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CHAPTER 5
GATHERING APPROPRIATE DATA
AND INFORMATION
Typical Operations and
Associated Waste
Streams
Receiving Areas (e.g.,
loading docks)
• Packaging materials
• Off-spec materials
• Damaged containers
• Spill residue
• Transfer line leaking or
dumping
Material and Product
Storage Areas (e.g., tanks,
warehouses, drum storage
yards, storerooms)
• Tank bottoms
• Off-spec and excess
materials
• Spill residue
• Leaking pumps, valves,
and pipes
• Damaged containers
• Empty containers
Production Areas (e.g.,
me/ting, curing, baking,
distilling, washing, coating
machinery, formulating)
• Wash water
• Solvents
• Still bottoms
• Off-spec products
• Catalysts
• Empty containers
• Sweepings
5.1 Introduction
Once goals have been established, the PPOA team
has a better idea of what information needs to be collected
during the assessment. For instance, to reach the goal of
reducing air emissions by 20 percent, the team should first
inventory sources of air emissions. Specific objectives for
meeting the goals can be developed based on the results of
the emissions inventory, for example:
• Finding substitutes for high VOC coatings
• Replacing gasoline powered vehicles with electric or
natural gas powered vehicles
• Replacing solvent-based degreasers with aqueous
cleaners.
The purpose of preparing a waste generation baseline is to
build a comprehensive picture of the materials usage patterns
and environmental impacts associated with the facility pro-
cess or activity.
Whether preparing a PPOA or a program plan, the
team must construct a comprehensive picture of the facility
or process. The following questions need to be addressed:
1. What materials enter the facility process and in what
volumes?
2. What operations occur at the facility process?
3. What wastes are generated as a result of the operations?
4. What other impacts does the facility process have on
the environment?
5. How are wastes and emissions managed?
74
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Gathering Appropriate Data and Information
6. What procedures have been established to prevent
accidental releases?
7. What pollution prevention measures has the facility
process already taken?
Developing a baseline is like preparing a material
balance: the goal is to track the flow of materials as they
enter the facility, are used in processes, and exit the facil-
ity as waste. Although in practice it may prove impos-
sible to develop an accurate quantifiable material balance,
the concept can still serve as a useful tool for understand-
ing the facility as a whole. A list of data sources that
should be compiled before a site visit is presented in
Table 7.
5.2 Preparing the Baseline
What kind of information should be collected for a
facility PPOA baseline? The information collected de-
pends to a large extent on the particular goals and objec-
tives. At a minimum, however, the data collected should
include the following:
Raw Materials
• Purchase cost, weight, hazardous or nonhazardous
nature, and volume of procured raw materials
• Inventory practices.
Waste Streams and Environmental Releases
• Volume and characteristics of hazardous wastes gen-
erated, waste management and disposal costs
• Volume and characteristics of solid wastes gener-
ated, waste management and disposal costs
• Volume and characteristics of air emissions and
waste management costs
• Volume and characteristics of wastewater discharges
and management costs
• Other releases and environmental impacts.
The baseline is like a
material balance for
evaluating materials
throughout.
The baseline contains:
• Raw materials
• Waste streams and
environmental releases
• Utilities
• Production.
75
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Chapter 5
TABLE 7. DATA SOURCES FOR FACILITY INFORMATION
Regulatory Information:
• Waste shipment manifests
• Emission inventories
• Biennial hazardous waste reports
• Waste, wastewater, and air emissions analyses,
including intermediate streams
• Environmental audit reports
• Permits and/or permit applications
• Form R for SARA Title III Section 313
Process Information:
• Process flow diagrams
• Design and actual material and heat balances for:
- Production processes
- Pollution control processes
• Operating manuals and process descriptions
• Equipment lists
• Equipment specifications and data sheets
• Piping and instrument diagrams
• Plot and elevation plans
• Equipment layouts and logistics
Raw Material/Production Information:
• Product composition and batch sheets
• Material application diagrams
• Product and raw material inventory records
• Operator data logs
• Operating procedures
• Production schedules
Accounting Information:
• Waste handling, treatment, and disposal costs
• Water and sewer costs, including surcharges
• Costs for nonhazardous waste disposal, such as
trash and scrap metal
• Product, energy, and raw materials costs
• Operating and maintenance costs
• Department cost accounting reports
Other Information:
• Environmental policy statements
• Standard operating procedures
• Organizational charts
Utilities
• Utility consumption and costs
• Maintenance of on-site utilities (e.g., emergency gen-
erators).
Production Factors
• The amount of product or service produced per year
• Number of employees, type of work schedule (shift
work, "9 to 5"), and hours of labor associated with
tasks of interest.
76
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Gathering Appropriate Data and Information
Ideally, records pertaining to the information outlined
above would be available for 5 years or more. Having a
larger data set enables the PPOA team to discount one-
time events that may skew the data for a particular year
(e.g., a significant hazardous waste spill).
5.3 Baseline Management
Recommendations
Developing a baseline at the facility level requires
careful organization and planning, particularly if the fa-
cility is large. The following suggestions may prove help-
ful:
• Selecting PPOAs — The facility should identify spe-
cific PPOAs based on its goals and objectives; con-
ducting site visits at all facility operations is
resource intensive and probably unnecessary.
• Information Collection — Prior to conducting the
assessments, the team should conduct a preassess-
ment and prepare worksheets tailored to the opera-
tions that the team will be assessing.
• Establishing a Schedule — The team coordinator
should develop a logical sequence for conducting the
site visits. For instance, it may make more sense
for the team to finish all the site visits related to a
particular issue (e.g., solvent substitution) before
beginning the visits for another issue. When devel-
oping the interview schedule, the team coordinator
should be careful to include time for follow-up ques-
tions and communication between the PPOA team
members. Depending on the scope of the program
plan, the team coordinator may find it useful to
schedule general information collection interviews
with upper management in addition to the site visits
with the technical staff.
• Information Management — Once the PPOAs are
underway, the team will collect pages and pages of
information. The team coordinator should establish
a system for ensuring that information is collected,
The Air Force Space
Command's Pollution
Prevention Management
Plan's baseline reflects
the Air Force's goals.
Baseline information will
be collected for the
following:
• Ozone depleting
compound purchases
• EPA's 17 industrial
toxic chemicals
purchases
• Hazardous waste
disposal
• Municipal solid waste
disposal
• Volatile air emissions
• Affirmative
procurement
- Paper
- Non-paper
Baseline
Recommenda tions
• Know where to
conduct PPOAs
• Know how to collect
information
• Know how to schedule
PPOA's
• Know how to organize
information
• Know how to identify
opportunities
77
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Chapter 5
organized, and stored in an efficient manner. A simple
file system may work well, or if many documents are
obtained, a computer database to track the documents
may be necessary.
• Identifying Options — During the baseline development
phase, team coordinators should encourage team mem-
bers to identify pollution prevention opportunities and
options. Keeping track of the opportunities during the
site visit phase enables the coordinator to shift re-
sources to the most productive areas as they are identi-
fied. Answers to technical questions can also be
obtained while the team is on-site.
• Keep Going — The team coordinator should use his or
her best professional judgement to determine when the
costs associated with gathering information exceed the
benefits. If a facility's environmental records are
poorly maintained, the team will have to devote extra
resources to information collection. Based on the pre-
assessment interview with the facility manager, the
team coordinator should be able to determine which in-
formation is worth collecting and in what situations the
costs outweigh the benefits.
5.3.1 Developing a Baseline by Conducting a Site Visit
After becoming familiar with the shop's goals and
objectives, the PPOA team should identify areas or opera-
tions where additional information is needed., To do this, the
PPOA team should conduct a preassessment.
A preassessment is particularly important if the PPOA
team comprises people from outside the shop. At a mini-
mum, the PPOA team should obtain a process description,
flow diagram, product description, and reports containing
waste generation statistics. The preassessment is a good op-
portunity to ask the environmental coordinator about the
shops's pollution prevention goals and about projects that
have already been identified or completed. The preassess-
ment helps the PPOA team formulate questions and identify
areas of special interest. In the case of a large facility, the
information gathered during the preassessment may also help
in the selection of the PPOA team members.
78
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Gathering Appropriate Data and Information
The EPA has developed a series of worksheets to
assist PPOA teams in developing the baseline. A com-
plete set of the worksheets appears in Appendix H. The
worksheet series is outlined in Table 8. Figure 4 shows a
completed worksheet for assessing waste sources at a hy-
pothetical facility.
The worksheets are only examples of the kinds of
questions the PPOA team might find useful. After the
preassessment, the PPOA team should tailor the work-
sheets to suit its needs. Teams may find that some of the
worksheets are not necessary for a given facility, or, con-
versely, the team may need to add specific technical ques-
tions or worksheets.
During the site visit, the PPOA team should use
worksheets #1 through #8a to gather the information tar-
geted during the preassessment as well as to record obser-
vations about the operations and general appearance of
TABLE 8. PPOA WORKSHEET TITLES
Worksheet No.
Title
Worksheet 1
Worksheet 2
Worksheet 3
Worksheet 4
Worksheet 5
Worksheet 6
Worksheet 7a
Worksheet 7b
Worksheet 8
Worksheet 9
Worksheet 10
Worksheet 11
Waste Sources
Waste Minimization: Material Handling (2a, 2b, and 2c)
Input Materials Summary
Products Summary
Option Generation: Material Handling
Process Description (6a, 6b, 6c, 6d, and 6e)
Waste Stream Summary
Waste Minimization
Waste Minimization: Reuse and Recovery
Option Generation: Process Operation
Waste Minimization: Good Operating Practices
Option Generation: Good Operating Practices
79
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Chapter 5
K"T-""~ \-2 -. _ -. p
ir fTTOP tiilCP A
\\ V vJ\ vw v — \A7>^> A*«
q.tP^l
Dilution Prevention
essment Worksheets
o ( -~> f^ r\ n ~^\
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Preoared Bv ^XljfYA CXV\\-Vy\
Checked Bv C^l . k — ,\QLY"'>x
Sheet H of i Paae I of ^~-
WORKSHEET INPUT MATERIALS SUMMARY
Attribute
Name/ID
Source/Supplier
Component/Attribute of Concern
Annual Consumption Rate
Overall
Component(s) of Concern
Purchase Price, $ per ^So C^L\.
Overall Annual Cost
Delivery Mode'
Shioomg Container Size & Type2
Storage ModeJ
Transfer Mode*
Empty Container Disposal Management5
Description
Stream No. I
H£^
^S.C^O^oA.
V^BC , ueavfu
(v\ehx\^
£?5§
*2,i~TZ-~%
~T?\AC£_
c~~^~) OS]\ .
\\\^(\Y\\^^
"TrucA^
D\^V\O
Shelf Life 1 N(O bCCVC
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— acceot exoired material? (Y/N)
— accept shipping containers? (Y/N)
— revise exciration date? (Y/N)
M(A
Acceotable Substitute(s), if any i^&H^iU /Mo^d
Alternate Suoolier(s)
£c^^?h^Ad:
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Stream No. /-^
Stream No. ^3
Notes: 1. e.g., pipeline, tank car, 100 bbl tank truck, truck, etc.
2. e.g., 55 gal drum 100 Ib paper bag, tank, etc.
3. e.g., outdoor, warehouse, underground, aboveground, etc.
4. e.g., pump, forklift, pneumatic transport, conveyor, etc.
5. e.g., crush and landfill, clean and recycle, return to supplier, etc.
Figure 4. Completed example of Worksheet 4.
80
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Gathering Appropriate Data and Information
the facility (e.g., evidence of leaks and spills). Other
sources of facility information which the PPOA team may
refer to while on-site are:
• Permits and/or permit application
• Environmental audit reports [e.g., DoD's Environ-
mental Compliance Audit System (EGAS)
reports]
• Biennial hazardous waste reports
• Material Safety Data Sheets (MSDSs)
• Product composition and batch sheets
• Operator data logs
• Waste handling, treatment, and disposal costs
• Water and energy costs
• SOPs
Although record reviews are informative, the best
way to find out what is occurring is to talk to as many
people at as many levels in the shop as possible. Observ-
ing the workers doing their jobs is another very important
technique. The longer a PPOA team can watch a process,
the better. In some cases, the team might find it neces-
sary to return to a process during different shifts. Under-
standing SOPs for how paint is supposed to be mixed is
one story; understanding how shop workers actually mix
the paint is sometimes another.
The PPOA team must keep in mind that the as-
sessment is not intended to identify improper practices.
In explaining the purpose of the PPOA to shop employ-
ees, the team should emphasi2;e that it is not performing a
compliance audit. Since shop employees are often good
sources of pollution prevention ideas, the team must gain
their trust and respect. The team should make an effort to
document any source reduction and recycling projects that
may already have been implemented.
81
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CHAPTER 6
IDENTIFYING AND SCREENING
POLLUTION PREVENTION ALTERNATIVES
OPTIONS
4 5 6
PARETO
SCREENING
ANALYSIS
Goals
••^^^••••^H
Environmental
Technical Feasibility
Option 1/ \Option4
Option 8
83
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CHAPTER 6
IDENTIFYING AND SCREENING
POLLUTION PREVENTION ALTERNATIVES
During the site visit and the record review, the PPOA
team will have identified several preliminary source reduc-
tion and recycling opportunities. Conducting a brainstorm-
ing session after the site visit is an effective method to get the
team together to compare notes and clarify the options. Us-
ing worksheets the team can record the options and begin to
identify follow-up steps. The team should hold the session
immediately after the site visit to take advantage of impres-
sions and observations that may be forgotten later.
An example of a list of general pollution prevention
options for a Federal site (an agricultural laboratory) is pre-
sented in Table 9.
Because of time and resource constraints, most facili-
ties have to prioritize their projects based on the original pol-
lution prevention goals and criteria specific to the shop.
Examples of criteria are the following:
• Complying with regulations (present and anticipated
compliance issues such as a product phaseout)
• Reducing volume of waste generated
• Reducing the cost of waste disposal and raw material
purchases
• Reducing toxicity — risk to human health and the envi-
ronment
• Reducing the impact on regional environmental con-
cerns (e.g., ground water contamination, endangered
species habitat)
Another criterion for evaluating projects is the project's
contribution to the development of a pollution prevention pro-
gram either at the shop or facility level. Structuring projects
that are inexpensive and easily implemented will build pro-
gram recognition and acceptability.
84
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Identifying and Screening Pollution Prevention Alternatives
TABLE 9. EXAMPLE OF GENERAL POLLUTION PREVENTION OPTIONS
FOR A FEDERAL LABORATORY SITE
Technique
Option
Training and assessment
Process or equipment modification
Waste segregation
Pollution prevention policy
Expand on the existing pollution prevention ethic with further education
and training.. Successful efforts are already underway including paper
recycling and source reduction in individual operations.
Appoint a pollution prevention "officer" within each research institute
to assist researchers with reduction and recycling initiatives. Pollution
prevention representatives from all the institutes could meet periodically
to discuss and compare efforts. Such information transfer, crucial for
the adoption of pollution prevention throughout the organization, re-
duces repetitive pollution prevention development efforts. For example,
DOE's Sandia National Laboratories has a pollution prevention network
where 60 people throughout the laboratory are points of contact.
Develop and implement a plan to conduct periodic pollution prevention
laboratory assessments using suitable in-house expertise. Such assess-
ments may uncover additional pollution prevention opportunities; they
emphasize BARC's commitment to pollution prevention. They can also
be used to monitor the success of pollution prevention efforts.
Keep abreast of commercially available technology changes as they re-
late to laboratory pollution prevention. When new technology is too
expensive for individual laboratories to implement, consider pooling re-
sources and locating instruments at a centralized facility which may be
used by several laboratories.
Reduce atmospheric emissions of chemicals from laboratories as part
of a comprehensive pollution prevention program. Glassware and auto-
mated extraction systems to reduce these emissions are commercially
available. In addition, for some samples, emissions can be reduced
through solid-phase extraction techniques as opposed to classical liquid
evaporation techniques that release the solvent carrier into the fume
hood and subsequently to the atmosphere.
Segregate hazardous from nonhazardous wastes. Hazardous waste
volumes are often unnecessarily increase because of the addition of
waste streams that are not hazardous. Segregation alone can signifi-
cantly reduce hazardous waste generation rates and disposal costs.
Require each laboratory to have a written waste management/reduction
policy. Minimum requirements would include annual chemical invento-
ries, the dating of chemicals as received, etc.
[Source: WREAFS PPOA: U.S. EPA-RREL. USDA Beltsville Agricultural Research Center Beltsville MD (EPA/
600/SR-93/008)]
85
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Chapter 6
6.1 Pareto Analysis
One of the most effective screening tools is known as
the Pareto analysis. The Pareto analysis is helpful in target-
ing problem areas and sources as illustrated in Figures 5 and
6. A Pareto analysis examines the environmental data in a
visual form to help pinpoint problem areas. Pareto analysis
is accomplished with the use of the Pareto chart (see Figure
5). Pareto analysis is often used in quality management to
identify quality defects or production costs. Small shops may
not need a Pareto analysis since the major environmental is-
sues at these types of shops may be obvious. Pareto analysis
is more appropriate for medium to large facilities with many
different operations, waste types, and potential environmen-
tal concerns and impacts which may require more in-depth
targeting analysis.
To conduct a Pareto analysis, the Pollution Preven-
tion Team and upper management should select the most im-
portant critical factors. Figure 5 is a Pareto analysis of waste
data from a hypothetical Army installation. In this case,
hazardous waste is the largest quantity of waste generated
and also the most expensive to manage. Based on this analy-
sis, the installation may want to focus pollution prevention
efforts on reducing hazardous waste generation and/or dis-
posal. The next step is to determine the organizations re-
sponsible for the target waste (see Figure 6). Once the
organizations have been determined, specific processes need
to be targeted using another Pareto analyses. The Team
should continue performing the Pareto analysis until a group
of targeted problem areas emerge.
An advantage to this type of analysis lies in its use of
readily available data and its focus on select issues, (e.g.,
waste quantities and disposal costs). A drawback is that it
does not account for other critical factors.
6.1.1 Screening Methods
There are two steps involved in prioritizing pollution
prevention projects. The first step is to narrow the list of
identified projects to a manageable number. For example, if
the PPOA team has identified 50 potential options but only
86
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Identifying and Screening Pollution Prevention Alternatives
73
en
3
O
sz
h-
800
700
600
500
400
300 -
200-
100 -
0
Hazardous Waste Solid Waste
Municipal Waste Wastewater
Energy
Figure 5. Pareto Chart Example.
TJ
V)
TJ
O
-C
I—
Division A
Division B
Division C
Division D
Figure 6. Pareto Analysis.
87
-------
Chapter 6
has resources for implementing 10, the team should first elimi-
nate 40 options using a screening method (the 40 options
should be put on hold for future evaluations).
The second step is to rank the options (in this ex-
ample, 10 options) by comparing each option to the program
plan criteria using a tool known as the decision matrix. Rank-
ing the options gives the PPOA team a better understanding
of each project's relative strengths and weaknesses.
6.1.2 The Decision Matrix
Once the PPOA team has narrowed down the list of
options using the Pareto analysis, it is ready to rank the op-
tions. The decision matrix is another powerful tool that can
be used to set priorities among pollution prevention options
(i.e., rank the options by a list of critical factors that are
important to the facility). The decision matrix enables a si-
multaneous examination and comparison of different pollu-
tion preventions alternatives. It facilitates an "apples-
to-apples" comparison of options based on the selected list of
critical factors, and, therefore, facilitate the group decision-
making process.
To use the decision matrix, one should first assign
either a numerical ranking to each of the critical factors, such
as 1-10, or general terms such as "high," "medium," or
"low " This approach can also be used if there is insufficient
information for performing a quantitative ranking. In these
cases, the coordinator should rely on his/her best profes-
sional judgement to assign a ranking.
The pollution prevention coordinator can also decide
on appropriate weighting factors. For example, s/he may de-
cide that estimated worker exposure issues are four times
more important than future regulations. In this case, s/he
would multiply the results of the criteria ranking by a factor
of 4 to give this issue increased relative importance. As seen
in Table 10, the final product of the decision matrix is a list
of options ranked in order of priority. If several projects
have the same numerical value, rank the "tied" options using
additional criteria such as:
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Identifying and Screening Pollution Prevention Alternatives
• Projected ease of reducing waste
• Downtime considerations
• Availability of people from the operating activity to
participate on the pollution prevention working team
• Necessity of revising SOPs, military specifications,
or technical orders
• Impact on the facility's mission.
After the decision matrix ranking process is complete, a
ranked list of those options that deserve the most immedi-
ate attention will be generated.
A quantitative ranking of pollution prevention op-
tions for a USPS facility is presented in Table 10.
Once the list of projects has been narrowed down,
based on the ranking process, additional research may be
required to determine whether the projects are truly fea-
sible. This reality check includes a technical evaluation
to ensure that a project is technically appropriate, an envi-
ronmental evaluation to weigh the project with regard to
environmental goals, and an economic evaluation to as-
sess the costs.
Typical technical
evaluation criteria:
• Will the project reduce
waste?
• /s the system safe for
workers?
• Will product quality be
improved or
maintained?
• Are the new
equipment, materials,
or procedures
compatible?
