , •
Is a security plan included in the BMP plan? D yes
Can the inspection program as part of the BMP plan be D yes
incorporated into current standard operation procedures?
Does the security program, as part of the BMP plan, focus D yes
on areas identified during the release identification and
assessment stage as having the highest potential for
harmful environmental releases?
Is the security program adequate such that current and D yes
potential releases are controlled?
A. Have the security personnel been considered for use in D yes
the conduct of visual inspections to identify actual or
potential releases of concern?
B. Are security personnel included in the decisions of the D yes
BMP committee?
Is documentation of the security system filed separately D yes
from the BMP plan to prevent unauthorized individuals
from obtaining confidential information?
' EMPLOYEE TRAINING , *
Is there an employee training program relative to the BMP D yes
program?

,
' - - -
D no D n/a
D no D n/a
D no D n/a
D no D n/a
D no D n/a
"°
D no D n/a
D no D n/a
D no D n/a
D no D n/a
D no D n/a
D no D n/a
D no D n/a
;,;~ ,
D no D n/a


















A-12
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BEST MANAGEMENT PRACTICES
PLATS DEVELOPMENT CHECKLIST
APPENDIX A
. '/' r -mtn^K^mmtContinv^ -
II.
III.
IV.











Can the employee training program, as part of the BMP
plan, be incorporated into existing training programs?
Does the employee training program developed as part of
the BMP plan focus on areas identified during the release
identification and assessment stage as having the highest
potential for harmful environmental releases?
Will the employee training program adequately address
changes resulting from the implementation of the BMP
plan?
A. Have the audience and topics for the training been
selected?
1. Have general sessions been planned to introduce the
concept of pollution prevention, discuss the changes
resulting from the BMP plan, and provide training
in the new procedures?
2. Have separate training sessions been considered for
specialized audiences (i.e., inspector, PM, and
process specific training)?
3. Has appropriate speaker selection been taken into
account to ensure effective training?
a. Has the expertise of persons outside the facility
been utilized?
b. Are knowledgeable and enthusiastic speakers
chosen?
B. Have materials been prepared to ensure the conduct of
effective training?
1. Are technically accurate materials prepared for
distribution at the training session?
a. Have references used in the development of this
manual been consulted and utilized in developing
training materials?
b. Are qualified personnel utilized in the
development of materials?
2. Are eyecatching handouts and training tools (i.e.,
overheads, slides, videos) prepared?
D yes D no D n/a
D yes D no CH n/a
D yes D no D n/a
D.yes D no D n/a
D yes n no D n/a
P yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
•D yes D no D n/a
NPDES Best Management Practices Manual
       A-13

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APPENDIX A
    BEST MANAGEMENT PRACTICES
   PLAN DEVELOPMENT CHECKLIST
* ' EMPLOYEE TRAINING (Continued),,,
3. Is ample time provided to develop training
materials?
a. Are research time considerations taken into
account?
b. Are speakers given ample time to prepare for the
presentation, establish timing, and perform a
practice presentation?
C. Are training events conducted to ensure that attendance
is high and information is transferred in the 'most
effective manner possible?
1. Are training events conducted in a positive manner
with enthusiastic and knowledgeable presentations?
2. Was "hands-on" field training and employee
participation incorporated where possible?
3. Are the schedules for the training sessions
announced well in advance of the planned date?
4. Is training mandatory for all employees?
a. Does training include temporary or contractor
personnel as well as permanent facility
personnel?
b. Are new hires immediately instructed in BMPs?
5. Has outside assistance for the conduct of specialized
presentations been considered?
D. Is training repeated when necessary?
1. Are meetings or training sessions held on a regular
basis?
2. Is training repeated after facility changes are
implemented which impact the BMP plan?
3. Are evaluation forms distributed at the end of each
training session to determine both the effectiveness
of sessions and the need for additional training?
D yes D no D n/a

D yes D no D n/a

D yes D no D n/a


D yes D no D n/a


D yes D no D n/a

D yes D no D n/a

D yes D no D n/a

D yes D no D n/a
D yes D no D n/a


D yes D no D n/a
D yes D no D n/a

D yes D no D n/a
D yes D no D n/a

D yes D no D n/a

D yes "D no D n/a


A-14
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 BEST MANAGEMENT PRACTICES
 PLAN DEVELOPMENT CHECKLIST
APPENDIX A
" - . , 'mmmm^mGAmmmmm^ „ *
I. Is there a recordkeeping and reporting program relative to
the BMP program?
II. Can the recordkeeping and reporting program, as part of
the BMP plan, be incorporated into established
recordkeeping and reporting procedures?
III. Will the recordkeeping and reporting program ensure that
records are appropriately kept and reporting is adequately
conducted?
A. Are records developed in a standardized format?
1. Is there a standard format for submitting a report
for internal review on accidental chemical releases
or near-releases?
a. Does this report include adequate information
. such that educated decision can be mad (i.e., the
area of release, volume of release, duration, and
control measures and countermeasures used)?
2. Is there a standard format for reporting to the
appropriate governmental regulating agency spills
that reach the receiving water?
B. Does the BMP plan specify how information is to be
transferred?
C. Is the identified method of communication effective?
1. Has verbal notification been considered to avoid a
paperwork nightmare?
2. Are procedures adequate such that notification for
accidental releases will be immediate?
a. Has a communication flow chart or other
mechanism displaying the committee member's
name, phone number, and responsibility been
developed so that personnel will know precisely
who needs to be notified in the event of a
release?
b. Is a communication system (radio, telephone,
public address system, or an alarm system)
established for accidental chemical releases? -
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
n yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
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      A-15

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APPENDIX A
    BEST MANAGEMENT PRACTICES
   PLAN DEVELOPMENT CHECKLIST
1 ,v ;!i ^OrakxHoaio^^ "'^;-
i. Is the communication system affected by D yes D no
power outages?
ii. Is there a plan warning system that utilizes D yes D no
alarms to alert personnel of an unexpected
release of material?
c. Do alarm systems, such as high-liquid-level D yes D no
alarms, for notification of impending spills
adequately alert plant personnel?
d. Is the alarm system code posted and/or is it D yes D no
familiar to all plant personnel?
e. Are these alarms or signals displayed on a D yes D no
central control panel so that immediate
communication to the supervisor or operator is
achieved?
3. Have procedures been developed for notifying D yes D no
regulatory agencies of environmental releases?
a. Are personnel knowledgeable of responsibilities D yes D no
for reporting accidental chemical releases to
regulatory agencies?
b. Are telephone numbers posted for the appropriate D yes D no
governmental regulating agencies (Federal, state,
and local) which are to be notified in the event of
a release of toxic and hazardous material to the
receiving water?
c. Have designated personnel been identified to D yes D no
coordinate regulatory notification, thereby
ensuring notification does occur?
4. Are personnel who will be receiving records and D yes D no
other notification aware of their responsibilities in
reviewing and responding, if necessary, to the
information?
a. Have review guidelines and response procedures D yes D no
been set forth?
b. Are the reviewing personnel in positions to D yes D no
require the prompt resolution of deficiencies
found during the inspection?
D n/a
D n/a
D n/a
D n/a
D n/a
D n/a
D n/a
D n/a
D n/a
D n/a
D n/a
D n/a
 A-16
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BEST MANAGEMENT PRACTICES
PLAN DEVELOPMENT CHECKLIST
APPENDIX A
r ^€ORI>KEEFMGANI>«EPOIlTING^Coiitaiijed) " ''V
5. Are procedures adequate to ensure that the BMP
committee is aware of the success of the BMP plan
and any changes to or at the facility which warrant
modification of the plan?
D. Has a filing system been developed to maintain the
reports and records?
1. Have procedures been set forth to maintain records
in an organized easily retrievable manner?
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
a. Are materials promptly filed?
b. Are material filed in an organized manner?
2. Are records made, when appropriate, of verbal
communication concerning the BMP plan?
3. Has one employee been chosen as the central
recordkeeper to ensure that designated individuals
review records where appropriate, and corrective
action are identified and pursued?
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
, BMP PLAN EVAMTATIOhf AND DEVALUATION ~ "-
I. Does the facility have a BMP plan in a narrative form?
II. Does the overall program appear to be comprehensive,
understandable, and well organized?
A. Is the BMP plan readily available for review?
B. Does the BMP plan appear to address past, current,
and potential environmental releases?
III. Is there a recognition of the need to periodically review
and update the risk assessment and the facility's BMP plan
as manufacturing conditions and applicable federal and
state regulations change?
A. Is the BMP plan to be comprehensively reviewed at
least once a year?
B. Is there a mechanism to keep the BMP committee
apprised of changes at the facility?
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
D yes D no D n/a
NPDES Best Management Practices Manual
      A-17

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APPENDIX A
    BEST MANAGEMENT PRACTICES
   PLAN DEVELOPMENT CHECKLIST

IV.
V.

VI.
- ^ ?W& PLAH EVALUATION "AW) «&&¥
ALXIATJOK (Continued)
Has a means of measuring the effectiveness of the BMP
committee been considered (e.g., employee surveys, cost
savings, analytical monitoring, reduced waste generation,
etc.)?
Are facility-specific BMPs included in the plan?
A. Are the facility-specific BMPs in the program
satisfactory?
Has a system been devised to continue to evaluate
components and incorporate modifications into the


plan
plan?
D
D
D
D
yes
yes
yes
yes
D
D
D
D
no
no
no
no
D
D
D
D
y
n/a
n/a
n/a
n/a
A-18
NPDES Best Management Practices Manual

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f EXAMPLE FORMS AND CHECKLISTS
                                 APPENDIX B
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                            NPDES Best Management Practices Manual

-------
EXAMPLE FORMS AND CHECKLISTS
                                            APPENDIX B
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NPDES Best Management Practices Manual
                                                     B-3

-------
APPENDIX B
  EXAMPLE FORMS AND CHECKLISTS
             I
             I
             TB
           *a
             1
           II
             •8
B-4
NPDES Best Management Practices Manual

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THEORETICAL DECISION-MAKING
PROCESS FOR BMP PLAN DEVELOPMENT
APPENDIX C
                 APPENDIX C — THEORETICAL DECISION-MAKING
                     PROCESS FOR BMP PLAN DEVELOPMENT
1.0 BACKGROUND
       A small manufacturing company produces decorative hardware by forging, polishing, coating,
and plating hardware sold for use in homes and businesses.  This company operates two shifts per
day, five days per week, and employs 65 persons.  The company has been in operation  since the
early 1950s, and has updated the process equipment and the treatment systems twice, to increase cost
effectiveness.  This plant has experienced a history of National Pollutant discharge Elimination
System (NPDES) permit limits exceedances of chromium and cyanide.