TABLE 10. EXAMPLE OF A DECISION MATRIX USED AT A USPS FACILITY
Criteria
Reduction in occupational hazard
Reduction of a RCRA-regulated waste
Reduction of a 33/50 F'rogram chemical
Reduction of environmental impact
Capital cost
Ease of implementation
Total
Water Borne Coating
5
5
5
4
3
2
24
HVLP Spray Gun
5
5
4
4
4
2
24
Gun Washer Station
5
4
4
2
2
3
22
5 - very positive; 4 = positive; 3 = neutral; 2 = negative; 1 = very negative
(Source: Adapted from the USPS Pollution Prevention Opportunity Assessment at a Vehicle Maintenance Facility, Buffalo, NY.)
89
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Chapter 6
Upper management
should always be in the
loop.
The key to a successful reality check is making sure
that the right people are involved. If the project requires
either purchasing new equipment or changes to operating
procedures, the shop should seek the opinions of the staff
who will be most directly affected by the changes. Building
staff support early on in the implementation phase helps pave
the way for later cooperation.
In the case of equipment purchases, technical exper-
tise may have to be sought from outside the shop either at the
facility level or from other organizations. One of the best
ways to avoid purchasing a white elephant is to talk to people
who have already purchased similar equipment. By taking
advantage of outreach programs such as the EPA's PIES sys-
tem, a computer bulletin board, contacts can be identified in
an efficient manner.
Some vendors are willing to perform an on-site equip-
ment demonstration at no cost. Vendors may also lease equip-
ment on a trial basis. Operator training and follow-up trouble
shooting and repairs are other services that vendors typically
provide.
The purpose of the environmental evaluation is to
weigh the advantages and disadvantages of a proposed pollu-
tion prevention option with regard to the environment. True
pollution prevention results in the elimination or reduction of
an environmental pollutant rather than simply shifting the
pollutant from one medium to another, for example, trading
an air release for a water release. The environmental trade-
offs should be carefully considered during project evalua-
tion. Projects that do create new releases of pollutants should
be carefully assessed. In some cases, trade-offs may be nec-
essary because of the nature of the operation, for example,
parts washing.
Replacing a hot caustic washing system with an aque-
ous jet washer reduces the use of toxic substances and air
emissions; however, the jet washer releases contaminated
wastewaters. A true source reduction option would be to
prevent the part that needs to be cleaned from becoming soiled
in the first place, or if that is impossible, to clean only when
it is absolutely necessary.
90
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Identifying and Screening Pollution Prevention Alternatives
Another example of an environmental trade-off de-
cision is whether to switch from stocking plastic grocery
bags to paper bags for use at a commissary. Plastic bags
are petroleum-derived products, and they degrade slowly
in a landfill. Incineration may contribute to the release of
hazardous substances to the atmosphere. On the other
hand, the process for manufacturing paper bags is energy
intensive and involves hazardous chemicals. Residence
times in landfills is also very long.
Another pollution prevention option for a com-
missary may be to reduce packaging wastes by buying
time-sensitive products in bulk; however, if the inventory
is not assessed accurately, buying in bulk may result in an
increase in expired materials.
6.2 Economic Screening Methods
This topic can be very complex in terms of the
economic tools available to assess costs, to calculate the
time value of money, and to define the variables affecting
the costs of a pollution prevention option. However, the
most common method of determining cost and ranking
projects is that of the payback calculation. A payback
calculation simply involves a determination of how much
time will pass before the proposed pollution prevention
option saves enough money or avoid enough costs to pay
for itself. To assess this situation, the pollution preven-
tion team should collectively discuss the pros and cons of
each option and attempt to estimate the costs associated
with both tangible and intangible aspects of its implemen-
tation. Program managers need to review the costs esti-
mated to ensure that as many of the avoided costs and as
accurate an estimate of capital and annual operating and
maintenance costs have been assessed as possible. This
will mean review of the notes and calculation sheets of
the team, especially those coming from the vendor of the
equipment or technology. Payback calculations can be as
simple as the following equation:
Startup costs = Payback
(avoided costs - annual costs)
91
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Chapter 6
A simple example of a payback calculation is presented be-
low in Example 8.
This type of analysis does not delve into intangible
costs (e.g., training of the operators of the recycling unit) or
benefits (e.g., reduced worker exposure to antifreeze and the
mixture). It does, however, cover the majority of the fund-
ing requirements for the option and allows prioritization of
this option with others based on payback.
Example 8
A Simple Payback Calculation
A motorpool desires an economic evaluation of an option to install an antifreeze recycling system, with 5
independent collectors carts to better manage the antifreeze change-outs. The motorpool disposes of 3,1 75
gallons of waste antifreeze mixture each year; the mix is 60 percent coolant and 40 percent water. The start-
up costs are estimated to be $9,360, based on:
5 collector units at $928 each =
1 recycler unit at $4,720 each =
Avoided costs, based on 85 percent recovery from the recycler, reduced raw material costs, reduced dis-
posal costs (including both the cost to dispose of bottles and antifreeze volumes), and reduced rental costs
for the disposal bin are calculated:
Disposal volume cost avoided =
Raw material cost avoided -
Bottle disposal avoided =
Reduced container rental =
Annual costs were estimated to include electricity, deionized water (Dl) and enough inhibitor to treat the
recycled antifreeze. Also, disposal of the 1 5 percent volume of antifreeze mix not recyclable is included.
The annual costs estimated for this option are:
Utilities, Dl water, and inhibitor =
Disposal costs =
The payback calculation for this example is then:
$9,360 = 55 years, or 6.6 months
$19,996- $3,120
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Identifying and Screening Pollution Prevention Alternatives
This type of calculation parallels the cost/benefit
ratio that is performed using Worksheet 9 of the Facility
Pollution Prevention Guide. More sophisticated calcula-
tions to determine net present value and internal rate of
return may be conducted. In addition, a "Primer for Fi-
nancial Analysis of Pollution Prevention Projects" has been
published and is available as EPA/600/R-93/059.
The Air Combat Command of the U.S. Air Force
has recently published a "Memorandum for Pollution Pre-
vention Program Managers on Justifications for Pollution
Prevention Equipment and Projects." It defines 10 sub-
categories of environmental benefit to be derived:
1. Reduce the demand for the EPA 17 Industrial Tox-
ics Project Chemicals.
2. Reduce the demand for other hazardous materials.
3. Recycle hazardous material.
4. Recycle nonhazardous material.
5. Reduce hazardous waste disposal volume.
6. Reduce hazardous material disposal toxicity.
7. Reduce harmful air emissions.
8. Reduce harmful water emissions.
9. Reduce municipal solid waste volume.
10. Intangible benefits: improved image of the Air
Force, easier compliance reduced potential cleanup
liability, etc.
More definition of economic terms and concepts,
as well as applications of the more sophisticated LCA,
LCC, and TCA is provided in Appendix A.
93
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CHAPTER 7
IMPLEMENTING AND MEASURING THE SUCCESS
OF POLLUTION PREVENTION
The Procedure for Conducting Pollution Prevention Opportunity Assessments
The recognized need to minimize waste
PLANNING AND ORGANIZATION
Get management commitment
Set overall assessment program goals
Organize assessment program task force
Assessment organization JL and commitment to proceed
ASSESSMENT PHASE
Collect process and facility data
Prioritize and select assessment targets
Select people for assessment teams
Review data and inspect site
Generate options
Screen and select options for further study
3 Select new
assessment targets
Assessment report • of selected options
and reevaluate
previous options
Technical evaluation
Economic evaluation
Select options for implementation
Review data and inspect site
Final report, including • recommended options
IMPLEMENTATION
Repeat the process
4
Justify projects and obtain funding
Installation (equipment)
>• Implementation (procedure)
X Evaluate performance
Successfully implemented pollution
prevention projects
95
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CHAPTER 7
IMPLEMENTING AND MEASURING THE SUCCESS OF
POLLUTION PREVENTION
A pollution prevention
program plan that
exhibits a sound
methodology for
identifying, prioritizing,
and selecting pollution
prevention projects can
itself be used to attract
capital investment in
pollution prevention
projects.
Project Types
• Foundation —
contribute to the
development of the
pollution prevention
program
• Action — specific
prevention activities
• Support — foster a
pollution prevention
ethic
7.1 Implementing Pollution Prevention
The schedule for implementing pollution prevention
projects or a program should be closely tied to the facility's
short-, mid-, and long-term goals. Designing a schedule is
similar to devising a personal investment strategy: an inves-
tor typically selects a mixture of stock, bond, and money
market options, each associated with varying degrees of risk
and dividends. Scheduling the tasks and projects that make
up the pollution prevention program plan is a balancing act to
ensure that projects with a longer payoff come to maturity at
the desired time; low-cost projects with a quick payback should
be implemented early on to gain program recognition. Un-
derstanding the nature of the projects is, therefore, impor-
tant.
7.1.1 Understanding Project Types
Pollution prevention projects fall into three general
types: foundation, action, and support. Most program plans
will probably contain a few of these three project types. A
discussion of the three types of pollution prevention projects
follows; examples are provided using projects identified in
the Yosemite National Park Waste Reduction Action Plan.
Foundation Projects
Foundation projects contribute to the development of
the pollution prevention program. These projects often take
the majority of funding in the initial years. When the basic
support is in place, the funding needs for foundation projects
virtually disappear.
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Implementing and Measuring the Success of Pollution Prevention
Examples of foundation projects are developing
hazardous material tracking systems, surveying fugitive
emissions, or installing utility meters on individual pro-
cesses. Additional analysis is often required to character-
ize the exact nature of a process that appears to present a
pollution prevention opportunity. Without sufficient data,
defining the exact nature of the pollution prevention op-
portunity is impossible.
Process-specific PPOAs, discussed in Chapter 3,
are another type of foundation project. Pollution preven-
tion process analyses are fundamental to the definition
and implementation of specific prevention projects. The
program planning process is used to identify the processes,
operations, and activities that should be analyzed first.
Action Projects
Action projects are specific prevention activities
that directly reduce environmental impacts and wastes.
Action projects are identified primarily during baseline
development and from process-specific pollution preven-
tion opportunity assessments. These projects often in-
volve modifying processes or operations, tor example with
new equipment, improved housekeeping practices, revised
SOPs, toxic use reduction techniques, toxic material sub-
stitutions, and material conservation practices. To imple-
ment process and operation modifications, the facility may
need to buy and install equipment and/or change operat-
ing procedures. These projects often include testing, de-
velopment, and training activities as part of their
implementation.
Action projects also include policy changes to in-
stitutionalize pollution prevention. Many prevention ac-
tivities will require policy modifications to formally adopt
the new practice or procedure into the facility's mission.
Further, existing policies may prohibit the favored pre-
vention option or may even be directly responsible for
generating waste. In such instances, facility or agency-
wide policies may need to be modified so that they sup-
port pollution prevention.
Yosemite National Park's
Action Plan includes a
project for evaluating the
feasibility of
implementing a
comprehensive food and
yard waste composting
program.
Yosemite National Park
will field test the use of
re-refined motor oil in
National Park Service
vehicles. If the field
tests are positive, the
park will increase the
purchase and use of
recycled content
products.
Yosemite National Park's
Waste Reduction Action
Plan calls for reviewing
each of the Concessioner
Operational Performance
Standards used in the
park. Suggestions will be
offered on how to
change the standards so
they encourage (or
require) recycling,
composting, source
reduction, and the
purchase and use of
recycled content of less
toxic materials.
Yosemite National Park's
Waste Reduction Action
Plan includes a project to
develop waste reduction
and recycling education
materials targeting
visitors before they
arrive at the Park to
increase recycling levels
and reduce solid waste.
97
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Chapter 7
Support activities help
foster a pollution
prevention ethic.
In order to secure long-
term support and
commitment, carefully
select projects that are:
• Achievable in a realistic
and short time frame
• High-profile, yielding
extraordinary
successes with small
investments in time
and money
• Action oriented rather
than research and
development oriented.
By emphasizing these
criteria pollution
prevention successes
should come quickly,
establishing the program
and attracting future
resources.
Support Projects
Support activities help foster a pollution prevention
ethic both for the facility's personnel and the local commu-
nity. Training is a typical support project. Training intro-
duces pollution prevention to those who will be instrumental
in making it happen. For example, training can teach the
pollution prevention working teams how to implement a spe-
cific prevention technique, or it can teach shop personnel
how to use a new piece of pollution preventing equipment.
Community outreach to inform the community of pre-
vention projects and to solicit public support is another type
of support project. Prevention projects may require the par-
ticipation of the community to succeed, (e.g., implementing
a recycling program).
From the start, the early success of the pollution pre-
vention program may depend on showing successes very
quickly. Upper management may buy into the concept of
pollution prevention, but they may only give financial sup-
port for the concept once the facility has demonstrated how
well it works. Therefore, the facility may choose to begin by
implementing low cost projects with a high payback.
As the program progresses, the facility can then imple-
ment projects that are more time and resource intensive. This
is not to say that easy-to-do projects should be pursued at the
expense of large-investment, large-return projects. However,
facilities should pursue a proper balance of projects to achieve
results in the short term as well as the long term.
It is important to realize that straightforward preven-
tion solutions can yield significant prevention gains. For
example, a facility may dispose of solvents from parts clean-
ers (solvent sinks). This may constitute a simple pollution
prevention opportunity that might be realized through the
following types of techniques:
• Dispose of the solvent only when completely saturated
with grease, oil, or other dirt (to the point where the
solvent is unusable) rather than at scheduled intervals.
• Preclean dirty parts with a brush.
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Implementing and Measuring the Success of Pollution Prevention
• Make sure all tanks are properly covered to mini-
mize fugitive losses.
• Segregate waste solvent from other wastes such as
oily wastes.
These actions can result in significant waste reduction,
yet they are simple and can be implemented immediately
without large capital investments. Meanwhile, a facility
should also be looking at more significant pollution pre-
vention options, for example:
• Substitute less hazardous alternative cleaning sub-
stances.
• Identify just how clean parts must be (e.g., whether
some processes require parts to be cleaned at all).
• Identify whether operators are utilizing solvent sinks
properly.
While it is important to initiate simple projects first,
it is equally important to remember that more complex
efforts may also be appropriate. In the long-term, it is
crucial that no prevention options be discarded on the
basis of being difficult or expensive.
7.1.2 Techniques for Developing a Schedule
Many pollution prevention coordinators find it help-
ful to develop a schedule for implementing specific pollu-
tion prevention actions. In general, the schedule is useful
for the following:
• Planning each effort and sequences of efforts
• Establishing milestones
• Defining staffing needs for each project
• Documenting roles and responsibilities
• Establishing monitoring efforts
• Obtaining funding
With the first series of
projects underway, begin
to raise longer term
issues that will require
investment as the short-
term achievements are
being demonstrated and
documented.
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Chapter 7
A PPOA requires:
• Direct involvement of
the pollution prevention
coordinator and facility
staff
• Support by upper
management
A fundamental lesson of
pollution prevention
education is to
demonstrate the potential
to improve operational
efficiency and thus
mission accomplishment.
The Air Force Center For
Environmental Excellence
(AFCEE) has established
a pollution prevention
training course for Air
Force employees which
includes hands-on
practice in conducting
opportunity assessments,
case studies, team-
building exercises, and
lectures on the tools
which comprise pollution
prevention. For
information on the
AFCEE training course,
call (210) 536-3517.
The complexity of the schedule should match the
facility's needs. If there are only a few projects, the facility
may be able to schedule each independently. Keeping track
of a few projects can be accomplished easily. For programs
that involve numerous projects, however, the pollution pre-
vention coordinator should define a schedule for initiating
these actions. This is particularly important for projects re-
quiring multiple actions simultaneously.
In the long run, many variables will impact and often
delay the schedule. One of the most important variables is
the availability of funding. To plan for interruptions, con-
sider developing a schedule for the first 12 to 18 months of
the program. Then, after 6 months, review and revise the
schedule to reflect any changes. After the initial 12 to 18
months, the coordinator should review the prevention plan
(see Step 6) to revise and refine it as needed. At this time,
the coordinator can also extend and modify the implementa-
tion schedule.
Project implementation consists of three basic steps:
• Getting management commitment
• Making the modifications
• Evaluating the results.
Getting Management Commitment
Upper management commitment is a critical compo-
nent of project implementation. Ideally, the pollution pre-
vention coordinator should secure upper management
commitment prior to beginning the PPOA. Getting manage-
ment on board can help remove organizational barriers and
ensure that implementation proceeds smoothly. Regardless
of whether the project ends up being successful or not, upper
management should always be in the loop.
7.1.3 Making the Modifications
Many pollution prevention projects will require
changes in operating procedures, purchasing methods, or
materials inventory control. Policies and procedures may
also be affected by the changes. For projects that involve
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Implementing and Measuring the Success of Pollution Prevention
equipment modifications or new acquisitions, getting a
project off the ground is essentially the same as any other
capital improvement project. The phases of the project
include planning, design, procurement, construction, and
operator training. As with other equipment acquisitions,
it is important to get warranties from vendors prior to
installation of the equipment. Training and incentive pro-
grams may be needed to get employees used to the new
pollution prevention procedures and equipment.
Once a shop has implemented a project, the pollu-
tion prevention coordinator should take the time to evalu-
ate and document its performance. Project implementation
is always a learning experience, and conducting a thor-
ough analysis is one way of streamlining the implementa-
tion process for future projects. Quantitative evaluation
is the most straightforward way to determine whether the
shop's pollution prevention goals are being met. The shop
should choose criteria to use as measurements of progress
prior to project implementation. The criteria for screen-
ing options (as discussed above) may overlap with the
criteria for measuring progress.
7.2 Monitoring and Evaluation
The pollution prevention program will change over
time as projects are implemented and priorities shift. The
planning process described in this manual is an iterative
approach to reducing waste through pollution prevention.
In most cases, pollution prevention team members work
with the pollution prevention coordinator to solve identi-
fied problems, after which they return to the planning
process and target another problem area.
Throughout this process, the pollution prevention
coordinator, as the principal monitoring agent, must ex-
amine the progress in meeting specified objectives. For
example, the coordinator might develop a checklist to
monitor progress. This checklist could include the fol-
lowing questions:
• Are the shops making progress towards their pollu-
tion prevention objectives?
No need to reinvent the
wheel! Numerous
pollution prevention
training videos and
materials are available.
For a list, refer to the
EPA's 1993 Reference
Guide to Pollution
Prevention Opportunities
(EPA/742/B-93-001).
Copies of the document
are available from the
Pollution Prevention
Information
Clearinghouse by calling
(202)260-1023.
Newsletter Contact:
DOE-DP Pollution
Prevention Advisor.
Elizabeth McPherson
(615)543-5422
DOE Federal Energy
Management Program—
Focus: Federal Energy
Management Update.
Rick Klimkos (202)586-
8287
EPA Pollution Prevention
News. U.S. EPA 401 M.
St. SW, Washington, DC
20460
EPA Chemicals in
Progress—En vironmen tal
Assistance Division (TS-
799) Office of Pollution
Prevention and Toxics,
U.S. EPA 401 M. St.
SW, Washington, DC
20460
101
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Chapter 7
A program that can
measure and demonstrate
the success is best able
to attract future
commitment of
resources.
Project tracking systems
are simple, effective tools
for monitoring progress,
• Is the facility meeting the milestones that it laid out for
itself during the goal setting exercise?
• Are certain team members acting as leaders in imple-
mentation and others acting as laggards?
• What issues are contributing to any lack of success?
» What is working well?
Monitoring and evaluating pollution prevention
progress is a last step in the program development process,
and it is the only method for tracking the effectiveness of
specific projects. The pollution prevention coordinator needs
to measure the program's progress against the objectives se-
lected by the Pollution Prevention Steering Committee. In
areas where the facility falls short of expectations, the coor-
dinator will need to adjust the program plan.
7,2.1 Monitoring Progress
In light of Executive Order No. 12856, Federal Agen-
cies may begin to require facilities to submit progress reports
documenting their pollution prevention achievements.
It is important for the pollution prevention coordina-
tor to stay abreast of implementation problems and to address
them in some manner. If implementation is not going well or
if there are barriers to program implementation that cannot
be overcome, it is the pollution prevention coordinator's re-
sponsibility to try to solve these problems. One mechanism
for steering the program in the right direction is to develop a
tracking system to monitor each project. The sophistication
of the tracking system will depend on the size of the facility
and the complexity of the processes.
For a small facility with few complex processes, track-
ing may be as simple as observing working team meetings or
obtaining the working team meeting notes. At large facili-
ties, however, a spreadsheet program that tracks milestones
may be required. In addition, frequent discussions with team
leaders and individuals involved in the operating activities
will assist in comprehensive tracking.
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Implementing and Measuring the Success of Pollution Prevention
7.2.2 Evaluating Progress
To effectively demonstrate implementation of the
pollution prevention program, it is important to measure
and evaluate progress. To do this, the coordinator needs
to compare the baseline data to the data obtained for the
tracking program. The choice of indicators depends on
the nature of the project being tracked.
Program Evaluators
• Measure the ratio of waste generated to a specific
unit of production or activity, before and after
implementation.
• Monitor the number of violation notices before and
after project implementation.
Air Emissions
• Compare air emissions before and after prograrri
implementation.
Cost
• Quantify savings attributed to reduced raw material
costs and/or waste disposal costs.
• Identify savings from util ity conservation and effi-
ciency.
• Monitor profits from revenue generating programs
such as recycling.
Training
• Track the number of students trained in pollution
prevention.
Recycling
• Monitor the number of waste streams collected and
the volume recycled.