       Through contacts within their trade association, other facilities, suppliers, and State and
Environmental Protection Agency (EPA) inspectors, the owner and plant manager learned of other
similar facilities that dramatically  increased profitability  through the  implementation of best
management practice (BMP) programs. The plant owner and manager believed that such increased
profitability was beyond their capabilities since they believed it would encompass an expensive,
overall plant modernization.  Despite being incredulous,  they investigated the possibilities of
developing and  implementing a similar plan.

       The owner and plant manager worked together to gather information.  They contacted State
and EPA representatives to obtain pamphlets, case studies, and other documents which illustrated the
benefits of pollution prevention.  Additionally, they visited facilities similar to theirs which had
implemented  comprehensive environmental programs.  Based  on  their  review of the  available
information, they decided that the development of a BMP program would help to solve many of their
environmental problems while proving to be profitable.

2.0 PLANNING PHASE
       Much of the information reviewed by the owner and plant manager pointed to the need for
a comprehensive environmental and management approach.  A consistent theme was the importance
of evaluating plant operations from the origination of pollution to  the final disposition.  Several
manuals set forth steps to follow to reach this end.  Generally,  both agreed that the steps seemed
 NPDES Best Management Practices Manual
          C-l

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APPENDIX C
       THEORETICAL DECISION-MAKING
PROCESS FOR BMP PLAN DEVELOPMENT
reasonable and logical.  As such, they formed a BMP committee, developed a policy statement, and
performed a study to evaluate and prioritize current and potential discharges of pollutants.

2.1 FORMATION OF A BMP COMMITTEE
       The owner and plant manager appointed themselves to be members of the committee because
they were interested in making things happen; and since they were in charge,  things would happen.
They would certainly pay attention to the financial impacts of any potential changes. Since the plant
processes were quite simple, they thought that at the most two more persons would be enough to
form the committee.  Several persons were approached about volunteering and few expressed interest
including both shift foreman, and employee from the forging section who had voiced concerns about
plant safety, a company receptionist, and a recently hired worker.

       In evaluating these candidates the owner  immediately  accepted the employee who  was
concerned about safety issues.  This decision was based on the need to both diversify input beyond
management, and to gain a hands-on perspective for evaluating  any changes they might consider.
Past experience had shown that this employee was eager to express her opinions, and was very good
at doing her job.  These qualities seemed  ideal.

       The company receptionist and the new employee were considered but their lack of technical
experience made them less likely candidates for committee members. However, the plant manager
assured both persons that they would take and active role in the BMP plan implementation.

       There was some hesitation about  adding both shift foremen as this  might be loading the
committee with too many "chiefs"and not enough"Indians". The owner and plant manager discussed
the qualifications of both foremen and decided that the foreman with seniority was better qualified
to act  as the BMP  committee  member since he had been around when they tried to fine tune
processes and waste handling in the past.  The owner and plant manager felt that including this
foreman, in lieu of the other, would make sure that past mistakes weren't repeated.
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THEORETICAL DECISION-MAKING
PROCESS FOR BMP PLAN DEVELOPMENT
APPENDIX C
       Having made this decision, the membership of the committee was set. The owner assigned

the plant manager as the committee leader since he seemed the most plausible candidate.  He then

gave the plant manager the full reign is assigning activities and in moderating .the committee.


       The plant manager roughed out a schedule of activities and a list of responsibilities, and held

a committee meeting to discuss BMP plan development.  Generally,  it was difficult to keep the
committee focussed since all committee members seemed to have different agendas. Safety concerns,

logistical problems,  and financial  considerations were all voiced.  The  plant manager assured

everyone that evaluation of these problems would be addressed in the BMP plan and proceeded to

introduce roles and responsibilities:

              The owner was assigned the task of developing the  policy statement and informing
              employees of this initiative.  The plant manager felt that the owner would be the most
              credible of the BMP committee members in formulating company policy.

              All four  committee  members were  responsible  with performing  the release
              identification and assessment since this would involve a significant effort.

              The foreman  was   delegated  primary responsibility  of  developing  the  good
              housekeeping program, with assistance from the plant manager.  The plant manager
              believed that the foreman was in the primary position to assure that  the good
              housekeeping program was implemented.  Additionally, the plant manager felt that
              together, he and the foreman would be more inclined to make logistically  sound
              decisions which would better assist them in meeting production schedules.

              The employee with safety concerns was  assigned with developing the preventive
              maintenance and recordkeeping and reporting portions of the BMP plan.  The plant
              manager felt that these programs involved and eye for detail and good organization
              skills, which had been demonstrated by this employee in the past.

              The owner felt obligated to address all security related issues since she had been
              responsible for addressing this  area in the past and since  security was somewhat
              outside the scope of any of the committee members'job .descriptions.

              The plant manager assigned  himself with the development of the inspection and
              employee training program.   He felt that oversight of operations was primarily his
              responsibility and that he would best be able to evaluate  their  current inspection
              program. He also was familiar with all employees at the plant, and was currently in
              charge of the employee training program, thus making him the  best candidate for
              integrating BMP plan training into the existing program.
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           C-3

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APPENDIX C
       THEORETICAL DECISION-MAKING
PROCESS FOR BMP PLAN DEVELOPMENT
       The plant manager established a schedule for conducting weekly meetings to discuss plan
development progress.  He also provided the foreman and the employee with the information that
had led to BMP plan development and development and suggested that they read the information
prior to the next meeting.  At the close of the meeting, the plant manager felt satisfied with the
progress, but  wished  that he had provided  the BMP plan-related documents to  the committee
members sooner, thus avoiding many of the questions that they had.

2.2 The BMP Policy Statement
       The committee members decided to introduce the BMP program and the pollution prevention
objectives by holding two meetings-one during each shift-which were open to all employees.  The
committee reasoned that this would help gain support from employees, and would make sure that
employees were aware of the forthcoming changes and had a chance to take an active role in the
company's success.  They had developed a policy statement with some basic objectives, but felt that
is was important to include employees in the development of the policy objectives.  As this was a
small facility,  they decided to hold a ground meeting during each  of the two shift's lunch hours.
They  offered free refreshments to increase voluntary attendance.

       The owner created draft policy statement which was introduced in the group meetings.  This
statement read:  "The objectives of the Best Management Practices Program at Sanchez Hardware
are to reduce or eliminate pollutants in the wastewater discharges and increase profit."  The meeting
was facilitated by the owner.  She  spoke on what pollution prevention was  all  about  and how
pollution prevention activities could increase the profitability of the company such that everyone in
the company would benefit with increased salaries, as well as company stability and growth.  She
described how  some of the pollution prevention activities would change the way everyone ordinarily
does their jobs.  She then opened the meeting up for comments and questions.

       The committee members were taken aback by the outpouring of concerns and ideas offered
by the employees.  The meetings had to be cut off due to tome limitations, but it was agreed that
these  meetings would be held again in the very near future.  During these initial two meetings,
employees expressed a number of concerns including:
C-4
   NPDES Best Management Practices Manual

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THEORETICAL DECISION-MAKING
PROCESS FOR BMP PLAN DEVELOPMENT
APPENDIX C
              Two employees complained that working conditions were unsafe due to spills on the
              floors not being cleaned up immediately, as well as safety of some of the solvents and
              chemicals used in the plant. One person was concerned that the ozone layer may be
              depleted as a result of their solvent use.

              Some employees thought that time and money could be saved by relocating raw
              materials storage.  It was considered to be too far away from the process area, and
              not set up in an organized fashion.

              Other employees were concerned that the so-called pollution prevention initiatives
              would make it hard for them to meet their quotas, and shipment dates, and that they
              weren't interested in changing operations.
       The owner promised that the members of the BMP committee would address each of the

issues raised at the open meetings. She requested that everyone feel free to provide information to

the members of the committee regarding areas of the plant that should be closely evaluated for the

need for pollution prevention activities.   For this  purpose, the owner  discussed establishing a

suggestion box in the employees' lounges.


       After these meetings, the members of the BMP committee added to the policy statement to

reflect the concerns of the employees.  It became:   "The objectives of the  Pollution Prevention

Program at Sanchez Hardware are to reduce or eliminate pollutants released to the environment, to

increase profits, and to protect the worker's health and safety."
 NPDES Best Management Practices Manual
           C-5

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BIBLIOGRAPHY
APPENDIX D
                           APPENDIX D — BIBLIOGRAPY
CHAPTER 2 REFERENCES

J.  Cleary, J. Kehrberger, and  C.  Stuewe,  "A Review  of the Criteria for Evaluating a BMP
Program," Control of Hazardous Material Spills, Proceedings of the 1980 National Conference on
Control of Hazardous Material Spills,  1980.

NPDES Best Management Practices Guidance Document,  EPA Industrial Environmental Research
Laboratory, December 1979.

NPDES Best Management Practices Guidance Document, EPA Office of Water Enforcement and
Permits, June 1981.

Waste Minimization Opportunity Assessment Manual (EPA 625 7-88 003), EPA Hazardous Waste
Engineering Research Laboratory, July 1988.

C. Stuewe, J. Cleary, H. Thron, Best Management Practices for Control of Toxic and Hazardous
Materials, Undated.

H. Thron, P. Rogoshewski, "Best Management Practices:  Usefull Tools  for Cleaning Up," 1982
Hazardous Materials Spills Conference, Undated.

Plant Maintenance Program  Manual of Practice OM-3,  Water  Pollution Control Federation,
Alexandria, VA, 1982.

Handbook for Using a Waste-Reduction Approach to Meet Aquatic Toxicity Limits, North Carolina
Department of Environment, Health, and Natural Resources, Pollution Prevention Program, May
1991.

Storm Water Pollution Prevention for Industrial Activities, EPA Office of Wastewater Enforcement
and Compliance, April 1992.