Monitoring and evaluating
progress is critical to the
long-term success of a
facility's pollution
prevention program.
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Chapter 7
Policies and Procedures
• Track the number of SOPs, technical orders, and
MILSPECs revised to incorporate pollution prevention.
For industrial operations, another important indicator
is worker health, safety, and job satisfaction. Implementing
pollution prevention projects may result in the following:
• A reduction in the number of work-related accidents
• A reduction in the number of sick days due to a
healthier working environment
• A lower turnover rate as workers opt to remain on the
job because of improved working conditions.
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APPENDIX A
ECONOMIC ANALYSES METHODS
105
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Appendix A
...there are always
alternative uses for the
resources used in a
project. Dollar values
can be assigned to those
alternative uses in order
that the true total cost
of a project can be
identified.
...a dollar invested today
will be worth something
more than a dollar 1 year
from now.
TOOL: COST BENEFIT ANALYSIS FOR
POLLUTION PREVENTION PROJECTS
Overview
Implementing most pollution prevention projects re-
quires spending capital. In order to determine whether the
project's benefits are worth the costs, facilities routinely per-
form economic assessments. The tool which Federal facili-
ties most commonly use is cost-benefit analysis. Cost-benefit
analysis investigates the costs and benefits of each of a set of
alternatives so that a decision maker can better understand
the consequences of a policy decision. Cost-benefit analysis
is primarily concerned with economic efficiency, the consid-
eration of whether total benefits outweigh the total costs of
providing them.
Cost-benefit analysis is also an important aid for de-
cision makers to use when evaluating the economic efficiency
of a pollution prevention project. Unlike the private sector
where the primary consequences of a project that are of con-
cern to a firm are those that affect profitability, the public
sector is more concerned with a much broader range of con-
sequences, including environmental effects. When used with
care, cost benefit analyses can help decision-makers consider
both economic and environmental aspects of a pollution pre-
vention project.
There are several different ways to perform cost-ben-
efit analysis for pollution prevention projects. While it is
beyond the scope of this guide to give a complete explanation
of this topic, this section provides a short summary of two
methods which are mostly commonly used.
Major Concepts
Every project will provide tangible and intangible ben-
efits, as well as costs. The challenge in applying conven-
tional economic assessment tools to environmental projects
lies in accurately evaluating the intangible benefits accruing
from project implementation. Intangible benefits are ben-
efits which are difficult to quantify (e.g., assigning a mon-
etary value to species preservation). Improving methods for
-------
Economic Analyses Methods
assessing costs and benefits for environmental projects is
an active area of research; Federal facilities should try to
keep abreast of new developments in the field.
To use cost benefit analysis, it is necessary to un-
derstand three concepts, opportunity cost, the time value
of money and uncertainty.
Opportunity Cost
The concepts of cost are fundamental to the com-
parison of project alternatives. The most fundamental
concept of an action, decision, or allocation being "costly"
is that there are alternative uses for the resources used in
a project. This concept is referred to as the opportunity
cost of a project.
There are two main categories of opportunity cost:
private opportunity cost and social opportunity cost. The
private opportunity cost approach acknowledges that pub-
lic funds are withdrav/n from private sectors where they
would otherwise earn some rate of return. By devoting
them to or investing them in some project, the rate of
return is given up as an opportunity cost. That cost rep-
resent by the minimum interest rate or discount rate that
the funds could otherwise earn should be used in evaluat-
ing public projects.
The social opportunity cost of using resources in
one activity is the value foregone by not using them in the
best alternative activity. For example, when a govern-
ment agency decides to fund a certain project, it is simul-
taneously deciding not to fund another project even though
the alternative project has redeeming features. Social op-
portunity cost is difficult to quantify because the costs are
subjective: valuing the preservation of a species; the pris-
tine quality of a lake; the healthy life of a human being.
However, there are methods available to assign costs even
to qualitative issues.
Time Value of Money
The basic concept of all project evaluations and
long-term financial plans is the time value of money. This
Making an investment
involves giving up capital
in the hope of getting
more in return.
The uncertainty, or risk,
associated with a project
is the chance that the
anticipated benefits may
not be realized.
107
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Appendix A
concept captures the opportunity cost of a given project. The
discount rate, similar to an interest rate, is the mechanism
that equates today's dollar with its value at some point in the
future.
The time value of money describes the principal that
a dollar invested today will be worth something more than a
dollar 1 year from now. At a simple interest rate of 5 per-
cent, a dollar today is worth $ 1.05 one year from now. This
is referred to as the "present value" of one dollar one year
from now at an interest rate of 5 percent.
The selection of an appropriate discount rate is one of
the most difficult aspects of a cost-benefit analysis, but it is
also one of the most important. For evaluating long-lived
projects, such as dams, the identification of an accuracy dis-
count rate is crucial: a project that looks favorable using a 3
percent discount rate may look very unattractive at a 10 per-
cent rate.
The time value of money means that money that is
available today to be spent or invested is more valuable than
money that will not be available to earn a return until some-
time in the future. Put simply, a thousand dollars in a shop's
budget today is worth more than the expectation of gaining a
thousand dollars in the future as pay off from an investment.
For an investment to be cost-beneficial, it must return
more dollars in the future (i.e., benefit) than the amount of
dollars spent in the present (i.e., the cost of the investment)
to account for this difference in value. In other words, the
dollar benefits gained in the future must be greater than the
initial investment.
Uncertainty
Another basic principle related to project evaluation
is the issue of uncertainty. Making an investment involves
giving up capital (i.e., dollars) in the hope of getting more in
return. For example, a supervisor buying an antifreeze recy-
cling unit expects the investment to pay for itself in terms of
reduced operating costs (i.e., avoided costs) within 3 years.
After the unit has paid for itself, the money saved on avoided
108
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Economic Analyses Methods
operating costs can be used for other purposes. The
risks associated with the investment are the chances that
the unit might break down after only two years and that
the annual savings may not be as great as expected.
For environmental projects, the degree of uncer-
tainty can be particularly high and stems from two con-
ditions: (1) the complexity of assessing risks associated
with the use, transport, and exposure to hazardous sub-
stances; and (2) the rapidly changing regulations and
shifts in judicial decisions that define and continually
alter costs. Thus, a cost-benefit analysis should include
a mechanism to account for these risks. This mecha-
nism is known as the "risk premium." Risky projects
have to earn a higher return than "safe" projects to com-
pensate for the uncertainty inherent in the project.
The two cost benefits analysis techniques de-
scribed below do not take into account risk. As a result,
they are easier to use; however, they are more likely to
produce misleading results. Other cost benefit analysis
techniques are available which consider both the time
value of money and risk (e.g.. present value and risk).
Two cost benefit methods are summarized in Table A-l.
Typically, Federal facility managers use the first method,
payback analysis, when justifying projects.
Key Terminology
For readers who are new to cost-benefit analy-
sis, this section explains frequently used terms. Many
of these terms are used in Table A-l.
Net Annual Benefit
Net annual benefit is the benefit in dollar terms
gained at the end of the year. To calculate the net an-
nual benefit, subtract the annual operating costs (e.g.,
labor, equipment maintenance, energy costs) from the
(gross) annual benefit. The annual benefit may be the
avoided costs resulting from the project (i.e., the waste
disposal costs in the antifreeze recycling example).
Payback analysis does
not take into account the
time value of money.
109
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Appendix A
Method
Payback Analysis
Net Present Value
Analysis
TABLE A-1. COST BENEFIT ANALYSIS METHODS
How to Apply the Method
Advantages/Disadvantages
1. Obtain the projects' net annual benefits by subtracting
the expected annual operating costs from the expected
annual benefit?;:
Net annual benefits = annual benefits - annual costs
2. Divide the total project development cost by the average
net annual benefit. A less accurate shortcut is to simply
use the net annual benefit. The result is the number of
years the facility can expect to wait before it recovers the
amount of money spent in the development of the system.
Payback period = Total project development cost/average
net annual benefit
Advantage: Simple to use. Federal facilities
typically requires a payback period of three
years in order to receive funding. Method
express savings in terms of the number of
years before an investment pays for itself.
Disadvantage: This is the least appropriate
method. It fails to consider the fact that the
time needed for project development may be
long in some cases (e.g., setting up a
recycling program). Although benefits may
be limited during the early years of
implementation, they will increase overtime
as the facility personnel become accustom to
the project.
This method does not take into account that
the current dollars are spent on the
development of the project, but because of
the time value of money, less valuable dollars
are returned in the future. In addition,
payback analysis does not consider the risk
that a facility may not receive the required
benefits from the project.
1. Obtain the net annual benefits of the project by Advantages: Takes into account time value of
subtracting the expected annual operating costs from the money
expected annual benefits:
Net annual benefit = annual benefits - annual costs
2. Discount the net annual benefits during the life of the
project using the following formula:
Discount factor = net annual benefits/(1 + i)
Disadvantages: Does not take into account
the risk of not fully receiving the benefits of
the new project.
Where:
i = discount rate organization's minimum expected rate
of return
n = number of years benefit will be received
3. Subtract the total development cost from the total of the
discounted net benefits, the results must be greater than
zero if the new system is to be cost-beneficial
Discounted net benefits - total development costs =
net present value
Source: Adapted from Richard T. Due "Determining Economic Feasibility: Four Cost/Benefit Analysis Methods". Journal of
Information Systems Management, pp 14-19, 1989
110
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Economic Analyses Methods
Project Development Cost
The implementation costs associated with the
project, including capital costs, administrative, permit-
ting.
Discount Rate
The discount rate is used to relate the value of a
dollar at one date to its value at a later date. It is similar
to an interest rate used in the private sector.
Net Present Value
Net present value (NPV) is the present value of
total benefits (i.e., the generated cash flow) minus total
costs (i.e., cost of the investment). A project with an
NPV greater than zero will be adopted; a negative NPV
project will be rejected.
Rate of Return
Rather than select a particular discount rate for the
present value analysis, various rates are tried until the
present value of the costs equals the present value of the
benefits. This rate is the rate of return. A project is
economically worthwhile if its rate of return exceeds the
cost of borrowing funds.
Payback
As discussed previously, payback period analysis
is the investment performance indicator used historically
by Federal agencies. The disadvantage of the payback
method is that it does not take the time value of money
into consideration. Despite this drawback, many Federal
agencies still use this form of project analysis. For those
that do, Total Cost Assessment (TCA) principles can still
be integrated into the payback calculations. Simply by
expanding the cost arid benefits inventory tabulated, ex-
panding the time horizon of the project evaluation, and by
properly allocating costs and benefits, the payback calcu-
lation will more accurately reflect the true payback period
for the pollution prevention project option.
Ill
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Appendix A
A PPOA requires:
• Direct involvement of
the pollution prevention
coordinator
• Support by facility staff
and upper management
NPV Method
Under the NPV method, the present value of each
cash flow, both costs and savings, is calculated, using an
appropriate discount rate. The present value of total benefits
minus total costs is the project's NPV. A positive NPV means
a project is worth pursuing and a negative NPV indicates that
it should be rejected. For example:
Discounted savings - discounted costs = NPV
$300,000 discounted savings - $200,000 discounted costs = $100,000
Thus, this project would be adopted, unless there was an
alternative project choice that had a NPV higher than
$100,000.
Major Concepts:
• LCCis a tool to
evaluate the private
and societal costs
across the entire life of
a pollution prevention
project.
• In LCC, social costs are
quantified, and when
that is to possible, they
are addressed
qualitatively.
Internal Rate of Return
The Internal Rate of Return (IRR) method is based on
the same theory as NPV, but the unknown in the equation is
the interest, or discount, rate. The IRR method calculates
the discount rate that equates the present value of a project's
expected savings to the expected costs, making NPV equal to
zero. A project is worthwhile if its internal rate of return
exceeds the cost of borrowing funds. The project alternative
with the greatest IRR will be the preferred option. For ex-
ample, if an investment choice indicated an IRR of 10 per-
cent it would be adopted unless there was an alternative
investment choice that had an IRR higher than 10 percent.
TOOLS: LIFE-CYCLE COSTING, TOTAL COST
ASSESSMENT, AND LIFE-CYCLE ANALYSIS
Overview
Over the years, Federal facilities have used a variety
of decision making tools to quantify the effects of alternative
strategies in the facility acquisition, operation and disposi-
tion process. These tools reflect the nature of the more press-
ing facility management issues of the day, and are similar to
the methods applied by the private sector.
During the past decade, economic analysis tools have
matured, and techniques for comparing the costs and benefits
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Economic Analyses Methods
of alternative Federal facility strategies have become more
rigorously specified by the OMB and implementing Fed-
eral agencies. More recently, the environmental effects
of alternative facility management strategies have received
greater attention, particularly in the field of pollution pre-
vention.
Tools for estimating the environmental effects as-
sociated with a project can be valuable when justifying
pollution prevention projects. Pollution prevention projects
are difficult to justify because environmental benefits are
often intangible, meaning that assigning a dollar value is
not always possible. In recent years, tools for a more
comprehensive analysis of the costs and benefits associ-
ated with a project have been developed. Similarly, com-
paring the environmental effects associated with a proposed
project requires using special tools. For example, would
a process modification reduce a hazardous waste stream
but result in an increase in pollutants discharged to waste-
water?
At this point in time, there are three tools avail-
able to Federal facilities for evaluating pollution preven-
tion projects:
• Life-Cycle Costing (LCC);
• Total Cost Assessment (TCA); and
• Life-Cycle Assessment (LCA).
Table A-2 illustrates the users and applications of these
three tools.
TABLE A-2. ANALYTICAL TOOLS
Application Users FOCUS
Economic Environmental Public Private
Criteria Criteria Sector Sector Limited Holistic
Life-Cycle Costing
Total Cost Assessment
Life-Cycle Assessment
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Appendix A
Life-Cycle Costing
Life-cycle costing (LCC) has been used for many years
by both the public and private sector. It associates economic
criteria and societal costs with individual pollution preven-
tion opportunities. Managers use LCC analyses to evaluate
the costs arid benefits of different pollution prevention op-
portunities. Typical decisions include disposal versus recy-
cling, replacement versus limited repairs, and hazardous
materials versus less toxic materials. LCC should not be
confused with TCA and LCA. To dispel any doubts over the
differences, this section explains LCC in greater detail. The
purpose of LCC is to quantify a series of time-varying costs
for a given opportunity over an extended time horizon, and
to represent these costs as a single value. These time varying
cost usually include the following:
• Capital Expenditures - Costs for large, infrequent in-
vestments with long economic lives (e.g., new struc-
tures, major renovations and equipment replacements)
• Nonrecurring Operations and Maintenance (O&M) -
Costs reflecting items that occur on a less frequent than
annual basis that are not capital expenditures (e.g., re-
pair or replacement of parts in a solvent distillation
unit)
• Recurring O&M - Costs for items that occur on an an-
nual or more frequent basis (e.g., oil and hydraulic
fluid changes)
• Energy - All energy or power generation related costs.
Although energy costs can be included as a recurring
O&M cost, they are usually itemized because of their
economic magnitude and sensitivity to both market
prices and building utilization.
• Residual Value - Costs reflecting the value of equip-
ment at the end of the LCC analysis period. Considers
the effects of depreciation and service improvements.
By considering all costs, a LCC analysis can quantify
relationships that exist between cost categories. For example,
certain types of capital improvements will reduce operations,
114
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Economic Analyses Methods
maintenance, and energy costs while increasing the
equipment's residual value at the end of the analysis pe-
riod. When energy costs are broken out from recurring
O&M costs, there is the potential for the application of
environmental criteria, but this is generally not the focus
of traditional LCC analysis.
Societal costs such as those resulting from health
and ecological damages related to unregulated air emis-
sions, wetland loss, and deforestation can also be reflected
in a LCC analysis either in a quantitative or qualitative
manner. LCC includes the following cost components:
• Extraction of Natural Resources - The cost of ex-
tracting the material for use and any direct or indi-
rect environmental cost for the process.
• Production of Raw Materials - All of the costs of
processing the raw materials.
• Making the Basic Components and Product - The to-
tal cost of material fabrication and product manufac-
turing.
• Internal Storage - The cost of storage of the product
before it is shipped to distributors and retail stores.
• Distribution and Retail Storage - The cost of distrib-
uting the products to retail stores including transpor-
tation costs, and the cost of retail storage before
purchase by the consumer.
• Product Use - The cost of consumer use of the prod-
uct. This could include any fuels, oils, mainte-
nance, and repairs which must be made to the
equipment.
• Product Disposal or Recycling - The cost of disposal
or recycling of the product.
Total Cost Assessment
Justifying pollution prevention projects is not an
easy task, as many Federal facility coordinators have dis-
covered. In the competition for scarce resources, facili-
ties are more likely to fund projects aimed at resolving
Major Concepts
• To tal Cos t A ssessmen t
is a too/ for identifying
the true economic and
environmental costs
associated with current
processes.
• To tal Cos t A ssessmen t
can be used to
evaluate pollution
prevention projects
using both direct and
indirect costs.
• Total Cost Assessment
analyzes: direct costs,
indirect costs, liability
costs, /ess tangible
benefits.
For further information on
TCA, refer to the EPA's
Total Cost Assessment:
Accelerating Industrial
Pollution Prevention
Through Innovative
Project Financial Analysis
(EPA/7417R-9 2/002).
May, 1992.
115
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Appendix A
immediate compliance violations than projects that could
prevent such problems in the long-run. Accounting pro-
cedures typically lump environmental costs together in a
single overhead account, or add them to other budget line
items where they cannot be disaggregated easily. As a
result, facilities are often unable to identify the processes
that cause the greatest environmental expenditures. Us-
ing total cost assessment, fa.cilities can customize account-
ing systems to gather the information necessary for an
accurate identification of costs related to environmental
management. Facilities can also use TCA to demonstrate
potential costs savings from specific pollution prevention
projects.
The TCA tool is especially interesting because it
employs both economic and environmental criteria. TCA
was originally intended for use primarily by private sec-
tor users engaged in a production process. EPA has be-
gun to study how TCA can be used to assess pollution
prevention projects. As with the LCC analysis, the TCA
study is usually focused on a particular process as it af-
fects the bottom-line costs to the user. Environmental
criteria are not explicit, i.e.; success is not measured by
waste reduction or resource conservation, but by cost sav-
ings. However, since the purpose of TCA is to change
accounting practices by internalizing otherwise external
(environmental) costs, environmental goals are met by cost
reductions.
Because of its focus on cost and cost effective-
ness, TCA shares many of the features of LCC analysis
by tracking direct costs (capital expenditures, and O&M
expenses/revenues). However, TCA also includes indi-
rect costs, liability costs and less tangible benefits—sub-
jects that are not customarily included in LCC analysis.
A summary of costs included in TCA is presented in Table
A-3. By factoring in these indirect environmental costs,
TCA achieves both economic and environmental goals.
Because of its private sector orientation, TCA not only
uses NPV as an economic criteria but Internal Rate of
Return (IRR) and Profitability Index (PI) as well.
Major Concepts
• LCA is a tool to
evaluate the
environmental
consequences of a
product or activity
across its entire life.
• A complete LCA
consists of three
components: Inventory,
Impact and
Improvement Analyses.
• Life-cycle inventory
analysis can be used in
process analysis,
material selection,
product evaluation,
product comparison,
and policy-making.
•LCA does not usually
include cost
assessment.
• Life-cycle inventory
analysis can be used
by acquisitions staff,
new product design
staff, and staff
involved in pollution
prevention
• LCA is an evolving tool
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Economic Analyses Methods
TABLE A-3. TCA COST CATEGORIES
Direct Costs
Capital Expenditures
- Buildings
- Equipment
- Utility connections
- Equipment installation
- Engineering
Operation and Maintenance
Expenses/Revenues
- Raw materials
- Labor
- Waste disposal
- Utilities
- Value of recovered
material
Indirect or Hidden Costs
Liability Costs
Compliance Costs
- Permitting
- Reporting
- Monitoring
- Manifesting
Insurance
On-Site Waste Management
Operation of Onsite Pollution
Control Equipment
Penalties and Fines
Personal injury and property
damage
Life-Cvcle Assessment
As its name implies, LCA is a departure from LCC
and TCA because it does not utilize economic criteria, con-
sequently the word "cost" is not included in the LCA termi-
nology. Historically, LCA has been used by both the public
and private sector to identify and evaluate opportunities to
reduce the environmental effects associated with a specific
product, production process, package, material, or activity.
The uses of LCA are to:
• Conserve resources
• Prevent pollution
• Preserve diverse, sustainable ecosystems
• Maintain long-term, viable economic systems
Figure A-l illustrates the typical product life cycle.
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Appendix A
Product
Manufacture
and Assembly
Product
Life-Cycle
Reuse, Recycle,
Treatment,
Disposal
Figure A-l. Product life-cycle.
Inventory analysis
quantifies:
• Energy requirements
• Raw materials
• Environmental releases
GSA's Environmental
Products Guide (RCPG-
0001), formerly the
Recycled Products
Catalogue , is a good
source of information.
EPA defines LCA as a tool for examining the envi-
ronmental releases and impacts of a specific product by track-
ing its development from a raw material through its production
and to eventual disposal. The main reason for using LCA is
to evaluate proposed changes to product or process designs
so that environmental trade-offs can be identified (see Figure
A-l).
The U.S. Postal Service encourages its facilities to
adopt a LCA approach when making decisions that might
impact the environment. Figure A-2 reproduces an LCA for
the manufacturing of Postal Service vehicles which is pub-
lished in the USPS Waste Reduction Guide,
As Figure A-l makes clear, LCA is much less fo-
cused on a single process, product or user. Instead, LCA
takes a truly look at atmospheric emissions, waterborne wastes,
solid wastes, coproducts, resource and energy outputs, and
other releases of environmental concern on the basis of prod-
uct/emission relationships as consumable goods percolate
through the economy. LCA analyzes all the processes in-
cluding extraction and processing of raw materials; manufac-
turing, transportation and distribution; use/reuse/maintenance;
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Economic Analyses Methods
Raw Material
Producers
Paint
Manufacturer
Vehicle
Manufacturer
Vehicle User
Mining/processing
metal constituents
Manufacturing of
chemical constituents
Refining
Pre-production
storage
Manufacturing
paint containers
Mixing paints
Pre-application
storage of paint
Paint application
Maintenance
(touch-up, repainting)
Disposal of vehicle
Transportation
Disposal of paint
1. Mining/processing and manufacturing of paint raw materials
2. Pre-production storage of raw materials for paint
3. Mixing of paints
4. Pre-application storage of paint
5. Application of paint to vehicles
6. Paint maintenance
7. Disposal of vehicles
8. Transportation
Source: Baker, Rachel D., and John Warren. "Management of the Product Life Cycle to Promote Pollution Prevention.
Pollution Prevention Review. Autumn 1991.
Figure A-2. LCA for U.S. Postal Service vehicles.
-------
Appendix A
What is Design for the
Environment?
EPA's Design for the
Environment (DfE)
program promotes
building the use of safer
chemicals, processes,
and technologies into
products during their
earliest design stages.
The DfE program has
three cornerstones: the
gathering of comparative
risk and performance
data; the development of
analytical tools for
assessing that data; and
the dissemination of
both data and analytical
tools to people in various
industries for use in
making environmentally
responsible choices. For
information on
participating in the DfE
program, contact Jean E.
(Libby) Parker,
Economics, Exposure
and Technology Division
(TS-779), U.S. EPA, 401
M Street, S. W.,
Washington, D.C.
20460; telephone (202)
260-0667.
Reprinted from
Chemicals in Progress
Bulletin Office of
Pollution Prevention and
Toxics Vol 14/No. 2
June 1993.
LCA and new product
design go hand-in-hand.
recycling and composting; and final disposition. Instead of
using cost as a criterion, LCA uses environmental impact
criteria such as emissions, waste generation, and effluent vol-
ume. These criteria enable Federal facility coordinators to
quantify the impacts of a specific product on the full range of
environmental media.
LCA is a very useful and evolving tool for the holistic
quantification of impacts without the constraints normally as-
sociated with a rigorous cost analysis with a narrow focus.
The three main components of a life-cycle analysis include
(1) inventory analysis: identifying and quantifying energy and
resource use and environmental releases to air, water, and
land; (2) impact analysis: characterizing and assessing the
impact on the environment; (3) improvement analysis: evalu-
ating and implementing opportunities to reduce environmen-
tal burdens. Of the three components, inventory analysis is
the best developed tool to date.
Inventory Analysis
Facilities use inventory analysis to quantify the en-
ergy and raw material requirements, and all environmental
releases (e.g., air emissions, solid waste, wastewater dis-
charge) during the life cycle of a product, package, process,
material, or activity. As such, LCA is best viewed as a pro-
cess for researching, confirming and disclosing the impor-
tant quantifiable environmental relationships that exist during
each phase of a product, process, material, or activity's life
cycle. Facility personnel involved directly with new design
work and acquisitions should become familiar with LCA as
well as anyone involved in choosing pollution prevention op-
portunities. For example, a facility coordinator may adopt a
life cycle approach to determine whether replacing a solvent
degreaser with a caustic cleaner makes sense in terms of the
total impact on the environment. Does the elimination of
VOC emissions offset the discharge of heavy-metal laden
caustic cleaner to the wastewater treatment plant? Does re-
placing paper towels in the restrooms with reusable cloth or
hand dryers decrease the impact on the environment?
LCA is particularly appropriate for those involved in
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Economic Analyses Methods
acquisitions and new product design. Acquisitions can
include anyone at a Federal facility that orders supplies,
from office staff ordering supplies out of a Federal supply
catalogue, to process design engineers ordering hazard-
ous substances. When ordering office supplies, for in-
stance, staff should be aware that the GSA catalogue
indicates which products contain recycled materials (e.g.,
paper products). It isn't necessary to perform a complete
LCA to realize that from an environmental standpoint,
staff should purchase products with recycled content if
possible.
Design engineers (e.g., DoD weapons acquisition
staff) can use the LCA approach to design or redesign
products to make them environmentally compatible. Typi-
cally design engineers focus exclusively on the product's
quality, performance, and production price. With an LCA
approach, environmental design criteria are given equal
footing with traditional criteria. Design criteria which
are commonly used include whether a design requires the
use of hazardous substances, consumes too much energy
or water, or is not readily recycled or reused. Stating
these criteria up-front helps ensure that products are envi-
ronmentally compatible from the manufacturing stage, and
through operation and maintenance, and final disposal.
Environmental criteria to consider in designing
products:
• Use renewable natural resource materials
• Use materials with recycled content
• Use fewer toxic substances
• Reuse scrap and excess material from production
• Produce goods with a longer life expectancy
• Manufacture products that can be recycled at the end
of their life cycle
LCA is still a relatively new tool, but research and devel-
opment are underway. The EPA, the Society for Envi-
ronmental Toxicology and Chemistry, and many industry
hor further information,
see the EPA Risk
Reduction Engineering
Laboratory's publications:
Life-Cycle Assessment:
Inventory Guidelines,
(EPA/600/R-92/245) this
publication describes the
three components of a
life-cycle assessment and
develops guidelines for
implementation; and
Principles and Life-Cycle
Design Manual:
Environmental
Requirements and the
Product System (EPA/
600/R-92/226) provides
guidance on life-cycle
design principles. Life-
cycle design promotes
the reduction of
environmental impacts
and health risks through
a system approach to
design.
121
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Appendix A
trade groups are actively involved in promoting the develop-
ment of consistent, consensus-based guidelines on the con-
duct of LCA.
3.6.3 Summary
In order to take full advantage of the tools described
in this section, Federal facility coordinators must be willing
to devote time and energy into collecting the necessary cost
and environmental data. A facility with good environmental
recordkeeping and audits should be able to prepare a suitable
data-set within a reasonable period of time. Although devel-
oping the data-set requires an initial investment of time, Fed-
eral facility coordinators will then have the means to prepare
more accurate justifications of pollution prevention projects.
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APPENDIX B
CASE STUDIES
123
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Appendix B
CASE STUDY 1: Air Emission Reductions, Robins Air Force Base
Opportunity Type: Source Reduction — Material Substitution
Project Description:
Robins Air Force Base (AFB) is testing a new technology for corrosion protection coatings
that promises to reduce air pollution. Many standard primers and topcoat paints (such as
two-part epoxies and polyurethanes, alkyd enamels, and Chemical Agent Resistance Coatings)
release volatile organic chemicals when they cure. Considered toxic, these chemicals also
contribute substantially to atmospheric pollution. In addition, the unused paint residues are
classified as hazardous waste.
Robins AFB is checking manufacturers' claims that their new plastic powder coatings
outperform standard coatings. Specifically, the base is conducting tests to flame-spray
these coatings on ground support equipment, mobile communications vans, and munitions
and munitions handling equipment in the field. The coated panels are currently undergoing
tests for chemical resistance properties and accelerated aging.
If test results are favorable, the Air Force will select one or more coatings for field
testing at bases experience serious corrosion problems.
Cost: Not available.
Technology Status: Preliminary testing stage.
(Source: SAIC Newsgram Spring 1993.)
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Case Studies
CASE STUDY 2: Air Emission Reductions, U.S. Navy
Opportunity Type: Source Reduction — Material Substitution
Project Description:
In 1992, the Navy received an EPA Administrator's Award for Pollution Prevention for
the development and implementation of a new paint called Unicoat. Unicoat was developed
by the U.S. Navy Exploratory Development Program for aircraft and other industrial
applications. With no toxic chromate pigments, the new paint reduces volatile organic
compounds and hazardous waste from the painting process by 67 percent. At the same time,
Unicoat provides equivalent or superior performance to the toxic paints the Navy and Air
Force have used in the past.
The traditional painting system for aircraft consists of an epoxy primer for adhesion and
control inhibition, and a polyurethane topcoat for aesthetics, durability, and additional
protection against degradation. This two-coat primer and topcoat painting system contains
high levels of VOCs and carcinogenic chromates. Unicoat, in contrast, is a self-priming
topcoat designed to replace the two coatings with a blend of organic and inorganic zinc
compounds that are nontoxic.
Cost: Not available.
Technology Status: Unicoat is being used in Navy and Air Force applications; efforts are
underway to transfer the technology to the commercial airline and industrial communities.
(Source: adapted from U.S. EPA Pollution Prevention News. May 1992.)
125
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Appendix B
CASE STUDY 3: Air Emission Reductions, DOE
Opportunity Type: Source Reduction — Material Substitution
Project Description:
Many Federal agencies have started testing and evaluating commercially available
substitutes for processes such as degreasing. The Materials Substitution Committee at Los
Alamos National Laboratory identified and tested 20 solvent substitutes for 1,1,1
Trichloroethane.
Criteria for selecting the substitutes included (1) easily accessible and commercially
available, (2) suitability for a wide variety of cleaning operations, (3) non-generator of a
hazardous waste, and (4) perform as well as existing solvent cleaners. Of the 20 products
tested, Inland Technology's X-Caliber performed the best. The toxicological effects of M-
pyrol, a constituent of X-caliber, are currently being tested.
For a summary of the project, contact the Waste Minimization Program Office at 505-
665-8294. The Office will continue identifying substitute solvents that perform effectively,
evaporate quickly, and serve as alternatives to chlorofluorocarbons.
Cost: Not available.
Technology Status: Fully developed products; may require testing prior to use.
(Source: adapted from an article published in the US DOE - Defense Programs newsletter, Pollution Prevention
Advisor, Spring 1993, Vol 3, No. 2.)
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Case Studies
CASE STUDY 4: Cadmium-Free Electroplating,
U.S. Army, Defense Logistics Agency
Opportunity Type: Source Reduction — Material Substitution, Operating Procedures
Project Description:
The Defense Logistics Agency Hazardous Material Minimization Program has modified
more than 50 specifications to use alternatives to cadmium-based plating. The discharge of
cadmium-contaminated plating rinsewaters requires costly wastewater treatment procedures
to remove the cadmium. Cadmium contaminated sludges and process residuals must be
handled as a Resource Conservation and Recovery Act (RCRA) hazardous waste. The
Defense Construction Supply Center, Columbus Ohio, identified more than 40 specifications
that have potential for change. Thirteen specifications have been changed, ranging from
dog collars to automotive radiator caps.
The Defense Personnel Support Center, Philadelphia, Pennsylvania, has changed
specifications for hospital furniture to have an alternative surface finish coating without
cadmium.
The Defense Electronics Supply Center, Dayton, Ohio, is looking for cadmium
replacements for fasteners and other related hardware items. Out of 200,000 cadmium-
plated items, the Defense Electronics Supply has changed the specification for 460 to replace
cadmium with zinc chromate.
Cost: Not available.
Technology Status: Some specifications fully developed, others under development.
(Source: Defense Logistics Agency. Hazardous Material Minimization Program. Unpublished)
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Appendix B
CASE STUDY 5: Hazardous Waste Reduction From Depainting Operations,
U.S. Coast Guard Support Center, Governors Island, New York
Opportunity Type: Source Reduction — Process Modification
Project Description:
This project was developed under RREL's Waste Reduction Evaluations At Federal Sites
(WREAFS) Program. The method the Coast Guard employed to remove paint and rust from
buoys was to use a steel shot blasting method. About 24.0 tons of steel shot were purchased
annually at a cost of $17,040. The shot passes through the system an average of five times
before it is too fragmented to be effective. Approximately, 120 drums (55-gallon) were
disposed of as hazardous waste annually due to the presence of lead. The cost for disposal is
$0.23/lbs or an annual cost of $20,700.
The pollution prevention opportunity identified by the WREAFS team for this process
was to convert from steel shot to plastic media. This conversion can be made relatively
easily and with minimal capital investment. Some minor equipment changes may be necessary;
however, the conversion would markedly reduce the weight of the residual blasting media as
a result of the lighter density material (steel at 299.65 Ibs/ft3 versus plastic bead at 49.94 Ibs/
ft3) and the increased recycle capability (20 cycles anticipated with the plastic versus five
cycles for steel shot).
Cost:
Total capital investment: $6,830
Annual Net Operating Costs Savings: $24,120/yr
Estimated payback for the plastic media blasting system is 3.4 months
Technology Status: Fully developed.
(Source: US EPA. Waste Minimization Opportunity Assessment. U.S. Coast Guard Support Center, Governors
Island, New York. 1990.)
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Case Studies
CASE STUDY 6: Hazardous Waste Reduction of Solvents
by an Aqueous Parts Washer, Naval Base Norfolk
Opportunity Type: Source Reduction - Process Change
Project Description:
To reduce solvent use in the parts cleaning process, aqueous parts washers were installed
aboard the U.S.S. Theodore Roosevelt and at the Shore Intermediate Maintenance Activity
(SIMA) Norfolk. These parts washers use high-pressure water and water-based cleaners,
rather than chemical solvents, to clean the equipment. The parts washers on the U.S.S.
Theodore Roosevelt represent the first such systems aboard ship; Naval Base Norfolk is
working with other ships to install additional systems. Many other commands at the base
and surrounding area have seen demonstrations of this technology and have procured or are
in the process of procuring additional parts washers.
Cost Savings: The installation of the parts washer at SIMA Norfolk resulted in the cancellation
of the base's single largest Safety Kleen solvent contract which will eliminate solvents and
the procurement and disposal of rags, immediately saving the base $24,000 a year. More
than $100,000 can be saved in labor cost the first year.
Technology Status: Fully developed.
(Source: U.S. EPA. Tidewater Interagency Pollution Prevention Progress Report. 1993)
129
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Appendix B
CASE STUDY 7: Hazardous Waste Reduction of Solvents by
Installation of a Jet Parts Washer, Dover Air Force Base
Opportunity Type: Source Reduction — Equipment Modification
Project Description:
Dover Air Force Base's Jet Engine Repair shop used to rely on a three-stage process for
cleaning aircraft engine assemblies and associated parts. The first tank contained a descaler
(potassium hydroxide), which is used for removing carbon deposits from the aircraft parts;
the second tank was a degreaser, which removed lubricants; and the third (Citrisolve — a
limonene extract) was a bearing cleaner, which removed grit. The open, heated tanks created
a hazardous working environment. Fumes and exhaust from the tanks made breathing difficult
while spills from transferring dripping parts increased the risk of accidents. The spent solvents
were classified as a RCRA hazardous waste because of corrosivity.
The shop manager worked with the base environmental program staff to identify an
alternative cleaning system. Research included visiting a Boeing facility that had already
installed a jet parts washer and working closely with vendors. The environmental staff
prepared a cost analysis as part of the request for obtaining funding. An estimated annual
savings of $6,000 was projected. Dover has purchased two jet parts washers for the Jet
Engine repair shop; they are awaiting funding for installation. The base also has several
more washers on order.
Although this pollution prevention project eliminated the generation of a RCRA hazardous
waste, it resulted in the production of a contaminated wastewater that may require pretreatment
prior to discharge.
Cost:
Total equipment cost (approximately): $30,000
Annual cost of detergent: $500
Annual cost of disposal: $1,000
Total Annual Cost: $1,500
Total annual savings in comparison to current system is $6,000. Estimated payback for the
system is 2.5 years.
Technology Status: Full-scale operational.
(Source: SAIC Onsite Pollution Prevention Opportunity Assessment. 1993)
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Case Studies
CASE STUDY 8: Hazardous Material Pharmacy,
U.S. Air Force Center for Environmental Excellence (AFCEE)
Opportunity Type: Source Reduction — Inventory Control
Project Description:
The Air Force is setting up hazardous material pharmacies at bases to reduce the volume
of hazardous materials with expired shelf lives that are disposed of as hazardous wastes. The
hazardous material pharmacy is an improved hazardous materials control program, which is
based on four elements:
1. Centralized control and management of hazardous material inventory replenishments —
The pharmacy is the sole source of hazardous materials to the base.
2. Regulated distribution of hazardous materials — Only limited quantities of hazardous
materials are issued to customers at one time.
3. Material reuse, alternative use, and recycling — The pharmacy serves as a base-wide
waste exchange service to find users for hazardous materials that are turned in as excess.
4. Reduction in the hazardous material and hazardous waste management burden placed on
functional organizations — the base ensures compliance with the waste storage provisions
of RCRA by removing wastes from work areas for accumulation at a small number of
sites under the control of specially trained staff.
Upon request, the pharmacy issues materials to base organizations that have an established
need for the material and have met all regulatory, training, and health, and environmental
protection precautions required for the use of the material. The amount of material released
matches the current need. The pharmacy records each material issued and maintains a history
of materials issued to each customer organization.
Cost Savings: Hill Air Force Base's material acquisition costs dropped from $14 million to
$4 million between 1990 and 1992. Point Magu Naval Air Station's hazardous material
purchases fell from $132,000 to $55,000 during the first year of the program with only one
directorate participating.
Technology Status: Fully developed.
(Source: Air Force Center for Environmental Excellence. Hazardous Material Pharmacy: Commanders''How
To Guide'. 1993)
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Appendix B
CASE STUDY 9: Recycling, Savannah River Site, DOE
Opportunity Type: Recycling Antifreeze and Paint Solvent Wastes
Project Description:
Bechtel Savannah River Inc. (BSRI), the principal subcontractor for Westinghouse
Savannah River Co. at the Savannah River Site, has instituted a pollution prevention program
that includes antifreeze recycling and paint solvent waste recycling. The antifreeze recycling
equipment includes mechanical filtration and chemical treatment. Spent filters are disposed
of as a nonhazardous waste. The recycled antifreeze meets or exceeds ASTM-3306 standards
for protection and performance. In 1991, more than 14,005 liters of antifreeze were recycled
and returned to service in construction equipment and passenger vehicles.
With respect to the paint solvent wastes, BSRI installed two 28 liter distillation units in
1991. Within the next 3 months, more than 757 liters of solvent were reclaimed and reused
as cleaning solvent. This reduced the volume of hazardous waste by 85 to 90 percent.
Cost Savings: Antifreeze — $11,500 in 1991; Solvent distillation — a savings of $13,400 in
the first three months of operation offset the purchase cost of the two distillation units.
Technology Status: Fully developed.
(Source: U.S. DOE - Defense, Programs. Pollution Prevention Advisor. Vol. 3, No. 3. Summer 1993.)
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CASE STUDY 10: Recycling Program, Fort Eustis, VA
Opportunity Type: Recycling
Project Description:
In response to Federal, State and Army requirements (Training and Doctrine Command),
Fort Eustis established a recycling program. The program recycles many types of materials,
including white paper, computer paper, white ledger, colored or coated paper, manila folders,
tab cards, cardboard, pressboard, car batteries, pallets, #1 and #2 plastic, tin cans, wood,
technical manuals, and metals. Ft. Eustis has also implemented curbside recycling service
for the residential areas. The curbside service accepts newspapers, magazines, aluminum
cans, and glass.
In 1992, Fort Eustis recycled approximately 1.6 million kilograms of material for an
annual recycling rate of 22 percent, surpassing the State of Virginia requirements. In addition,
the base recycled the following amounts of materials from March 1990 to November 1992:
• More than 992.25 tons of paper
• More than 1,543.5 tons of metal
• More than 462.6 tons of cardboard
• More than 158 tons of glass
• More than 73.5 tons of aluminum cans
In recognition of its success, the recycling program was given the 1992 Training and
Doctorine Command (TRADOC) Pollution Prevention and Recycling Award and has been
nominated for the Army Pollution Prevention and Recycling Award.
Cost Savings: (1992) avoided landfill disposal cost is $57,780; revenue from sale of recycled
materials is $67,414.
(Source: US EPA. Tidewater Interagency Pollution Prevention Program Progress Report. 1993).
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CASE STUDY 11: Pollution Prevention in the Home, HUD, EPA
Opportunity Type: Policy and Regulatory Development
Project Description:
EPA, Department of Housing and Urban Development (HUD), and 18 other Federal
organizations have organized a Federal interagency task force to reduce the exposure of
children to lead-based paint. In 1991, EPA completed a comprehensive strategy for dealing
with exposure to lead from all sources, including paint. HUD also developed a lead strategy.
In 1992, Congress strengthened these efforts by passing the Residential Lead-Based Paint
Hazard Reduction Act (Title X of the Housing and Community Development Act of 1992).
The new law mandates activities to reduce hazards posed by lead exposure in housing
and establishes an infrastructure for a national program to eliminate childhood lead poisoning.
Congress assigned EPA and HUD primary responsibility for implementing the act. The
Office of Pollution Prevention and Toxic Substances is taking the lead for EPA.
The act's key requirements fall into four categories:
• Training, accreditation, and contractor certification
• Laboratory programs
• Public education
• Hazard identification
In April 1993, EPA and other Federal agencies opened a clearinghouse for disseminating
technical and nontechnical lead-related information. A toll free hotline was established in
November 1992, the phone number is (800) LEAD-FYI.