Facility Pollution Prevention Guide, EPA Office of Solid Waste and Risk Reduction Engineering
Laboratory, Undated.
CHAPTER 3 REFERENCES
            i
       METAL FINISHING TEST REFERENCES

       Industrial Pollution Prevention Opportunities for the 1990s (EPA 600 8-91 052), EPA Office
       of Research and Development, August 1991.  .         -     '
NPDES Best Management Practices Manual
          D-l

-------
APPENDIX D
                        BIBLIOGRAPHY
       Development Document for Effluent Guidelines New Sources Performance Standards for the
       Metal Finishing Category, EPA Office of Water Regulation and Standards, June 1983.

       METAL FINISHING TABLE REFERENCES

       Fl    Development Document for Effluent Guidelines New Sources Performance Standards
             for the Metal Finighing Category, EPA Office of Water Regulation and Standards,
             June 1983.

       F2    G.  Hunt,  et al., Accomplishments of North Carolina Industries-Case Summaries,
             North Carolina Department of Resources and Community Development, January
             1986.

       F3    Waste Reduction Assistance Program (WRAP) On-Site Consultation Audit Report:
             Electroplating Shop, Alaska Health Project, April 1989.

       F4    The Robbins Company: Wastewater Treatment and Recovery System, A Case Study,
             Office  of Safe Waste Management, Massachusetts Department of  Environmental
             Management, Undated.

       F5    A Study of Hazardous Waste Source Reduction and Recycling in  Four Industry
             Groups in New Jersey, Case Study D6, Jersey Hazardous Waste Facilities Siting
             Commission,  April 1987.

       F6    Compendium  on Low and Non-Waste Technology, United Nations  Economic and
             Social Counsel, 1991.

       F7    Guides to Pollution Prevention, The Fabricated Metal Industry (EPA 625/7-90/006),
             EPA Office of Research and Development, July 1990.

       F8    Metal Recovery: Dragout Reduction, Case History,  Minnesota Tehcnical Assistance
             Program, University of Minnesota, September 1988.

       F9    D.  Huisingh, L. Martin,  H. Hilger, N. Seldman, Proven Profits from Pollution
             Prevention: Case Studies in Resource Conservation and Waste Reduction, Institute
             for Local Self-Reliance, Washington, D.C., 1985.

       F10   R.  Schecter,  G.  Hunt, Case Summaries of Waste  Reduction by Industries in the
             Southeast,  North Carolina Department of  Natural  Resources and  Community
             Development, July  1989.

       Fll   [To be located]

       F12   Case Studies of Existing Treatment Applied to Hazardous Waste Banned from Landfill
             Phase II, Summary of Waste Minimization Case Study Results, EPA Hazardous Waste
             Engineering Research Laboratory, October 1986.
D-2
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BIBLIOGRAPHY
APPENDIX D
       F13   Preliminary Report: Phase 7 Source Reduction Activities, Southeast Platers Project,
             Massachusetts  Department  of Environmental Management Office of Safe  Waste
             Management, July 1988.

       F14   CALFRAN  International,  Inc., "Waste  Reduction  and Minimization by  Cold
             Vaporization,"  Process Technology '88, The Key to Waste Minimization, Volume 2,
             August 15-18,  1988, held in Sacramento, California.

       F15   Wastestream  Segregation,  Recycling,  and  Treatment  from  an  Electroplating
             Operation, Keysoton Plating,  Hazardous Waste Minimization, A Resource Book for
             Industry, San Diego County Department of Health Services, Undated.

       F16   Pollution Prevention Case Studies Compendium (EPA/600/R-92/046), EPA Office of
             Research and Development, April 1992.

       F17   Waste Minimization Issues and Options Volume II (EPA/530-SW-86-04), EPA Office
             of Solid Wasted and Emergency Response, October 1986.

       F18   Handbook for Using a Waste-Reduction Approach to Meet Aquatic Toxicity Limits,
             North Carolina Department of Environment, Health, and Natural Resources Pollution
             Prevention Program, 1991.

       F19   Industrial Pollution Prevention Opportunities for the 1990s (EPA 600 8-91052), EPA
             Office of Research and Development, August 1991.

       F20   Addendum to Speakers' Notes,  The University of Tennessee Center for Industrial
             Services, March 13, 1991.

       OCPSF MANUFACTURING TEXT REFERENCES

       Industrial Pollution Prevention Opportunities for the 1990s (EPA 600 8-91 052), EPA Office
       of Research and Development, August 1991.

       Development Document for Effluent Limitations Guidelines and Standards for the OCPSF
       Point Source Category (EPA 440/1-87/009), EPA Office of Water Regulations and Standards,
       October 1987.

       Guides to Pollution Prevention, The Paint Manufacturing Industry (EPA 625/7-90/005), EPA
       Office of Research and Development, June 1990.

       OCPSF MANUFACTURING TABLE REFERENCES

       Cl    G. Hunt, R. Schecter, Accomplishments of North Carolina Industries-Case Studies,
             North Carolina Department of Resources and Community Development, January
             1986.
NPDES Best Management Practices Manual
          D-3

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APPENDIX D
                        BIBLIOGRAPHY
       C2    Process Technology and Flowsheets, Chemical Engineering, McGraw Hill Publishing
             Company, New York, New York, 1979.

       C3    Pollution Prevention Guidance Manual for the Dye Manufacturing Industry, EPA
             Office of Pollution Prevention, Undated.