Eliminating lead from interior and exterior paints was a true pollution prevention
opportunity. While reducing lead exposure does not fall under the traditional definition of
pollution prevention, it is an example of actions Federal agencies can take to reduce the risks
associated with hazardous substances.
(Source: Adapted from U.S. EPA Office of Pollution Prevention and Toxics Chemicals in Progress Bulletin
Vol. 14 No. 2, June 1993.)
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Case Studies
CASE STUDY 12: Miscellaneous Cost Savings
The Defense Logistics Agency (DLA) reports the following cost savings through pollution
prevention:
Packaging: Revision to the packaging standard for isopropyl alcohol reduced air
transport preparation time to a fraction of its previous allocation, but also saved more
than $8,000 in the first year.
Chlorofluorocarbons (CFCs): Requirements were set for elimination of CFCs as a
propellant for all DGSC-rnanaged items by using carbon dioxide gas or a simple pump
mechanism instead. Specification revisions have eliminated 240.0 tons of CFC from
being consumed annually and have saved $540,000 in CFC excise tax.
Solvents: MIL-0-11090, a cleaning compound, is now replaced by aromatic naptha,
a less hazardous and noncarcinogenic cleaning compound. On an annual basis, this
results in 75,003 gallons and saves more than $200,000.
(Source: Defense Logistics Agency, undated)
The Department of Energy's Defense Programs office reports the following costs savings
through pollution prevention:
Ethylene glycol: the Nevada Test Site has begun using an additive in its fleet operations
which greatly extends coolant life. As a result, Nevada Test Site will no longer need
to replace or dispose of 20,000 gallons of antifreeze annually resulting in a cost
avoidance of $245,000.
Oil filters: the Nevada Test site has installed filter crushers for engine oil and hydraulic
filters, fluids are collected and recycled through an off-site vendor. This has resulted
in a cost savings of $428,000 in waste disposal costs.
Chemicals: recycling of chemicals at Sandia National Laboratory (Albuquerque, NM)
through implementation of the Chemical Exchange Program has resulted in a cost
avoidance of $81,500.
Electroplating wastes: Lawrence Livermore National laboratory is saving $400,000
per year as a result of implementing waste minimization technologies in the electroplating
and metal finishing facility. Changes included: relocation of cyanide solutions,
eliminating chromium plating, changing rinsing practices, and the elimination of vapor
degreasers.
(Source: U.S. DOE -Defense Program. Summary of Waste Minimization and Pollution Prevention Activities,
undated)
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Appendix B
CASE STUDY 13: Spent Parts Washer Solution, Fort Riley, KS
Opportunity: Recycling — Equipment Modification
Project Description:
Under the Waste Reduction Evaluations of Federal Sites (WREAFS) program, a PPOA
team assessed a maintenance operation at Fort Riley, Kansas, a U.S. Army Forces Command
facility. The maintenance shop generated a spent aqueous alkaline detergent solution resulting
from cleaning automotive parts. The waste stream contaminants included trace concentrations
of lead, chromium, and cadmium at a pH greater than 12, as well as the oils, grease, and dirt
removed from the automotive parts.
Although the waste stream had been classified as nonhazardous, it was being reclassified
as a RCRA hazardous waste because of its characteristics. As a result, the shop's goal was to
reduce or eliminate this waste stream. The assessment team examined records to determine
the annual volume of the waste generated, its characteristics, the current disposal cost, and the
cost of raw materials (i.e., the replacement cost of the fresh detergent).
The team proposed that the shop install a system to remove the oily contaminants from the
detergent through emulsification, skimming, and filtration. With replenishment with minor
amounts of fresh detergent, the cleaned washwater would then be recirculated to the parts
washer. Buildup of impurities in the recycled washwater would be prevented by purging 25
percent of the used alkaline detergent and recycling 75 percent. The material being purged
would be neutralized with an appropriate amount of waste battery acid (obtained from the
facility's battery shop), treated to remove precipitated trace heavy metals, and disposed of as
a nonhazardous waste.
Cost Savings: $107.00 per year with a payback of . 18 years.
(Source: This project was developed under RREL's Waste Reduction Evaluation At Federal Sites (WREAFS)
Program. WMOA Report and Project Summary - Ft. Riley, Kansas. EPA/600/S2-90/031)
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Case Studies
CASE STUDY 14: General Pollution Prevention Techniques,
USDA Beltsville Agricultural Research Laboratory
Under the Waste Reduction Evaluations of Federal Sites (WREAFS) program, a PPOA
team assessed a major USDA research laboratory, Beltsville Agricultural Research Laboratory
(BARC). BARC employs approximately 900 scientists and technicians who perform research
work in all areas related to the Department of Agriculture activities. State of the art
research is conducted on livestock diseases, animal and human nutrition, animal genetics
and physiology, plant productivity and diseases, and a host of other topics.
The BARC facility generates approximately 22.5 tons of hazardous waste annually at a
disposal cost of approximately $423,000. A strong site-wide hazardous waste management
program is led by the Safely, Occupation Health, and Environmental Section (SOHES)
Office. This program includes: state of the art facilities for solvent bulking; site-wide
hazardous waste training; the presence of collateral hazardous waste duty officers in each
research institute; an E-mail system for trading chemicals on-site; recycling programs; and
many others. An existing strong incentive for pollution prevention on the site is the charge-
back policy. A charge-back policy is a means of making waste generators responsible for
paying for their waste disposal costs. Once generators are financially responsible for their
wastes, they have an incentive to reduce. This incentive, coupled with the environmental
ethic of many researchers and their desire to minimize raw material costs, has already led to
significant pollution prevention on-site. Additional approaches to pollution prevention
identified by the PPOA team are presented in Table 9 in Chapter 6 of this report.
(Source: US EPA. Pollution Prevention Opportunity Assessment: USDA Beltsville Agricultural Research
Laboratory. EPA/600/SR-93/008).
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APPENDIX C
FEDERAL FACILITIES COMPLIANCE ACT
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Appendix C
LEVEL 1 - 1 OF 1 SECTION
UNITED STATES CODE SERVICE
ADVANCE LEGISLATIVE SERVICE
(c) 1992 THE LAWYERS CO-OPERATIVE PUBLISHING COMPANY
Public Law 102-386
102nd Congress
[H.R. 2194]
102 P.L. 386; 1992 H.R. 2194; 106 Stat. 1505
SYNOPSIS:
An Act
To amend the Solid Waste Disposal Act to clarify provisions concerning the appli-
cation of certain requirements and sanctions to Federal facilities.
OCT. 6, 1992 -- PUBLIC LAW 102-386
TEXT: Be it enacted by the Senate and House of Representatives of the United
States of American in congress assembled,
TITLE I - FEDERAL FACILITY COMPLIANCE ACT
[*101] SEC. 101. SHORT TITLE.
This title may be cited as the "Federal Facility Compliance Act of 1992".
[102] SEC. 102. APPLICATION OF CERTAIN PROVISIONS TO FEDERAL
FACILITIES.
(a). In General. Section 6001 of the Solid Waste Disposal Act (42 U.S.C. 6961) is amended
- (1) by inserting "(a) In General. " after "6001."; (2) in the first sentence, by inserting
"and management" before "in the same manner"; (3) by inserting after the first sentence
the following: "The Federal, State, interstate and local substantive and procedural re-
quirements referred to in this subsection include, but are not limited to, all administrative
orders and all civil and administrative penalties and fines, regardless of whether such
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Federal Facility Compliance Act
penalties or fines are punitive or coercive in nature or are imposed for isolated, intermit-
tent, or continuing violations. The United States hereby expressly waives any'immunity
otherwise applicable to the United States with respect to any such substantive or proce-
dural requirement (including, but not limited to, any injunctive relief, administrative order
or civil or administrative penalty or fine referred to in the preceding sentence, or reason-
able service charge). The reasonable service charges referred to in this subsection in-
clude, but are not limited to, fees or charges assessed in connection with the processing
and issuance of permits, renewal of permits, amendments to permits, review of plans,
studies, and other documents, and inspection and monitoring of facilities, as well as any
other nondiscriminatory charges that are assessed in connection with a Federal, State,
interstate, or local solid waste or hazardous waste regulatory program."; and (4) by insert-
ing after the second sentence the following: "No agent, employee, or officer of the Untied
States shall be personally liable of any civil penalty under any Federal, State, interstate,
or local solid or hazardous v/aste law with respect to any act or omission within the scope
of the official duties of the agent, employee, or officer. An agent, employee, or officer of
the United States shall be subject to any criminal sanction (including, but not limited to,
any fine or imprisonment) under any Federal or State solid or hazardous waste law, but
no department, agency, or instrumentality of the executive, legislative, or judicial branch
of the Federal Government shall be subject to any such sanction.".
(b) Administrative Enforcement Actions. Such section is further amended by adding at
the end the following new subsections:
"(b) Administrative Enforcement Actions. (1) The Administrator may commence an ad-
ministrative enforcement action against any department, agency, or instrumentality of the
executive, legislative, or judicial branch of the Federal Government pursuant to the en-
forcement authorities contained in this Act. The Administrator shall initiate an administra-
tive enforcement action against such a department, agency, or instrumentality in the same
manner and under the same circumstances as an action would be initiated against an-
other person. Any voluntary resolution or settlement of such an action shall be set forth in
a consent order.
"(2) No administrative order issued to such a department, agency, or instrumental-
ity shall become final until such department, or agency, or instrumentality has had the
opportunity to confer with the Administrator in the same manner and under the same
circumstances as an action would be initiated against another person. Any voluntary
resolution or settlement of such an action shall be set forth in a consent order.
"(c) Limitation on State Use of Funds Collected From Federal Government. Unless a
State law in effect on the date of the enactment of the Federal Facility Compliance Act of
1992 or a State constitution requires the funds to be used in a different manner, all funds
collected by a State from the Federal Government from penalties and fines imposed for
violation of any substantive or procedural requirement referred to in subsection (a) shall
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Appendix C
be used by the State only for projects designed to improve or protect the environment or
to defray the costs of environmental protection or enforcement.".
(c) Effective Dates. -- (1) In general. Except as otherwise provided in paragraphs (2) and
(3), the amendments made by subsection (a) shall take effect upon the date of the enact-
ment of this Act.
(2) Delayed effective date for certain mixed waste. Until the date that is 3 years
after the date of the enactment of this Act, the waiver of sovereign immunity contained in
section 6001 (a) of the Solid Waste Disposal act with respect to civil, criminal, and admin-
istrative penalties and fines (as added by the amendments made by subsection (a)) shall
not apply to departments, agencies, and instrumentalities of the executive branch of the
Federal Government for violations of section 3004(j) of the Solid Waste Disposal Act
involving storage of mixed waste that is not subject to an existing agreement, permit, or
administrative or judicial order, so long as such waste is managed in compliance with all
other applicable requirements.
(3) Effective date lor certain mixed waste. (A) Except as provided in subpara-
graph (B), after the date that is 3 years after the date of enactment of this Act, the waiver
of sovereign immunity contained in section 6001 (a) of the Solid Waste Disposal Act with
respect to civil, criminal, and administrative penalties and fines (as added by the amend-
ments made by subsection (a)) shall apply to departments, agencies, and instrumentali-
ties of the executive branch of the Federal Government for violations of section 3004(j) of
the Solid Waste Disposal Act involving storage of mixed waste.
(B) With respect to the Department of Energy, the waiver of sovereign immunity
referred to in subparagraph (A) shall not apply after the date that is 3 years after the date
of the enactment of this Act for violations of Section 3004 (j) of such Act involving storage
of mixed waste, so long as the Department of Energy is in compliance with both ~ (i) a
plan that has been submitted and approved pursuant to section 302l(b) of the Solid
Waste Disposal Act and which is in effect; and (ii) an order requiring compliance with
such plan which has been issued pursuant to such section 302l(b) and which is in effect.
(4) Application of waiver to agreements and orders. The waiver of sovereign
immunity contained in section 6001 (a) of the Solid Waste Disposal Act (as added by the
amendments made by subsection (a)) shall take effect on the date of the enactment of this
Act with respect to any agreement, permit, or administrative or judicial order existing on
such date of enactment (and any subsequent modifications to such an agreement, permit,
or order), including, without limitation, any revision of an agreement, permit, or order that
addresses compliance with section 3004(j) of such Act with respect to mixed waste.
(5) Agreement or order. Except as provided in paragraph (4), nothing in this Act
shall be construed to alter, modify, or change in any manner any agreement, permit, or
administrative or judicial order, including, without limitation, any provision of any agree-
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Federal Facility Compliance Act
ment, permit, or order -- (i) that addresses compliance with mixed waste; (ii) that is in
effect on the date of enactment of this Act; and (iii) to which a department, agency, or
instrumentality of the executive branch of the Federal Government is a party'.
[*103] SEC. 103. DEFINITION OF PERSON.
Section 1004(15) of the Solid Waste Disposal Act (42 U.S.C.6903(15)) is amended by
adding the following before the period: "and shall include each department, agency, and
instrumentality of the United States".
[*104] SEC. 014. FACILITY ENVIRONMENTAL ASSESSMENTS.
Section 3007(c) of the Solid Waste Disposal Act (42 U.S.C. 6927(c)) is amended as
follow: (1) the first sentence is amended by striking out "Beginning" and all that follows
through "undertake" and inserting in lieu thereof "The Administrator shall undertake".
(2) The first sentence is further amended by striking out "Federal agency" and
inserting in lieu thereof "department, agency, or instrumentality of the United States".
(3) The section is further amended by inserting after the first sentence the follow-
ing new sentence: "Any State with an authorized hazardous waste program also may
conduct an inspection of any such facility for purposes of enforcing the facility's compli-
ance with the State hazardous waste program.".
(4) The section is further amended by adding at the end the following: "The de-
partment, agency, or instrumentality owning or operating each such facility shall reim-
burse the Environmental Protection Agency for the costs of the inspection of the facility.
With respect to the first inspection of each such facility occurring after the date of the
enactment of the Federal Facility Compliance Act of 1992, the Administrator shall con-
duct a comprehensive ground water monitoring evaluation at the facility, unless such an
evaluation was conducted during the 12-month period preceding such date of enact-
ment.".
[*105] SEC. 105 MIXED WASTE INVENTORY REPORTS AND PLAN.
(a) Mixed Waste Inventory Reports. - "(1) Requirement. Not later than 180 days after the
date of the enactment of the Federal Facility Compliance Act of 1992, the Secretary of
Energy shall submit to the Administrator and to the Governor of each State in which the
Department of Energy stores or generates mixed wastes the following reports: "(A) A
report containing a national inventory of all such mixed wastes, regardless of the time
they were generated, on a State-by-State basis.
"(B) A report containing a national inventory of mixed waste treatment capacities
and technologies.
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Appendix C
"(2) Inventory of wastes. The report required by paragraph (1)(A) shall include the
following: "(A) A description of each type of mixed waste at each Department of Energy
Facility in each State, including, at a minimum, the name of the waste stream.
"(B) The amount of each type of mixed waste currently stored at each Department
of Energy facility in each State, set forth separately by mixed waste that is subject to the
land disposal prohibition requirements of section 3004 and mixed waste that is not sub-
ject to such prohibition requirements.
"(C) An estimate of the amount of each type of mixed waste the Department ex-
pects to generate in the next 5 years at each Department of Energy facility in each state.
"(D) A description of any waste minimization actions the Department has imple-
mented at each Department of Energy facility in each State of each mixed waste stream.
"(E) The EPA hazardous waste code for each type of mixed waste containing
waste that has been characterized at eacli Department of Energy facility in each State for
each mixed waste stream.
"(F) An inventory of each type of waste that has not been characterized by sam-
pling and analysis at each Department of Energy facility in each State.
"(G) The basis for the Department's determination of the applicable hazardous
waste code for each type of mixed waste at each Department of Energy facility and a
description of whether the determination is based on sampling and analysis conducted on
the waste or on the basis of process knowledge.
"(H) A description of the source of each type of mixed waste at each Department of
Energy facility in each State.
"(I) The land disposal prohibition treatment technology or technologies specified
for the hazardous waste component of each type of mixed waste at each Department of
Energy facility in each State.
"(J) A statement of whether and how the radionuclide content of the waste later or
affects use of the technologies described in subparagraph (I).
"(3) Inventory of treatment capacity and technologies. The report required by
paragraph (1)(B) shall include the following:
"(A) An estimate of the available treatment capacity for each waste described in
the report required by paragraph (1)(A) for which treatment technology exist.
"(B) A description, including the capacity, number and location, of each treatment
unit considered in calculating the estimate under subparagraph (A).
"(C) A description, including the capacity, number and location, of any existing
treatment unit that was not considered in calculating the estimate under subparagraph
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Federal Facility Compliance Act
(A) but that could, alone or in conjunction with other treatment units, be used to treat any
of the wastes described in the report required by paragraph (1)(A) to meet the require-
ments of regulations promulgated pursuant to section 3004(m).
"(D) For each unit listed in subparagraph (C), a statement of the reasons why the
unit was not included in calculating the estimate under subparagraph (A).
"(E) A description, including the capacity, number, location and estimated date of
availability, of each treatment unit currently proposed to increase the treatment capacities
estimated under subparagraph (A).
"(F) For each waste described in the report required by paragraph (1)(A) for which
the Department has determined no treatment technology exists, information sufficient to
support such determination and a description of the technological approaches the De-
partment anticipates will need to be developed to treat the waste.
"(4) Comments and revisions. Not later than 90 days after the date of the submis-
sion of the reports by the Secretary of Energy under paragraph (1), the Administrator and
each State which received the reports shall submit any comments they may have con-
cerning the reports to the Department of Energy. The Secretary of Energy shall consider
and publish the comments prior to publication of the final report.
"(5) Requests for additional information. Nothing in this subsection limits or re-
stricts the authority of States or the Administrator to request additional information from
the Secretary of Energy.
"(b) Plan for Development of Treatment Capacities and Technologies. - "(1) Plan re-
quirement. (A)(i) For each facility at which the Department of Energy generates or stores
mixed waste, except any facility subject to a permit, agreement, or order described in
clause (ii), the Secretary of Energy shall develop and submit, as provided in paragraph
(2), a plan for developing treatment capacities and technologies to treat all of the facility's
mixed wastes, regardless of the time they were generated, to the standards promulgated
pursuant to section 3004(m).
"(ii) Clause (i) shall not apply with respect to any facility subject to any permit
establishing a schedule for treatment of such wastes, or any existing agreement or ad-
ministrative or judicial order governing the treatment of such wastes, to which the State is
a party.
"(B) Each plan shall contain the following:
"(i) For mixed wastes for which treatment exist, a schedule for submitting all appli-
cable permit applications, entering into contracts, initiating construction, conducting sys-
tems testing, commencing operations, and processing backlogged and currently generated
mixed wastes.
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Appendix C
"(ii) For mixed wastes for which no treatment technologies exist, a schedule for
identifying and developing such technologies, identifying the funding requirements for
the identification and development of such technologies, submitting treatability study ex-
emptions, and submitting research and development permit applications.
"(iii) For all cases where the Department proposes radionuclide separation of mixed
wastes, or materials derived from mixed wastes, it shall provide an estimate of the volume
of waste generated by each case of radionuclide separation, the estimated costs of waste
treatment and disposal if radionuclide separation is used compared to the estimated costs
if it is not used, and the assumptions underlying such waste volume and cost estimates.
"(C) A plan required under this subsection may provide for centralized, regional, or
on-site treatment of mixed wastes, or any combination thereof.
"(2) Review and approval of plan. (A) For each facility that is located in a State (i)
with authority under State law to prohibit land disposal of mixed waste until the waste has
been treated and (ii) with both authority under State law regulate the hazardous compo-
nents of mixed waste and authorization from the Environmental Protection Agency under
section 3006 to regulate the hazardous components of mixed waste, the Secretary of
Energy shall submit the plan required under paragraph (1) to the appropriate State regu-
latory officials for their review and approval, modification, or disapproval. In reviewing the
plan, the State shall consider the need for regional treatment facilities. The State shall
comments in making its determination on the plan. The State shall approve, approve with
modifications, or disapprove the plan within 6 months after receipt of the plan.
"(B) For each facility located in a State that does not have the authority described
in subparagraph (A), the Secretary shall submit the plan required under paragraph (1) to
the Administrator of the Environmental Protection Agency for review and approval, modi-
fication or disapproval.
A copy of the plan also shall be provided by the Secretary to the State in which
such facility is located. In reviewing the plan, the Administrator shall consider the need
for regional treatment facilities. The Administrator shall consult with the State or States in
which any facility affected by the plan is located and consider public comments in making
a determination on the plar. The Administrator shall approve, approve with modifica-
tions, or disapprove the plan within 6 months after receipt of the plan.
"(C) Upon the approval of a plan under this paragraph by the Administrator or a
State, the Administrator shall issue an order under section 3008(a), or the State shall
issue'an order under appropriate State authority, requiring compliance with the approved
plan.
"(3) Public participation. Upon submission of a plan by the Secretary of Energy to
the Administrator or a State, and before approval of the plan by the Administrator or State,
the Administrator or State shall publish a notice of the available to the public on request.
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Federal Facility Compliance Act
"(4) Revisions of plan. If any revisions of an approved plan are proposed by the
Secretary of Energy or required by the Administer or a State, the provisions of paragraphs
(2) and (3) shall apply to the revisions in the same manner as they apply to the original
plan.