       C4    Achievements in Source Reduction and Recycling for Ten Industries  in the  United
             States, EPA Office of Research and Development, September 1991.

       C5    D. Huisingh, L.  Martin, H.  Hilger,  N.  Seldman, Proven  Profits from Pollution
             Prevention:  Case Studies in Resource Conservation and Waste Reduction, Institute
             for Local Self-Reliance, Washington, D.C., 1985.

       C6    D. Sarokin, W. Muir, C. Miller, S. Sperber, Cutting Chemical Wastes:  What 29
             Organic Chemical Plants are Doing to Reduce Hazardous Wastes, Inform, Inc., New
             York, New York, 1985.

       C7    Waste Minimization Issues and Options Volume II (EPA/530-SW-86-04), EPA Office
             of Solid Waste and Emergency Response, October 1986.

       C8    Handbook for Using a Waste-Reduction Approach to Meet Aquatic Toxicity Limits,
             North Carolina Department of Environment, Health, and Natural Resources Pollution
             Prevention Program, 1991.

       TEXTILE MANUFACTURING TEXT REFERENCES

       G. Hunt, R. Schecter, Accomplishments of North Carolina Industries-Case Studies, North
       Carolina Department of Resources and Community Development, January 1986.

       Recycling Zinc in Viscose Rayon Plants by Two-Stage Precipitation, EPA, Undated.

       Industrial Pollution Prevention Opportunities for the 1990s (EPA 600 8-91 052), EPA Office
       of Research and Development, August 1991.

       TEXTILE MANUFACTURING TABLE REFERENCES

       Tl    D. Huisingh, L.  Martin, H.  Hilger,  N.  Seldman, Proven  Profits from Pollution
             Prevention:  Case Studies in Resource Conservation and Waste Reduction, Institute
             for Local Self-Reliance, Washington, D.C., 1987.

       T2    Textile Oil Reclamation and Water Re-Use, Osmonics, Inc., Undated.

       T3    Compendium on .Low and Non-waste Technology, United Nations Economic and
             Social Counsel, 1991.

       T4    B. Smith, "Pollution Source Reduction (Part-II)" American Dyestuff Reporter, 1989.
D-4
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BIBLIOGRAPHY
APPENDIX D
       T5    B. Handa,  "Wastewater  Management  in a Synthetic Textile Industry", All  India
             Workshop on Environmental Management of Small Scale Industries, July 22-23,
             1989.                                                            .

       T6    H. Hiajue et al., "A Study of Reuse of Water in a Woolen Mill," Purdue University
             Conference on Industrial  Waste Treatment, Undated.

       T7    L. Paneerselvam, Director (PC), National Productivity Council, Lodhi Road, New
             Delhi 110 003.

       T8    M. Sharma, Chief Chemist, Century Textiles and Industries Limited, Worli, Bombay
             400 025, India.

       T9    H. Asnes,  "Reduction in .Water Consumption in the Textile Industry," IFATCC
             Conference, London, 1978.

       T10   S. Haribar, Senior Executive President, GRASIM, India, UNEP Workgroup, Paris.

       Til   Achievements in Source Reduction and Recycling for Ten Industries in the United
             States, EPA Office of Research and Development, September 1991.

       T12   Waste Minimization Issues and Options Volume II (EPA/530-SW-86-04), EPA Office
             of Solid Waste and Emergency Response, October 1986.

       T13   Handbook for Using a Waste-Reduction Approach to Meet Aquatic Toxicity Limits,
             Pollution Prevention Program of the North Carolina Department of Environment,
             Health, and Natural Resources, 1991.

       T14   Industrial Pollution Prevention Opportunities for the 1990s (EPA 600 8-91052), EPA
             Office of Research and Development, August, 1991.

       T15   Waste Identification and Minimization: A Reference Guide, 1987.

       PULP AND PAPER MANUFACTURING TEXT REFERENCES

       Estimates of Waste Generation by the Pulp and Paper Industry, Draft Report,  EPA Office
      . of Solid Waste, August 12, 1987.

       The Product is the Poison: The  Case for a Chlorine Phase-Out, Greenpeace, Washington,
       D.C., 1991.

       USEPA/Paper Industry Cooperative Dioxin Study, The 104 Mill Study Summary Report, EPA
       Office of Water  Regulations and Standards, July 1990.
 NPDES Best Management Practices Manual
          D-5

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APPENDIX D
                       BIBLIOGRAPHY
       Background Document to the Integrated Risk Assessment for Dioxins and Furans from
       Chlorine Bleaching in Pulp and Paper Mills (EPA 560/5-90-014), EPA Office of Toxic
       Substances, July 1990.

       PULP AND PAPER MANUFACTURING TABLE REFERENCES

       PI    Compendium on Low- and Non-Waste Technology, United Nations Economic and
             Social Counsel, 1991.

       P2    Pollution Prevention: Strategies for Paper Manufacturing, University of Pittsburgh,
             Center for Hazardous Materials Research, Undated.

       P3    "Memorandum:  Strategy for the Regulation of Discharges of PHDDs and PHDFs
             from Pulp  and Paper Mills to Waters of the United States," EPA Office of Water,
             May 21, 1990.

       P4    Summary of Technologies for the Control and Reduction of Chlorinated Organics
             from the Bleached Chemical Pulping Subcategories of the Pulp and Paper Industry,
             EPA Office of Water Regulations and Standards and Office of Water Enforcement
             and Permits, April 1990.

       P5    M.  Sittig, Pulp  and  Paper Manufacture, Energy Conservation  and Pollution
             Prevention, Noyes Data Corporation, Park Ridge, NJ, 1977.

       P6    Summary of Technologies for the Control and Reduction of Chlorinated Organics
             from the Bleached Chemical Pulping Subcategories of the Pulp and Paper Industry,
             EPA Office of Water Regulations and Standards and Office of Water Enforcement
             and Permits, April 27, 1990.

       PESTICIDES FORMULATION TEXT REFERENCES

       Case Studies in Waste Minimization, Government Institutes, Inc., Rockville, MD,  October
       1991.

       Industrial Pollution Prevention Opportunities for the 1990s (EPA 600 8-91 052), EPA Office
       of Research and Development, August  1991.

       D. Sarokin, W. Muir, C. Miller, S. Sperber, Cutting Chemical Wastes: What 29  Organic
       Chemical Plants are Doing to Reduce  Hazardous Wastes,  Inform, Inc., New York, New
       York,  1985.

       PESTICIDES FORMULATION TABLE REFERENCES

       SI    Case Studies in Waste Minimization,  Government Institutes, Inc., Rockville, MD,
             October 1991.
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BIBLIOGRAPHY
APPENDIX D
       S2     "Fort Bliss' Hazardous Waste Minimization Plan," Department of Defense Report on
             the Status ofDOD Hazardous Waste Minimization, March 31, 1988.

       S3    Guides to Pollution Prevention, The Pesticide Formulating Industry (EPA  626/7-
             90/004), EPA Risk Reduction Engineering Laboratory and Center for Environmental
             Research Information, February 1990.

       S4    R. Schecter, G. Hunt, Case Summaries of Waste Reduction by  Industries in  the
             Southeast,  North  Carolina Department of Natural  Resources  and Community
             Development, July 1989.

       S5    Hazardous  Waste Minimization Manual for Small Quantity Generators, Center for
             Hazardous Materials Research, October  1989.

       PHARMACEUTICAL MANUFACTURING TEXT REFERENCES

       D. Sarokin, W. Muir, C.  Miller, S. Sperber, Cutting Chemical Wastes:  What 29 Organic
       Chemical Plants are Doing to Reduce Hazardous Wastes, Inform, Inc.,  New York, New
       York, 1985.

       Industrial Pollution Prevention Opportunities for the 1990s (EPA 6008-91 052), EPA Office
       of Research and Development, August 1991.

       Guides to Pollution Prevention:  the  Pharmaceutical Industry (EPA 625/7-91/017), EPA
       Office of Research  and Development,  October 1992.

       Preliminary Data Summary for the Pharmaceutical Manufacturing Point  Source Category
       (440/1-89/084), EPA Waster Regulations and Standards, September 1989.

       PHARMACEUTICAL MANUFACTURING TABLE REFERENCES

       HI    Guides to Pollution Prevention:  the Pharmaceutical Industry (EPA 625/7-91/017),
             EPA Office of Research and Development, October 1992.

       H2    D. Huisingh,  L. Martin, H. Hilger,  N. Seldman, Proven Profits from Pollution
             Prevention:  Case  Studies in Resource Conservation and Waste Reduction, Institute
             for Local Self-Reliance, Washington, D.C., 1985.

       H3    A Study of Hazardous Waste Reduction  in  Four Industrial Groups in New Jersey,
             New Jersey Hazardous Waste Facilities Siting Commission, April  1987.

       H4    [To be located]

       H5    M. Melody, "Reducing the Waste in Wastewater", Hazmat World, August 1992.
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APPENDIX D
                       BIBLIOGRAPHY
       PRIMARY METALS MANUFACTURING TEXT REFERENCES

       Industrial Pollution Prevention Opportunities for the 1990s (EPA 600 8-91 052), EPA Office
       of Research and Development, August 1991.

       Guidance Manual for Iron and Steel Manufacturing Pretreatment Standards, EPA Office of
       Water, September 1985.

       PRIMARY METALS MANUFACTURING TABLE REFERENCES

       Ml    D.  Huisingh, L.  Martin, H.  Hilger,  N.  Seldman,  Proven Profits from Pollution
             Prevention:  Case Studies in Resource Conservation and Waste Reduction, Institute
             for Local Self-Reliance, Washington, D.C., 1985.

       M2    H.  Nash, "Pretreatment and Recycle at Wire Rope Manufacture,"  Sixteenth Mid-
             Atlantic Industrial Waste Conference,  Undated.

       M3    Catalogue of Successful Hazardous Waste Reduction/Recycling Projects,  Energy
             Pathways, Inc. and Pollution  Probe Foundation, prepared for Industrial Programs
             Branch, Conservation and Protection Environment Canada," March 1987.

       M4    "Recycling at California Steel  Industries, Inc., Acid Wastes Become Profits." Case
             Studies in Waste Minimization, Government Institutes, Inc., Rockville, MD, October
             1991.

       M5    Compendium on Low- and Non-Waste Technology, United  Nations Economic and
             Social Counsel, 1991.