"(5) Waiver of plan requirement. (A) A State may waive the requirement for the
Secretary of Energy to develop and submit a plan under this subsection for a facility
located in the State if the State (i) enters into an agreement with the Secretary of energy
that addresses compliance at: the facility with section 3004(j) with respect to mixed waste,
and (ii) issues an order requiring compliance with such agreement and which is in effect.'
"(B) Any violation of an agreement or order referred to in subparagraph (A) is
subject to the waiver of sovereign immunity contained in section 6001 (a).
"(C) Schedule and Progress Reports -- "(1) Schedule. Not later than 6 months
after the date of the enactment of the Federal Facility Compliance Act of 1992, the Secre-
tary of Energy shall publish in the Federal Register a schedule for submitting the plans
required under subsection (b).
"(2) Progress reports. (A) Not later than the deadlines specified in subparagraph
(B), the Secretary of Energy shall submit to the Committee on Environment and Public
Works of the Senate and the Committee on Energy and Commerce of the House of Rep-
resentatives a progress report containing the following: "(i) An identification, by facility, of
the plans that have been submitted to States or the Administrator of the Environmental
Protection Agency pursuant to subsection (b).
"(ii) the status of State and Environmental Protection Agency review the approval
of each such plan.
"(hi) The number of orders requiring compliance with such plans that are in effect.
"(iv) For the first 2 reports required under this paragraph, an identification of the
plans required under such subsection (b) that the Secretary expects to submit in the 12-
month period following submission of the report.
(B) The Secretary of Energy shall submit a report under subparagraph (A) not later
than 12 months after the date of the enactment of the Federal Facility Compliance Act of
1992, 24 months after such date, and 36 months after such date.".
(2) The table of contents for subtitle C of the Solid Waste Disposal Act (contained
in section 1001) is amended at the end the following new item:
"Sec 3021. Mixed waste inventory reports and plan.".
(b) Definition. Section 1004 of the Solid Waste Disposal Act (42 U.S.C. 6902) is amended
by adding at the end the following new paragraph: "(41) The term 'mixed waste' means
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Appendix C
waste that contains both hazardous waste and source, special nuclear, or by-product
material subject tot he Atomic Energy Act of 1954 (42 U.S.C. 2011 et seq.).".
(c) GAO Report -- (1) Requirement. Not later than 18 months after the date of the enact-
ment of this Act, the Comptroller General shall submit to Congress a report on the Depart-
ment of Energy's progress in complying with section 302l(b) of the Solid Waste Disposal
Act.
(2) Matters to be included. The report required under paragraph (1) shall contain,
at a minimum, the following: (A) The Department of Energy's progress in submitting to the
State or the Administrator of the Environmental Protection Agency a plan for each facility
for which a plan is required under section 302l(b) of the Solid Waste Disposal Act and the
Status of State or Environmental Protection Agency review and approval of each such
plan.
(B) The Department of Energy's progress in entering into orders requiring compli-
ance with any such plans that have been approved.
(C) An evaluation of the completeness and adequacy of each such plan as of the
date of submission of the report required under paragraph (1).
(D) An identification of any recurring problems among the Department of Energy's
submitted plans.
(E) A description of treatment technologies and capacity that have been devel-
oped by the Department of Energy since the date of the enactment of this Act and a list of
the wastes that are expected to be treated by such technologies and the facilities at which
the wastes are generated or stored.
(F) The progress made by the Department of Energy in characterizing its mixed
waste streams at each such facility by sampling and analysis.
(G) An identification and analysis of additional actions that the Department of En-
ergy must take to -- (i) complete submission of all plans required under such section
302l(b) for all such facilities; (ii) obtain the adoption of orders requiring compliance with
all such plans; and (ii) develop mixed waste treatment capacity and technologies.
[*106] SEC. PUBLIC VESSELS.
(a) Amendment. Subtitle C of the Solid Waste Disposal Act (42 U.S.C. 6921 et seq. ) is
further amended by adding at the end the following new section:
"SEC. 3022 PUBLIC VESSELS.
(a) Waste Generated on Public Vessels. Any hazardous waste generated on a public
vessel shall not be subject to the storage, manifest, inspection, or recordkeeping require-
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ments of this Act until such waste is transferred to a shore facility, unless- "(1) the waste
is stored on the public vessel for more than 90 days after the public vessel is placed in
reserve or is otherwise no longer in service; or "(2) the waste is transferred to another
public vessel within the territorial waters of the United States and is stored on such vessel
or another public vessel for more than 90 days after the date of transfer.
"(b) Computation of Storage Period. For purposes of subsection (a), the 90-day period
begins on the earlier of - "(1) the date on which the waste was generated is placed in
reserve or is otherwise no longer in service; or "(2) the date on which the waste is trans-
ferred from the public vessel on which the waste was generated to another public vessel
within the territorial waters on the United States; and continues, without interruption as
long as the waste is stored on the original public vessel (if in reserve or not in service) or
another public vessel.
"(c) Definitions. For purposes of this section: "(1) The term ' public vessel' means a
vessel owned or bareboat chartered and operated by the United States, or by a foreign
nation, except when the vessel is engaged in commerce.
"(2) The terms 'in reserve' and 'in service' have the meanings applicable to those
terms under section 7293 and sections 7304 through 7308 of title 10, United States Code
and regulations prescribed under those sections.
"(d) Relationship to Other Law. Nothing in this section shall be construed as altering or
otherwise affecting the provisions of section 7311 of title 10, United States Code.".
(b) Technical Amendment. The table of contents for subtitle C of such Act (contained in
section 1001) is further amended by adding at the end the following new item:
"Sec. 3022. Public vessels.".
[*107] SEC. 107 MUNITIONS.
Section 3004 of the Solid Waste Disposal Act ( 42 U.S.C. 6924) is amended by adding at
the end the following new subsection:
"(y) Munitions. (1) Not later than 6 months after the date of the enactment of the Federal
Facility Compliance Act of 1992, the Administrator shall propose, after consulting with the
Secretary of Defense and appropriate State officials, regulations identifying when military
munitions become hazardous waste for purposes of this subtitle and providing for the
safe transportation and storage of such waste. Not later than 24 months after such date
and after notice and opportunity for comment, the Administrator shall promulgate such
regulations. Any such regulations shall assure protection of human health and the envi-
ronment.
"(2) For purposes of this subsection, the term 'military munitions' includes chemi-
cal and conventional monitions."
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[*108] SEO 108. FEDERALLY OWNED TREATMENT WORKS.
(a) Amendment. Subtitle C of the Solid Waste Disposal Act (42 U.S.C. 6921 et seq.) is
further amended by adding at the end the following new section:
"SEC. 3023. FEDERALLY OWNED TREATMENT WORKS.
"(a) In General. For purposes of section 1004(27), the phrase 'but does not include solid
or dissolved material in domestic sewage' shall apply to any solid or dissolved material
introduced by a source into a federally owned treatment works if -- "(1) such solid or
dissolved material is subject to a pretreatment standard under section 307 of the Federal
Water Pollution Control Act (33 U.S.C. 1317), and the source is in compliance with such
standard;
"(2) for a solid or dissolved material for which a pretreatment standard has not
been promulgated pursuant to section 307 of the Federal Water Pollution Control Act (33
U.S.C. 1317), the Administrator has promulgated a schedule for establishing such a pre-
treatment standard v/hich would be applicable to such solid or dissolved material not later
than 7 years after the date of enactment of this section, such standard is promulgated nor
before the date established in the schedule, and after the effective date of such standard
the source is in compliance with such standard;
"(3) such solid or dissolved material is not covered by paragraph (1) or (2) and is
not prohibited from land disposal under subsections (d), (e), (f), or (g) of section 3004(m);
or
"(4) notwithstanding paragraphs (1), (2), or (3), such solid or dissolved material is
generated by a household or person which generates less than 100 kilograms of hazard-
ous waste per month unless such solid or dissolved material would otherwise be an acutely
hazardous waste and subject to standards, regulations, or other requirements under this
Act notwithstanding the quantity generated.
"(b) Prohibition. It is unlawful to introduce into a federally owned treatment works any
pollutant that is a hazardous waste.
"(c) Enforcement. (1) Actions taken to enforce this section shall not require closure of a
treatment works if the hazardous waste is removed or decontaminated and such removal
or decontamination is adequate, in the discretion of the Administrator or, in the case of an
authorized State, of the State, to protect human health and the environment.
"(2) Nothing in this subsection shall be construed to prevent the Administrator or
an authorized State from ordering the closure of a treatment works if the Administrator of
State determines such closure is necessary for protection of human health and the envi-
ronment.
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"(3) Nothing in this subsection shall be construed to affect any other enforcement
authorities available to the Administrator or a State under this subtitle.
"(d) Definition. For purposes of this section, the term 'federally owned treatment
works' means a facility that is owned and operated by a department, agency, or instru-
mentality of the Federal Government treating wastewater, a majority of which is domestic
sewage, prior to discharge in accordance with a permit issued under section 402 of the
Federal Water Pollution Control Act.
"(e) Savings Clause. Nothing in this section shall be construed as affecting any
agreement, permit, or administrative or judicial order, or any condition or requirement
contained in such an agreement, permit, or order, that is in existence on the date of the
enactment of this section and the requires corrective action or closure at a federally owned
treatment works or solid waste management unit of facility related to such a treatment
works.".
(b) Technical Amendment. The table of contents for subtitle C of such Act (contained in
section 1001) is further amended by adding at the end the following new item:
"Sec. 3023. Federally-owned treatment works.".
[*109] SEC. 109 SMALL TOWN ENVIRONMENTAL PLANNING.
(a) Establishment. The Administrator of the Environmental Protection Agency (hereafter
referred to as the "Administrator") shall establish a program to assist small communities
in planning and financing environmental facilities. The program shall be known as the
"Small Town Environmental Planning Program".
(b) Small Town Environmental Planning Task Force. (1) The Administrator shall establish
a Small Town Environmental Planning Task Force which shall be composed of represen-
tatives of small towns form different areas of the United States, Federal and State govern-
mental agencies, and public interest groups. The Administrator shall terminate the Task
Force not later than 2 years after the establishment of the Task Force.
(2) The Task Force shall -- (A) identify regulations developed pursuant to Federal
environmental laws which pose significant compliance problems for small towns; (B)
identify means to improve the working relationship between the Environmental Protection
Agency (hereafter referred to as the Agency) and small towns; (C) review proposed
regulations for the protection of the environmental and public health and suggest revi-
sions that could improve the ability of small towns to comply with such regulations; (D)
identify means to promote regionalization of environmental treatment systems and infra-
structure serving small towns to improve the economic condition of such systems and
infrastructure; and (E) provide such oiher assistance to the Administrator as the Adminis-
trator deems appropriate.
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(C) Identification if Environmental Requirements. (1) Not later than 6 months after the
date of the enactment of this Act, the Administrator shall publish a list of requirements
under Federal environmental and public health statutes (and the regulations developed
pursuant to such statutes) applicable to small towns. Not less than annually, the Admin-
istrator shall make such additions and deletions to and from the list as the Administrator
deems appropriate.
(2) The Administrator shall, as part of the Small Town Environmental Planning
Program under this section, implement a program to notify small communities of the regu-
lations identified under paragraph (1) and of future regulations and requirements through
methods that the Administrator determines to be effective to provide information to the
greatest number of small communities, including any of the following: (A) Newspapers
and other periodicals.
(B) Other news media.
(C) Trade, municipal, and other associations that the Administrator determines to
be appropriate.
(D) Direct mail.
(d) Small Town Ombudsman. The Administrator shall establish and staff an Office of the
Small Town Ombudsman. The Office shall provide assistance to small towns in connec-
tion with the Small Town Environmental Planning Program and other business with the
Agency. Each regional office shall identify a small town contact. The Small Town Om-
budsman and the regional contacts also may assist larger communities, but only if first
priority is given to providing assistance to small towns.
(e) Multi-Media Permits. (1) The Administrator shall conduct a study of establishing a
multi-media permitting program for small towns. Such evaluation shall include an analy-
sis of — (A) environmental benefits and liabilities of a multi-media permitting program; (B)
the potential of using such a program to coordinate a small town's environmental and
public health activities; and
(C) The legal barriers, if any, to the establishment of such a program.
(2) Within 3 years after the date of enactment of this Act, the Administrator shall
report to Congress on the result of the evaluation performed in accordance with para-
graph (1). Included in this report shall be a description of the activities conducted pursu-
ant to subsections (a) through (d).
(f) Definition. For purposes of this section, the term "small town" means an incorporated
or unincorporated community (as defined by the Administrator) with a population of less
than 2,500 individuals.
(g) Authorization. There is authorized to be appropriated the sum of $ 5000,000 to imple-
ment this section.
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[*110] SEC. 110 CHIEF FINANCIAL OFFICER REPORT.
The Chief Financial Officer of each affected agency shall submit to Congress an annual
report containing, to the extent practicable, a detailed description of the compliance ac-
tivities undertaken by the agency for mixed waste streams, and an accounting of the fines
and penalties imposed on the agency for violations involving mixed waste.
TITLE II - METROPOLITAN WASHINGTON WASTE MANAGEMENT STUDY ACT
[*201] SEC. 201. SHORT TITLE.
This title may be cited as the "Metropolitan Washington Waste Management Study Act".
[*202] SEC. 202. FINDINGS.
The Congress finds that the 1-95 Sanitary Landfill, in Fortune, Virginia, is located on Fed-
eral land, and the ultimate responsibility for maintaining environmental integrity at such
landfill is on the Federal Government, as well a the signatories to the July 1981 1-95
Sanitary Landfill Memorandum of Understanding.
[*203] SEC 203 ENVIRONMENTAL IMPACT STATEMENT
(a) Environmental Impact Statement. Except as provided in subsection (b), in order to
assure environmental integrity in and around properties owned by the Government of the
United States, no expansion of the 1-95 Sanitary Landfill shall be permitted or otherwise
authorized unless— (1) and environmental impact statement, pursuant to the National
Environmental Policy Act, regarding any such proposed expansion has been completed
and approved by the Administrator; and (2) the costs incurred in conducting and complet-
ing such environmental impact statement are paid (A) from the landfill's so-called enter-
prise fund established pursuant to the July 1981 1-95 Sanitary Landfill Memorandum of
Understanding, or (B) in accordance with some other payment formula based on past and
projected percentage of the jurisdictional usage of the landfill.
(b) Exception. (1) Notwithstanding subsection (a), the 1-95 Sanitary Landfill may be ex-
panded for the purpose of the ash monofill planned by the parties to the July 1981 1-95
Sanitary Landfill Memorandum of Understanding if such monofill, subject to paragraph
(2), is used solely for the disposal of incinerator ash from such parties.
(2) The ash monofill referred to in paragraph (1) may be used for the disposal of
solid waste for a maximum of 30 days whenever a resource recovery facility, or an incin-
erator and a resource recovery facility, operated for or by the parties to the July 1981 1-95
Sanitary Landfill Memorandum of Understanding is completely unavailable because of an
emergency shutdown.
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(c) Limitation. After December 31, 1995, the 1-95 Sanitary Landfill, including any expan-
sions thereof, shall not be available to receive or dispose of municipal or industrial waste
of any kind other than incinerator ash unless the conditions enumerated in subsection (a)
are met.
(d) General. Notwithstanding any other provisions of this title, the parties of the July 1981
1-95 Sanitary Landfill Memorandum of Understanding, together with the Federal Govern-
ment, shall continue to be responsible for maintaining environmental stability at the 1-95
Sanitary Landfill, including any expansion, in accordance with applicable laws of the United
States, the Commonwealth of Virginia, and the local jurisdictions in which the 1-95 Sani-
tary landfill if located.
[*204] SEC. 204 DEFINITIONS.
For purposes of this title: (1) The term "expansion" includes any development or use,
after May 31, 1991, of any lands (other than those lands which were used as a landfill on
or before May 31, 1991) owned by the Government of the United States in and around
Lorton, Virginia, for the purpose of, or use as, a sanitary landfill in accordance with the
July 1981 1-95 Sanitary Landfill Memorandum of Understanding. The term also includes
variances or exemptions from any elevation requirements relating to landfill operations
established by the laws of the Commonwealth of Virginia, or any subdivision thereof, in
connection with any such lands used on or before May 31, 1991.
(2) the term "lands owned by the Government of the United States" includes any
lands owned by the United States, and any such lands with respect to which the Govern-
ment of the District of Columbia has beneficial ownership.
(3) The term "July 1981 1-95 Sanitary Landfill Memorandum of Understanding"
means the document titled "Memorandum of Understanding 1-95 Resource Recovery,
Land Reclamation, and Recreation Complex" that was executed July 22, 1981, and sub-
sequently amended by supplemental agreements executed before May 31,1991.
Speaker of the House of Representatives
Vice President of the United States and President of the Senate
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APPENDIX D
PRESIDENTIAL EXECUTIVE ORDERS
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Appendix D
April 17, 1991
EXECUTIVE ORDER 12759
FEDERAL ENERGY MANAGEMENT
By the authority vested in me as President by the Constitution and the laws of the United States
of America, including the Energy Policy and Conservation Act, as amended (Public Law 94—
163, 89 Stat. 871, 42 U.S.C. 6201 et seq.}, the Motor Vehicle Information and Cost Savings
Act, as amended (15 U.S.C. 1901 et seq.}, section 205(a) of the Federal Property and Adminis-
trative Services Act, as amended (40 U.S.C. 486(a)), and section 301 of title 8 of the United
States Code, it is hereby ordered as follows:
Section 1. Federal Energy Efficiency Goals for Buildings. Each agency shall develop and
implement a plan to meet the 1995 energy management goals of the National Energy Conserva-
tion Policy Act, as amended, 42 U.S.C. 8251 et seq., and by the year 2000 reduce overall energy
use of Btu's per gross square foot of the Federal buildings it operates, taking into account utiliza-
tion, by 20 percent from 1985 energy use levels, to the extent that these measures minimize life
cycle costs and are cost-effective in accordance with 10 CFR Part 436.
Sec. 2. Federal Energy Efficiency Goals for Other Facilities. Each agency will prescribe poli-
cies under which its industrial facilities in the aggregate increase energy efficiency by at least 20
percent in fiscal year 2000 in comparison to fiscal year 1985, to the extent that these measures
minimize life cycle costs are cost-effective in accordance with 10 CFR Part 436. Each agency
shall establish appropriate indicators of energy efficiency to comply with this section.
Sec. 3. Minimization of Petroleum Use in Federal Facilities. Each agency using petroleum
products for facilities operations or building purposes shall seek to minimize such use through
switching to an alternative energy source if it is estimated to minimize life cycle costs and which
will not violate Federal, State, or local clean air standards. In addition, each agency shall survey
its buildings and facilities to determine where the potential for a dual fuel capability exists and
shall provide dual fuel capability where practicable.
Sec. 4. Implementation Strategies, (a) Except as provided by paragraph (b) and (c) of this
section, each agency shall adopt an implementation strategy, consistent with the provisions of
this order, to achieve the goals established in sections 1, 2, and 3. That strategy should include,
but not be limited to, changes in procurement practices, acquisition of real property, participation
in demand side management services and shared savings agreements offered by private firms,
and investment in energy efficiency measures. The mix and balance among such measures shall
be established in a manner most suitable to the available resources and particular circumstances in
each agency.
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Executive Orders
(b) The Secretary of Defense may, if he determines it to be in the national interest, issue
regulations exempting from compliance with the requirements of this order, any weapons, equip-
ment, aircraft, vehicles, or other classes or categories of real or personal property which are
owned or operated by the Armed Forces of the United States (including the Coast Guard) or by
the National Guard of any State and which are uniquely military in nature.
(c) The Secretary and the Attorney General, consistent with their protective and law
enforcement responsibilities, shall determine the extent to which the requirements of this order
shall apply to the protective and law enforcement activities of their respective agencies.
Sec. 5. Procurement of Energy Efficient Goods and Products. In order to assure the purchase of
energy efficient goods and products, each agency shall select for procurement those energy
consuming goods or products which are the most life cycle cost-effective, pursuant to the require-
ments of the Federal Acquisition Regulation. To the extent practicable, each agency shall require
vendors of good to provide appropriate data that can be used to assess the life cycle costs of each
good or product, including cmilding energy system components, lighting systems, office equip-
ment, and other energy using equipment.
Sec. 6. Participation in Demand Side Management Services. Each agency shall review its
procedures used to acquire utility and other related services, and to the extent practicable and
consistent with its strategy established pursuant to section 4, remove any impediments to receiv-
ing, utilizing, and taking demand side management services, incentives, and rebates offered by
utilities and other private sector energy service providers.
Sec. 7. Energy Efficiency Requirement for Current Federal Building Space. Each agency occu-
pying space in Federal buildings shall implement the applicable rules and regulations regarding
Federal property and energy management.
Sec. 8. Energy Efficiency Requirements for Newly Constructed Federal Buildings. Each agency
responsible for the construction of a new Federal building shall ensure that the building is de-
signed and constructed to comply with the energy performance standards applicable to Federal
residential and commercial buildings as set forth in 10 CFR Part 435. Each agency shall establish
certification procedures to implement this requirement.
Sec. 9. Vehicle Fuel Efficiency Outreach Programs. Each agency shall implement outreach
programs including, but not limited to, ride sharing and employee awareness programs to reduce
the petroleum fuel usage by Federal employees and by contractor employees at Government-
owned, contractor-operated facilities.