       M6    I. Rulkens, "Wastewater Problems in the Metal Industry: Results of Interviews in
             48  Companies,"  TNO, Maatschappelijke Technologic, Postbus 342,  7300 AH,
             Apeldoorn, Netherlands.

       M7    M. Stein, "Evaluation of the  Chemelec Metal Recover^ System as Applied to the
             Recovery of Zinc from Rinse Waters Following an Acid Pickle on a Barrel Zinc
             Plating Line,"  RIVM, Dept.  LAE, Anthonie  Van Leeuwenhoeklaan 1, Postbus 1,
             Bilthoven, Netherlands.

       M8    M. Rachlitz, Vandig affedtning af stl inden  malebehandling, Milig ~ styrelsen,
             1990.

       M9    [Source to be located]

       M10  Aluminum, Copper, and Nonferrous Metals Forming and Metal Powders Pretreatment
             Standards, A Guidance Manual, EPA Office of Water, December 1989.
D-8
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 BIBLIOGRAPHY
                                                                         APPENDIX D
       Mil   Development Document for Effluent Limitations Guidelines and Standards for the
              Aluminum Forming Point Source Category (EPA 440/1-82/073-b), EPA Office of
              Water and Waste Management, November 1982.

       M12   Guidance Manual for Iron and Steel Manufacturing Pretreatment Standards, EPA
              Office of Water, September 1985.

       M13   Environmental Research Brief, Waste  Minimization Assessment for an Aluminum
              Extrusions Manufacturer  (EPA 600/S-92/018), EPA Risk Reduction Engineering
              Laboratory,  April  1992.

       M14   Pollution Prevention Case Studies Compendium (EPA/600/R-92/046), EPA Office of
              Research and Development, April 1992.

       M15   New York State Waste Reduction Guidance Manual, New York State Department of
              Environmental Conservation, March 1989.

       PETROLEUM REFINING TEXT REFERENCES

       The Generation and Management of Wastes and Secondary Materials:  1987-1988, American
       Petroleum Institute,  Washington, D.C., June 1992.

       Industrial Pollution Prevention Opportunities for the 1990s (EPA 600 8-91052), EPA Office
       of Research and Development, August 1991.

       Development Document for Effluent Limitations Guidelines and Standards for the Petroleum
       Refining Point Source Category  (EPA 440/1-82/014), EPA Office  of Water and Waste
       Management, October  1982.

       Waste Minimization  in the Petroleum Industry:  A Compendium  of Practices, American
       Petroleum Institute, Washington, D.C., November 1991.

       PETROLEUM REFINING TABLE REFERENCES

       Rl    Development Document for Effluent Limitations  Guidelines and Standards for the
             Petroleum Refining Point Source Category (EPA 440/1-82/014), EPA Office of Water
             and Waste Management, October 1982.

       R2    Generation and Management of Wastes and Secondary Materials: Petroleum Refining
             Performance 1989 Survey, American Petroleum Institute, Washington, D.C., June
             1992.

       R3    Waste  Minimization  in the Petroleum Industry:  A Compendium of Practices,
             American Petroleum Institute,  Washington, D.C., November 1991.
NPDES Best Management Practices Manual
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APPENDIX D
                      BIBLIOGRAPHY
      INORGANIC MANUFACTURING TEXT REFERENCES

      Industrial Pollution Prevention Opportunities for the 1990s (EPA 600 8-91052), EPA Office
      of Research and Development, August 1991.

      Development Document for Effluent Limitations Guidelines and Standards for the Inorganics
      Chemical Manufacturing Point Source Category (EPA-440/l-80/007-b), EPA Office of Water
      and Waste Management, June 1980.

      INORGANIC MANUFACTURING TABLE REFERENCES

      Nl    Development Document for Effleunt Limitations Guidelines and Standards for the
             Inorganice Chemical Manufacturing Point Source Category (EPA-440/l-80/007-b),
             EPA Office of Water and Waste Management, June 1980.

      N2    Waste Minimization Issues and Options Volume II (EPA/530-SW-86-04), EPA Office
             of Solid Waste and Emergency Response, October 1986.
CHAPTER 4 REFERENCES

NIJS 1992 Catalog of Products and Services, U.S. Department of Commerce, Springfield, VA,
October 1991.

Access EPA/IMSD-91-100, EPA Office of Administration and Resources Management, 1991.

M. Melody, R. McNulty, "Tap into Resources: technical Assistance Programs Further Industry's
Efforts", Hazmat World, The Magazine for Environmental Management, May 1992.

Pollution Prevention Resources and Training Opportunities in 1992 EPA/560/8-92-002, EPA Office
of Pollution Prevention and Toxics and Office of Environmental Engineering  and Technology
Demonstration, January 1992.

ICPIC, International Cleaner Production Information Clearinghouse, United Nations Environment
Programme in cooperation with EPA, Undated.

PPIC, Pollution Prevention Information  Clearinghouse, EPA Office of Pollution Prevention and
Office of Environmental Engineering and Technology Demonstration, April 1990.

 CWRT WasteNotes, Center for Waste Reduction Technology, Summer 1992.

SWICHMemo, Solid Waste Information Clearinghouse, Undated.

 Waste Reduction Institute for Training and Applications Research, WRITAR, Undated.
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