Sec. 10. Federal Vehicle Fuel Efficiency. Consistent with its mission requirements, each agency
operating 300 or more commercially designed motor vehicles domestically shall develop a plan to
reduce motor vehicle gasoline and diesel consumptions by at least 10 percent by 1995 in compari-
son with fiscal year 1991. The Administrator of General Services, in consultation with the
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Appendix D
Secretary of Energy, shall issue appropriate guidance concerning vehicles to be covered, the use
of alternative/blended fuels, initiatives to improve fuel efficiency of the existing fleet, the use of
modified energy life cycle costing consistent with life cycle costing methods in 10 CFR 436, and
limitations on vehicle type and engine size to be acquired. Each agency electing to use alternative
fuel motor vehicles shall receive credit for such use.
Sec. 11. Procurement of Alternative Fueled Vehicles. The Secretary of Energy, with the coop-
eration of other appropriate agencies, and consistent with other Federal law, shall ensure that the
maximum number practicable of vehicles acquired annually are alternative fuel vehicles as re-
quired by the Alternative Motor Fuels Act of 1988 (42 U.S.C. 6374.) Subject to availability of
appropriations for this purpose, the maximum number practicable of alternative fuel vehicles
produced by original equipment vehicle manufacturers shall be acquired by the end of model year
1995.
Sec. 12. Federal Funding. Within approved agency budget totals, each agency head shall work
to achieve the goals set forth in this order. To the extent that available resources fall short of
requirements, agency heads shall rank energy efficiency investments in descending order of the
savings-to-investment ratios, or their adjusted internal rate of return to establish priority.
Sec. 13. Annual Reports. The head of each agency shall report annually to the Secretary of
Energy, in a format specified by the Secretary after consultation with the heads of affected
agencies, on progress in achieving the goals of this Executive order with respect to Federal
buildings, facilities, and vehicles subject to this order. The Secretary of Energy will prepare a
consolidated report to the President annually on the implementation of this order.
Sec. 14. Definitions. For the purpose of this order—
(a) the term "energy use" means the energy that is used at a building or facility and
measured in terms of energy delivered to the building or facility;
(b) the term "Federal building" means any building in the United States which is con-
trolled by the Federal Government for its use.
[Signed] WILLIAM J. CLINTON
THE WHITE HOUSE,
April 17, 1992.
[FR Doc. 91g89473
Filed 4-18-91; 10:33 am]
Billing code 3195-01-M
Editorial note: For the President's remarks on signing Executive Order 12759, see the Weekly
Compilation of Presidential Documents (vol. 27, no. 16).
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(This Order was revoked by E.O. 12873, and is included here only for information)
EXECUTIVE ORDER 12780
FEDERAL AGENCY RECYCLING AND THE COUNCIL
ON FEDERAL RECYCLING AND PROCUREMENT POLICY
WHEREAS, this Administration is determined to secure for future generations of Ameri-
cans their rightful share of our Nation's natural resources, as well as a clean and healthful
environment in which to enjoy them; and
WHEREAS, two goals of the Administration's environmental policy, cost-effective pol-
lution prevention and the conservation of natural resources, can be significantly advanced by
reducing waste and recycling the resources used by this generation of Americans' and
WHEREAS, the Federal Government, as one of the Nation's largest generators of solid
waste, is able through cost effective waste reduction and recycling resources to conserve local
government disposal capacity; and
WHEREAS, the Federal Government, as the Nation's largest single consumer is able
through affirmative procurement practices to encourage the development of economically effi-
cient markets for products manufactured with recycled materials;
NOW, THEREFORE, I, GEORGE BUSH, by the authority vested in me as President by
the Constitution and the laws of the United States of America, including the Solid Waste Disposal
Act, Public Law 89-272, 79 Stat. 997, as amended by the Resource Conservation and Recovery
Act ("RCRA"), Public Law 94-580, 90 Stat. 2795 (1976), hereby order as follows:
PART 1-PREAMBLE
Section 101. The purpose of this Executive order is to:
(a) Require that Federal agencies promote cost-effective waste reduction and recycling of
reusable materials from wastes generated by Federal Government activities.
(b) Encourage economically efficient market demand for designated items produced
using recovered materials by directing the immediate implementation of cost-effective Federal
procurement preference programs favoring the purchase of such items.
(c) Provide a forum for the development and study of policy options and procurement
practices that will promote environmentally sound and economically efficient waste reduction
and recycling of our Nation's resources.
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Appendix D
(d) Integrate cost-effective waste reduction and recycling programs into all Federal agency
waste management programs in order to assist in addressing the Nation's solid waste disposal
problems.
(e) Establish Federal Government leadership in addressing the need for efficient State
and local solid waste management through implementation of environmentally sound and eco-
nomically efficient recycling.
Sec. 102. Consistent with section 6002(c)(l) of RCRA (42 U.S.C. 6962(c)(l)), activities and
operations of the executive branch shall be conducted in an environmentally responsible manner,
and waste reduction and recycling opportunities shall be utilized to the maximum extent practi-
cable, consistent with economic efficiency.
Sec. 103. Consistent with section 6002(c)(2) of RCRA (42 U.S.C. 6962(c)(2)), agencies that
generate energy from fossil fuel in systems that have the technical capacity of using energy or
fuels derived from solid waste as a primary or supplementary fuel shall use such capability to the
maximum extent practicable.
PART 2-DEFINITIONS
For purposes of this order:
Sec. 201. "Federal agency" means any department, agency, or other instrumentality of the
executive branch.
Sec. 202. "Procurement" and "acquisition" are sued interchangeably to refer to the processes
through which Federal agencies purchase products.
Sec. 203. "Recovered materials" is used as defined in section 1004(19) and 6002(h) of the
Resource Conservation and Recovery Act (42 U.S.C. 6903(19) and 6962(h)), as amended.
Sec 204. "Recycling" means the diversion of materials from the solid waste stream and the
beneficial use of such materials. Recycling is further defined as the result of a series of activities
by which materials that would become or otherwise remain waste, are diverted from the solid
waste stream by collection, separation processing and are used as raw materials in the manufac-
ture of goods sold or distributed in commerce or the reuse of such materials as substitutes for
goods made of virgin materials.
Sec. 205. "Waste reduction" means any change in a process, operation, or activity that results in
the economically efficient reduction in waste material per unit of production without reducing the
value output of the process, operation, or activity, taking into account the health and environ-
mental consequences of such change.
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PART 3-SOLID WASTE RECYCLING PROGRAMS
Sec. 301. Recycling Programs. Each Federal agency that has not already done so shall initiate
a program to promote cost-effective waste reduction and recycling of reusable materials in all of
its operations and facilities. These programs shall foster (a) practices that reduce waste genera-
tion, and (b) the recycling of recyclable materials such as paper, plastic, metals, glass, used oil,
lead acid batteries, and tires and the composting of organic materials such as yard waste. The
recycling programs implemented pursuant to this section must be compatible with applicable
State and local recycling requirements.
Sec. 302. Contractor Operated Facilities. Every contract that provides for contractor operation
of a Government-owned or leased facility, awarded more than 210 days after the effective date of
this Executive order, shall include provisions that obligate the contractor to comply with the
requirements of this Part as fully as though the contractor were a Federal agency.
PART 4-VOLUNTARY STANDARDS
Sec. 401. Amendment of OMB Circular No. A-119. The Director of the Office of Management
and Budget ("OMB") shall amend, as appropriate, OMB Circular No. A-119, "Federal Partici-
pation in the Development and Use of Voluntary Standards," to encourage Federal agencies to
participate in the development of environmentally sound and economically efficient standards
and to encourage Federal agency use of such standards.
PART 5-PROCUREMENT OF RECOVERED MATERIALS
Sec. 501. Adoption of Affirmative Procurement Programs. Within 180 days after the effective
date of this order, each Federal agency shall provide a report to the Administrator of the Environ-
mental Protection Agency regarding the Agency's adoption of an affirmative procurement pro-
gram; such programs are required by section 6002(i) of RCRA (42 U.S.C. 6962(i)). Within 1
year of the issuance of this order, the Administrator of the Environmental Protection Agency
shall report to the President regarding the compliance of each Federal agency with this require-
ment.
Sec. 502. Annual Review of Affirmative Procurement Programs. In accordance with section
6002(i) of RCRA (42 U.S.C. 6962(i)), each Federal agency shall review annually the effective-
ness of its affirmative procurement program and shall provide a report regarding its findings to
the Environmental Protection Agency and to the Office of Federal Procurement Policy, begin-
ning with a report covering fiscal year 1992. Such report shall be transmitted by December 15
each year. Reports required by this section shall be made available to the public.
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Appendix D
PART 6-RECYCLING COORDINATORS AND THE COUNCIL ON FEDERAL RECY-
CLING AND PROCUREMENT POLICY
Sec. 601. Federal Recycling Coordinator. Within 90 days after the effective date of this order,
the head of each Federal agency shall designate an agency employee to serve as Agency Recy-
cling Coordinator. The Federal Recycling Coordinator shall review and report annually to OMB,
at the time of agency budget submissions, the actions taken by the agencies to comply with the
requirements of this order.
Sec. 602. Designation of Recycling Coordinators. Within 90 days after the effective date of this
order, the head of each Federal agency shall designate an agency employee to serve as Agency
Recycling Coordinator. The Agency Recycling Coordinator shall be responsible for:
(a) coordinating the development of an effective agency waste reduction and recycling
program that complies with the comprehensive implementation plan developed by the Council on
Federal Recycling and Procurement Policy;
(b) coordinating agency action to develop benefits, costs, and savings data measuring the
effectiveness of the agency program; and
(c) coordinating the development of agency reports required by this Executive order and
providing copies of such reports to the Environmental Protection Agency.
Sec. 603. The Council on Federal Recycling and Procurement Policy, (a) A Council on Federal
recycling and Procurement Policy is hereby established. It shall comprise the Federal Recycling
coordinator, the Chairman of the Council on Environmental Quality, the Administrator of the
Office of Federal Procurement Policy, and the Agency Recycling Coordinator and the Procure-
ment Executive of each of the following agencies: the Environmental Protection Agency, the
Department of Defense, the General Service Administration, the National Aeronautics and Space
Administration, the Department of Energy, the Department of Commerce, and the Department
of the Interior. The Federal Recycling coordinator shall serve as Chair of the Council.
(b) Duties. The Council on Federal Recycling and Procurement Policy shall:
(1) identify and recommend, to OMB, initiatives that will promote the purposes of
this order, including:
(A) the development of appropriate incentives to encourage the economically effi-
cient acquisition by the Federal Government of products that reduce waste and of prod-
ucts produced with recycled materials;
(B) the development of appropriate incentives to encourage active participation in
economically efficient Federal waste reduction and recycling programs; and
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(C) the development of guidelines for cost-effective waste reduction and recycling
activities by Federal agencies;
(2) review Federal agency specifications and standards and recommend changes that will
enhance Federal procurement of products made from recycled and recyclable materials, taking
into account the costs and the performance requirements of each agency;
(3) collect and disseminate Federal agencies' information concerning methods to reduce
wastes, types of materials that can be recycled, the costs and savings associated with recycling,
and the current market sources and prices of products that reduce waste and of products produced
with recycled materials;
(4) assist the development of cost-effective waste reduction and recycling programs
pursuant to this order by developing guidelines for agency waste reduction and recycling pro-
grams and by identifying long-range goals for Federal waste reduction and recycling programs;
(5) provide meaningful data to measure the effectiveness and progress of Federal waste
reduction and recycling programs;
(6) provide guidance and assistance to the Agency Recycling Coordinators in setting up
and reporting on agency programs; and
(7) review Federal agency compliance with section 103 of this order.
PART 7-LEVIITATION
Sec. 701. This order is intended only to improve the internal management of the executive
branch and shall not be interpreted to create any right or benefit, substantive or procedural,
enforceable at law by a party against the United States, its officers, or any other person.
Sec. 702. Section 502 and Part 6 of this order shall be effective for 5 years only, beginning on
the effective date of this order.
Sec. 703. This order shall be effective immediately.
[Signed] GEORGE BUSH
THE WHITE HOUSE,
October 31, 1991.
[FR Doc. 91-26646
Filed 10-31-91; 12:42 pm]
Billing code 3195-01-M
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Appendix D
April 21, 1993
EXECUTIVE ORDER 12843
PROCUREMENT REQUDIEMENTS AND POLICIES FOR FEDERAL AGENCIES
FOR OZONE-DEPLETING SUBSTANCES
WHEREAS, the essential function of the stratospheric ozone layer is shielding the Earth
from dangerous ultraviolet radiation; and
WHEREAS, the production and consumption of substances that cause the depletion of
stratospheric ozone are being rapidly phased out on a worldwide basis with the support and
encouragement of the United States; and
WHEREAS, the Montreal Protocol on Substances that Deplete the Ozone Layer, to which
the United States is a signatory, calls for a phaseout of the production and consumption of these
substances; and
WHEREAS, the Federal government, as one of the principal users of these substances, is
able through affirmative procurement practices to reduce significantly the use of these substances
and to provide leadership in their phaseout; and
WHEREAS, the use of alternative substances and new technologies to replace these ozone-
depleting substances may contribute positively to the economic competitiveness on the world
market of U.S. manufacturers of these innovative safe alternatives;
NOW, THEREFORE, I, WILLIAM JEFFERSON CLINTON, by the authority vested in
me as President by the Constitution and the laws of the United States of America, including the
1990 amendments to the Clean Air Act ("Clean Air Act Amendments"), Public Law 101-549,
and in order to reduce the Federal government's procurement and use of substances that cause
stratospheric ozone depletion, do hereby order as follows:
Section 1. Federal Agencies. Federal agencies shall, to the extent practicable:
(a) conform their procurement regulations and practices to the policies and requirements
of Title VI of the Clean Air Act Amendments, which deal with stratospheric ozone protection;
(b) maximize the use of safe alternatives to ozone-depleting substances;
(c) evaluate the present and future uses of ozone-depleting substances, including making
assessments of existing and future needs for such materials and evaluate their use of and plans for
recycling;
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(d) revise their procurement practices and implement cost-effective programs both to
modify specifications and contracts that require the use of ozone-depleting substances and to
substitute non-ozone-depleting substances to the extent economically practicable; and
(e) exercise leadership, develop exemplary practices, and disseminate information on
successful efforts in phasing out ozone-depleting substances.
Sec. 2. Definitions, (a) "Federal agency" means any executive department, military depart-
ment, or independent agency within the meaning of 5 U.S.C. 101, 102, or 104(1), respectively.
(b) "Procurement" and "acquisition" are used interchangeably to refer to the processes
through which Federal agencies purchase products and services.
(c) "Procurement regulations, policies and procedures" encompasses the complete acqui-
sition process, including the generation of product descriptions by individuals responsible for
determining which substances must be acquired by the agency to meet its mission.
(d) "Ozone-depleting substances" means the substances controlled internationally under
the Montreal Protocol and nationally under Title VI of the Clean Air Act Amendments. This
includes both Class I and Class II substances as follows:
(i) "Class I substance" means any substance designated as Class I in the Federal Register
notice of July 30, 1992 (57 Fed. Reg. 33753), including chlorofluorocarbons, halons,
carbon tetrachloride, and methyl chloroform and any other substance so designated by
the Environmental Protection Agency ("EPA") by regulation at a later date; and
(ii) "Class II substance" means any substance designated as Class II in the Federal Regis-
ter notice of July 30, 1992 (57 Fed. Reg. 33753), including hydrochlorofluorocarbons
and any other substances so designated by EPA by regulation at a later date.
(e) "Recycling" is used to encompass recovery and reclamation, as well as the reuse of
controlled substances.
Sec. 3. Policy. It is the policy of the Federal Government that Federal agencies: (i) implement
cost-effective programs to minimize the procurement of materials and substances that contribute
to the depletion of stratospheric ozone; and (ii) give preference to the procurement of alternative
chemicals, products, and manufacturing processes that reduce overall risks to human health and
the environment by lessening the depletion of ozone in the upper atmosphere. In implementing
this policy, prior to final promulgation of EPA regulations on Federal procurement, Federal
agencies shall begin conforming their procurement policies to the general requirements of Title
VI of the Clean Air Act Amendments by:
(a) minimizing, where economically practicable, the procurement of products containing
or manufactured with Class I substances in anticipation of the phaseout schedule to be promul-
gated by EPA for Class I substances, and maximizing the use of safe alternatives. In developing
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Appendix D
their procurement policies, agencies should be aware of the phaseout schedule for Class II sub-
stances;
(b) amending existing contracts, to the extent permitted by law and where practicable, to
be consistent with the phaseout schedules for Class I substances. In awarding contracts, agencies
should be aware of the phaseout schedule for Class II substances in awarding contracts;
(c) implementing policies and practices that recognize the increasingly limited availabil-
ity of Class I substances as production levels capped by the Montreal Protocol decline until final
phaseout. Such practices shall include, but are not limited to:
(i) reducing emissions and recycling ozone-depleting substances;
(ii) ceasing the purchase of nonessential products containing or manufactured with ozone-
depleting substances; and
(iii) requiring that new contracts provide that any acquired products containing or manu-
factured with Class I or Class II substances be labeled in accordance with section 611
of the Clean Air Act Amendments.
Sec. 4. Responsibilities. Not later than 6 months after the effective date of this Executive order,
each Federal agency, where feasible, shall have in place practices that, were economically prac-
ticable, minimize the procurement of Class I substances. Agencies also shall be aware of the
phaseout schedule for Class II substances. Agency practices may include, but are not limited to:
(a) altering existing equipment and/or procedures to make use of safe alternatives;
(b) specifying the use of safe alternatives and of goods and services, where available, that
do not require the use of Class 1 substances in new procurements and that limit the use of Class II
substances consistent with section 612 of the Clean Air Act Amendments; and
(c) amending existing contracts, to the extent permitted by law and where practicable, to
require the use of safe alternatives.
Sec. 5. Reporting Requirements. Not later than 6 months after the effective date of this Execu-
tive order, each Federal agency shall submit to the Office of Management and Budget a report
regarding the implementation of this order. The report shall include a certification by each
agency that its regulations and procurement practices are being amended to comply with this
order.
Sec. 6. Exceptions. Exceptions to compliance with this Executive order may be made in accor-
dance with section 604 of the Clean Air Act Amendments and with the provisions of the Montreal
Protocol.
Sec. 7. Effective Date. This Executive order is effective 30 days after the date of issuance.
Although full implementation of this order must await revisions to the Federal Acquisition Regu-
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lations ("FAR"), it is expected that Federal agencies will take all appropriate actions in the
interim to implement those aspects of the order that are not dependent upon regulatory revision.
Sec. 8. Federal Acquisition Regulatory Councils. Pursuant to section 6(a) of the Office of
Federal Procurement Policy Act, as amended, 41 U.S.C. 405(a), the Defense Acquisition Regu-
latory Council and the Civilian Agency Acquisition Council shall ensure that the policies estab-
lished herein are incorporated in the FAR within 180 days from the date this order is issued.
Sec. 9. Judicial Review. This order does not create any right or benefit, substantive or proce-
dural, enforceable by a non-Federal party against the United States, its officers or employees, or
any other person.
[Signed] WILLIAM /. CLINTON
THE WHITE HOUSE,
April 27, 7993.
[FR Doc. 93-9757
Filed 4-22-93; 10:48 am]
Billing code 3195-01-M
Editorial note: For the President's remarks on Earth Day, see issue 16 of the Weekly Compila-
tion of Presidential Documents.
April 21, 1993
EXECUTIVE ORDER 12844
FEDERAL USE OF ALTERNATIVE FUELED VEHICLES
By the authority vested in me as President by the Constitution and the laws of the United State of
America, including the Energy Policy and Conservation Act, as amended (42 U.S.C. 6201 et
seq.}, the Motor Vehicle Information and Cost Savings Act, as amended (15 U.S.C. 1901 et
seq.}, the Energy Policy Act of 1992 (Public Law 102-486), and section 301 of title 3, United
States Code, it is hereby ordered as follows:
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Appendix D
Section 1. Federal Leadership and Goals. The use of alternative fueled motor vehicles can, in
some applications, substantially reduce pollutants in the atmosphere, create significant domestic
economic activity and stimulate jobs creation, utilize domestic fuel sources as defined by the
Energy Policy Act of 1992, and reduce vehicle maintenance costs.
Moreover, Federal action can provide a significant market impetus for the development and
manufacture of alternative fueled vehicles, and for the expansion of the fueling infrastructure
necessary to support large numbers of privately owned alternative fueled vehicles.
The Federal Government can exercise leadership in the use of alternative fueled vehicles. To that
end, each agency shall adopt aggressive plans to substantially exceed the alternative fueled ve-
hicle purchase requirements established by the Energy Policy Act of 1992.
Section 2. Alternative Fueled Vehicle Requirements. The Federal Government shall acquire,
subject to the availability of funds and considering life cycle costs, alternative fueled vehicles in
numbers that exceed by 50 percent the requirements for 1993 through 1995 set forth in the
Energy Policy Act of 1992. The Federal fleet vehicle acquisition program shall be structured
with the objectives of: (a) continued reduction in the incremental cost associated with specific
vehicle and fuel combinations; (b) long-term movement toward increasing availability of alterna-
tive fueled vehicles produced as standard manufacturers' models; and (c) minimizing life cycle
costs in the acquisition of alternative fueled vehicles. In addition, there is established, for a
period not to exceed 1 year, the Federal Fleet Conversion Task Force, a Federal interagency
implementation committee to be constituted by the Secretary of Energy, in consultation with a
Task Force Chairman to be named by the President. The Task Force will advise on the imple-
mentation of this Executive order. The Task Force will issue a public report within 90 days,
setting forth a recommended plan and schedule of implementation and, no later than 1 year from
the date of this order, in cooperation with the Secretary of Energy, file a report on the status of
the conversion effort.
Section 3. Alternative Fueled Vehicle Acquisition Assistance. Within available appropriations,
and a required by the Energy Policy Act of 1992, the Secretary of Energy shall provide assistance
to other agencies that acquire alternative fueled vehicles. This assistance includes payment of
incremental costs associated with acquisition and disposal. All vehicles, whether conversions or
purchases as original equipment manufacturer models, shall comply with all applicable Federal
and State emissions and safety standards, consistent with those requirements placed on original
equipment manufacturers, including years and mileage.
Section 4. Alternative Fueled Vehicle Purchase and Use Incentives. The Administrator of the
General Services Administration, to the extent allowed by law, may provide incentive* to pur-
chase alternative fueled vehicles, including priority processing of procurement requests, and,
with the Secretary of energy, provide any other technical or administrative assistance aimed at
accelerating the purchase and use of Federal alternative fueled vehicles.
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Section 5. Cooperation with Industry and State and Local Authorities on Alternative Fueled
Vehicle Refueling Capabilities. The Secretary of Energy shall coordinate Federal planning and
siting efforts with private industry fuel suppliers, and with State and local governments, to ensure
that adequate private sector refueling capabilities exist or will exist wherever Federal fleet alter-
native fueled vehicles are sited. Each agency's fleet managers are expected to work with appro-
priate organizations at their respective locations on initiatives to promote alternative fueled vehicle
use.
Section 6. Reporting. The head of each agency shall report annually to the Secretary of Energy
on actions and progress under this order, consistent with guidance provided by the Secretary.
The Secretary shall prepare a consolidated annual report to the President and to the Congress on
the implementation of this order. As part of the report, the Secretary and the Director of the
Office of Management and Budget shall complete a thorough, objective evaluation of alternative
fueled vehicles. The evaluation shall consider operating and acquisition costs, fuel economy,
maintenance, and other factors as appropriate.
Section 7. Definitions. For the purpose of this order, the terms "agency" and "alternative
fueled vehicle" have the same meanings given such terms in sections 151 and 301 of the Energy
Policy Act of their respective agencies.
Section 8. Exceptions. The Secretary of Defense, the Secretary of the Treasury, and the Attor-
ney General, consistent with the national security and protective and law enforcement activities
of their respective agencies, shall determine the extent to which the requirements of this order
apply to the national security and protective and law enforcement activities of their respective
agencies.
Section 9. Judicial Review. This order is not intended to create any right or benefit, substantive
or procedural, enforceable by a non-Federal party against the United States, its officers or em-
ployees, or any other person
[Signed] WILLIAM J. CLINTON
THE WHITE HOUSE,
April 21, 1993.
[PR Doc. 93-9751
Filed 4-22-93; 10:33 am]
Billing code 3195-01-M
Editorial note: For the President's remarks on Earth Day, see issue 16 of the Weekly Compila-
tion of Presidential Documents.
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Appendix D
April 21, 1993
EXECUTIVE ORDER 12845
REQUIRING AGENCIES TO PURCHASE
ENERGY EFFICIENT COMPUTER EQUIPMENT
WHEREAS, the Federal Government should set an example in the energy efficient opera-
tion of its facilities and the procurement of pollution preventing technologies;
WHEREAS, the Federal Government should minimize its operating costs, make better
use of taxpayer-provided dollars, and reduce the Federal deficit; and
WHEREAS, the Federal Government is the largest purchaser of computer equipment in
the world and therefore has the capacity to greatly accelerate the movement toward energy effi-
cient computer equipment;
NOW, THEREFORE, by the authority vested in me as President by the Constitution and
the laws of the United States of America, including section 381 of the Energy Policy and Conser-
vation Act, as amended (42 U.S.C. 6361), section 205 of the Federal Property and Administra-
tive Services Act, as amended (40 U.S.C. 486), section 152 of the Energy Policy Act of 1992
(Public Law 102-486), and section 301 of title 3, United States Code, and to ensure the energy
efficient operation of the Federal Government's facilities and to encourage the procurement of
pollution preventing technologies that will save taxpayer money, reduce the Federal deficit, and
accelerate the movement to energy efficient designs in standard computer equipment, it is hereby
ordered as follows:
Section 1. Procurement of Computer Equipment that Meets EPA Energy Star Requirements for
Energy Efficiency, (a) The heads of Federal agencies shall ensure that, within 180 days from the
date of this order, all acquisitions of microcomputers, including personal computers, monitors,
and printers, meet "EPA Energy Star" requirements for energy efficiency, the heads of Federal
agencies may grant, on a case-by-case basis, exemptions to this directive for acquisitions, based
upon the commercial availability of qualifying equipment, significant cost differential of the
equipment, the agency's performance requirements, and the agency's mission.
(b) Within 180 days from the date of this order, agencies shall specify that microcomput-
ers, including personal computers, monitors, and printers, acquired by the agency shall be equipped
with the energy efficient low-power standby feature as defined by the EPA Energy Star comput-
ers program. This feature shall be activated when the equipment is shipped and shall be capable
of entering and recovering from the low-power state unless the equipment meets Energy Star
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efficiency levels at all times. To the extent permitted by law, agencies shall include this specifi-
cation in all existing and future contracts, if both the Government and the contractor agree, and
if any additional costs would be offset by the potential energy savings.
(c) Agencies shall ensure that Federal users are made aware of the significant economic
and environmental benefits of the energy efficient low-power standby feature and its aggressive
use by including this information in routine computer training classes.
(d) Each agency shall report annually to the General Services Administration on acquisi-
tions exempted from the requirements of this Executive order, and the General Services Admin-
istration shall prepare a consolidated annual report for the President.
Sec. 2. Definition. For purposes of this order, the term "agency" has the same meaning given
it in section 151 of the Energy Policy Act of 1992.
Sec. 3. Judicial Review. This order does not create any right or benefit, substantive or proce-
dural, enforceable by a non-Federal party against the United States, its officers or employees, or
any other person.
[Signed] WILLIAM J. CLINTON
THE WHITE HOUSE,
April 21, 1993.
[FR Doc. 93-9757
Filed 4-22-93; 10:48 am]
Billing code 3195-01-M
Editorial note: For the President's remarks on Earth Day, see issue 16 of the Weekly Compila-
tion of Presidential Documents.
171
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Appendix D
August 4, 1993
EXECUTIVE ORDER 12856
FEDERAL COMPLIANCE WITH RIGHT-TO-KNOW LAWS AND
POLLUTION PREVENTION REQUIREMENTS
WHEREAS, the Emergency Planning and Community Right-to-Know Act of 1986 (42
U.S.C. 11001-11050) (EPCRA) established programs to provide the public with important infor-
mation on the hazardous and toxic chemicals in their communities, and established emergency
planning and notification requirements to protect the public in the event of a release of extremely
hazardous substances;
WHEREAS, the Federal Government should be a good neighbor to local communities by
becoming a leader in providing information to the public concerning toxic and hazardous chemi-
cals and extremely hazardous substances at Federal facilities, and in planning for and preventing
harm to the public through the planned or unplanned releases of chemicals;
WHEREAS, the Pollution Prevention Act of 1990 (42 U.S.C. 13101-13109) (PPA) es-
tablished that it is the national policy of the United States that, whenever feasible, pollution
should be prevented or reduced at the source; that pollution that cannot be prevented should be
recycled in an environmentally safe manner; that pollution that cannot be prevented or recycled
should be treated in an environmentally safe manner; and that disposal or other release into the
environment should be employed only as a last resort and should be conducted in an environmen-
tally safe manner;
WHEREAS, the PPA required the Administrator of the Environmental Protection Agency
(EPA) to promote source reduction practices in other agencies;
WHEREAS, the Federal Government should become a leader in the field of pollution
prevention through the management of its facilities, its acquisition practices, and in supporting
the development of innovative pollution prevention programs and technologies;
WHEREAS, the environmental, energy, and economic benefits of energy and water use
reductions are very significant; the scope of innovative pollution prevention programs must be
broad to adequately address the highest-risk environmental problems and to take full advantage of
technological opportunities in sectors other than industrial manufacturing; the Energy Policy Act
of 1992 (Public Law 102-486 of October 24, 1992) requires the Secretary of Energy to work with
other Federal agencies to significantly reduce the use of energy and reduce the related environ-
mental impacts by promoting use of energy efficiency and renewable energy technologies; and
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Executive Orders
WHEREAS, as the largest single consumer in the Nation, the Federal Government has
the opportunity to realize significant economic as well as environmental benefits of pollution
prevention;
AND IN ORDER TO:
Ensure that all Federal agencies conduct their facility management and acquisition activi-
ties so that, to the maximum extent practicable, the quantity of toxic chemicals entering any
wastestream, including any releases to the environment, is reduced as expeditiously as possible
through source reduction; that waste that is generated is recycled to the maximum extent practi-
cable; and that any wastes remaining are stored, treated or disposed of in a manner protective of
public health and the environment;
Require Federal agencies to report in a public manner toxic chemicals entering any
wastestream from their facilities, including any releases to the environment, and to improve local
emergency planning., response, and accident notification; and
Help encourage markets for clean technologies and safe alternatives to extremely hazard-
ous substances or toxic chemicals through revisions to specifications and standards, the acquisi-
tion and procurement process, and the testing of innovative pollution prevention technologies at
Federal facilities or in acquisitions;
NOW THEREFORE, by the authority vested in me as President by the Constitution and
the laws of the United States of America, including the EPCRA, the PPA, and section 301 of title
5, United States Code, it is hereby ordered as follows:
Section 1. Applicability
1-101. As delineated below, the head of each Federal agency is responsible for ensuring
that all necessary actions are taken for the prevention of pollution with respect to that agency's
activities and facilities, and for ensuring that agency's compliance with pollution prevention and
emergency planning and community right-to-know provisions established pursuant to all imple-
menting regulations issued pursuant to EPCRA and PPA.
1-102. Except as otherwise noted, this order is applicable to all Federal agencies that
either own or operate a "facility" as that term is defined in section 329(4) of EPCRA, if such
facility meets the threshold requirements set forth in EPCRA for compliance as modified by
section 3-304(b) of this order ("covered facilities"). Except as provided in section 1-103 and
section 1-104 below, each Federal agency must apply all of the provisions of this order to each of
its covered facilities, including those facilities which are subject, independent of this order, to the
provisions of EPCRA and PPA (e.g., certain Government-owned/contractor-operated facilities
(GOCO's), for chemicals meeting EPCRA thresholds). This order does not apply to Federal
agency facilities outside the customs territory of the United-States, such as United States diplo-
matic and consular missions abroad.
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Appendix D
1-103. Nothing in this order alters the obligations which GOCO's and Government
corporation facilities have under EPCRA and PPA independent of this order or subjects such
facilities to EPCRA or PPA if they are otherwise excluded. However, consistent with section 1-
104 below, each Federal agency shall include the releases and transfers from all such facilities
when meeting all of the Federal agency's responsibilities under this order.
1-104. To facilitate compliance with this order, each Federal agency shall provide, in all
future contracts between the agency and its relevant contractors, for the contractor to supply to
the Federal agency all information the Federal agency deems necessary for it to comply with this
order. In addition, to the extent that compliance with this order is made more difficult due to lack
of information from existing contractors, Federal agencies shall take practical steps to obtain the
information needed to comply with this order from such contractors.
Sec. 2-2 Definitions
2-201. All definitions found in EPCRA and PPA and implementing regulations are
incorporated in this order by reference, with the following exception: for the purposes of this
order, the term "person", as defined in section 329(7) of EPCRA, also includes Federal agen-
cies.
2-202. Federal agency means an Executive agency, as defined in 5 U.S.C. 105. For the
purpose of this order, military departments, as defined in 5 U.S.C. 102, are covered under the
auspices of the Department of Defense.
2-203. Pollution Prevention means "source reduction," as defined in the PPA, and other
practices that reduce or eliminate the creation of pollutants through: (a) increased efficiency in
the use of raw materials, energy, water, or other resources; or (b) protection of natural resources
by conservation.
2-204. GOCO means a Government-owned/contractor-operated facility which is owned
by the Federal Government but all or portions of which are operated by private contractors.
2-205. Administrator means the Administrator of the EPA.
2-206. Toxic Chemical means a substance on the list described in section 313(c) of
EPCRA.
2-207. Toxic Pollutants. For the purposes of section 3-302(a) of this order, the term
"toxic pollutants" shall include, but is not necessarily limited to, those chemicals at a Federal
facility subject to the provisions of section 313 of EPCRA as of December 1, 1993. Federal
agencies also may choose to include releases and transfers of other chemicals, such as "extremely
hazardous chemicals" as defined in section 329(3) of EPCRA, hazardous wastes as defined under
the Resource Conservation and Recovery Act of 1976 (42 U.S.C. 6901-6986) (RCRA), or haz-
ardous air pollutants under the Clean Air Act Amendments (42 U.S.C. 7403-7626); however, for
the purposes of establishing the agency's baseline under 3-302(c), such "other chemicals" are in
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addition to (not instead of) the section 313 chemicals. The term "toxic pollutants" does not
include hazardous waste subject to remedial action generated prior to the date of this order.
Sec. 3-3. Implementation
3-301. Federal Agency Strategy. Within 12 months of the date of this order, the head of
each Federal agency must develop a written pollution prevention strategy to achieve the require-
ments specified in sections 3--302 through 3-305 of this order for that agency. A copy thereof
shall be provided to the Administrator. Federal agencies are encouraged to involve the public in
developing the required strategies under this order and in monitoring their subsequent progress in
meeting the requirements of this order. The strategy shall include, but shall not be limited to, the
following elements: (a) A pollution prevention policy statement, developed by each Federal
agency, designating principal responsibilities for development, implementation, and evaluation
of the strategy. The statement shall reflect the Federal agency's commitment to incorporate
pollution prevention through source reduction in facility management and acquisition, and it shall
identify an individual responsible for coordinating the Federal agency's efforts in this area.
(b) A commitment to utilize pollution prevention through source reduction, where prac-
ticable, as the primary means of achieving and maintaining compliance with all applicable Fed-
eral, State, and local environmental requirements.
3-302. Toxic Chemical Reduction Goals, (a) The head of each Federal agency subject to
this order shall ensure that the agency develops voluntary goals to reduce the agency's total
releases of toxic chemicals to the environment and off-site transfers of such toxic chemicals for
treatment and disposal from facilities covered by this order by 50 percent by December 31, 1999.
To the maximum extent practicable, such reductions shall be achieved by implementation of
source reduction practices.
(b) The baseline for measuring reductions for purposes of achieving the 50 percent
reduction goal for each Federal agency shall be the first year in which releases of toxic chemicals
to the environment and off-site transfers of such chemicals for treatment and disposal are publicly
reported. The baseline amount as to which the 50 percent reduction goal applies shall be the
aggregate amount of toxic chemicals reported in the baseline year for all of that Federal agency's
facilities meeting the threshold applicability requirements set forth in section 1-102 of this order.
In no event shall the baseline be later than the 1994 reporting year.
(c) Alternatively, a Federal agency may choose to achieve a 50 percent reduction goal for
toxic pollutants. In such event, the Federal agency shall delineate the scope of its reduction
program in the written pollution prevention strategy that is required by section 3-301 of this
order. The baseline for measuring reductions for purposes of achieving the 50 percent reduction
requirement for each Federal agency shall be the first year in which releases of toxic pollutants to
the environment and off-site transfers of such chemicals for treatment and disposal are publicly
reported for each of that Federal agency's facilities encompassed by section 3-301. In no event
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Appendix D
shall the baseline year be later than the 1994 reporting year. The baseline amount as to which the
50 percent reduction goal applies shall be the aggregate amount of toxic pollutants reported by
the agency in the baseline year. For any toxic pollutants included by the agency in determining
its baseline under this section, in addition to toxic chemicals under EPCRA, the agency shall
report on such toxic pollutants annually under the provisions of section 3-304 of this order, if
practicable, or through an agency report that is made available to the public.
(d) The head of each Federal agency shall ensure that each of its covered facilities
develops a written pollution prevention plan no later than the end of 1995, which sets forth the
facility's contribution to the goal established in section 3-302(a) of this order. Federal agencies
shall conduct assessments of their facilities as necessary to ensure development of such plans and
of the facilities, pollution prevention programs.
3-303. Acquisition and Procurement Goals, (a) Each Federal agency shall establish a
plan and goals for eliminating or reducing the unnecessary acquisition by that agency of products
containing extremely hazardous substances or toxic chemicals. Similarly, each Federal agency
shall establish a plan and goal for voluntarily reducing its own manufacturing, processing, and
use of extremely hazardous substances and toxic chemicals. Priorities shall be developed by
Federal agencies, in coordination with EPA, for implementing this section.
(b) Within 24 months of the date of this order, the Department of Defense (DoD) and the
General Services Administration (GSA), and other agencies, as appropriate, shall review their
agency's standardized documents, including specifications and standards, and identify opportuni-
ties to eliminate or reduce the use by their agency of extremely hazardous substances and toxic
chemicals, consistent with the safety and reliability requirements of their agency mission. The
EPA shall assist agencies in meeting the requirements of this section, including identifying sub-
stitutes and setting priorities for these reviews. By 1999, DoD, GSA and other affected agencies
shall make all appropriate revisions to these specifications and standards.
(c) Any revisions to the Federal Acquisition Regulation (FAR) necessary to implement
this order shall be made within 24 months of the date of this order.
(d) Federal agencies are encouraged to develop and test innovative pollution prevention
technologies at their facilities in order to encourage the development of strong markets for such
technologies. Partnerships should be encouraged between industry, Federal agencies, Govern-
ment laboratories, academia, and others to assess and deploy innovative environmental technolo-
gies for domestic use and for markets abroad.
3-304. Toxics Release Inventory/Pollution Prevention Act Reporting.
(a) The head of each Federal agency shall comply with the provisions set forth in section
313 of EPCRA, section 6607 of PPA, all implementing regulations, and future amendments to
these authorities, in light of applicable guidance as provided by EPA.
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(b) The head of each Federal agency shall comply with these provisions without regard to
the Standard Industrial Classification (SIC) delineations that apply to the Federal agency's facili-
ties, and such reports shall be for all releases, transfers, and wastes at such Federal agency's
facility without regard to the SIC code of the activity leading to the release, transfer, or waste.
All other existing statutory or regulatory limitations or exemptions on the application of EPCRA
section 313 shall apply to the reporting requirements set forth in section 3-304(a) of this order.
(c) The first year of compliance shall be no later than for the 1994 calendar year, with
reports due on or before July 1, 1995.
3-305. Emergency Planning and Community Right-to know Reporting Responsibilities. The
head of each Federal agency shall comply with the provisions set forth in sections 301 through
312 of EPCRA, all implementing regulations, and future amendments to these authorities, in
light of any applicable guidance as provided by EPA. Effective dates for compliance shall be:
(a) With respect to the provisions of section 302 of EPCRA, emergency planning notifi-
cation shall be made no later than 7 months after the date of this order.
(b) With respect to the provisions of section 303 of EPCRA, all information necessary
for the applicable Local Emergency Planning Committee (LEPC's) to prepare or revise local
Emergency Response Plans shall be provided no later than 1 year after the date of this order.
(c) To the extent thai a facility is required to maintain Material Safety Data Sheets under
any provisions of law or Executive order, information required under section 311 of EPCRA
shall be submitted no later than 1 year after the date of this order, and the first year of compliance
with section 312 shall be no later than the 1994 calendar year, with reports due on or before
March 1, 1995.
(d) The provisions of section 304 of EPCRA shall be effective beginning January 1
1994.
(e) These compliance dates are not intended to delay implementation of earlier timetables
already agreed to by Federal agencies and are inapplicable to the extent they interfere with those
timetables.
Sec/ 4-4. Agency Coordination
4-401. By February 1, 1994, the Administrator shall convene an Interagency Task Force
composed of the Administrator, the Secretaries of Commerce, Defense, and Energy, the Admin-
istrator of General Services, the Administrator of the office of Procurement Policy in the Office
of Management and Budget, and such other agency officials as deemed appropriate based upon
lists of potential participants submitted to the Administrator pursuant to this section by, the
agency head. Each agency head may designate other senior agency officials to act in his/her
stead, where appropriate. The Task Force will assist the agency heads in the implementation of
the activities required under this order.
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4-402. Federal agencies subject to the requirements of this order shall submit annual
progress reports to the Administrator beginning on October 1, 1995. These reports shall include
a description of the progress that the agency has made in complying with all aspects of this order
including the pollution reductions requirements. This reporting requirement shall expire after the
report due on October 1, 2001.
4-403. Technical Advice. Upon request and to the extent practicable, the Administrator
shall provide technical advice and assistance to Federal agencies in order to foster full compli-
ance with this order. In addition, to the extent practicable, all Federal agencies subject to this
order shall provide technical assistance, if requested, to LEPC's in their development of emer-
gency response plans and in fulfillment of their community right-to-know and risk reduction
responsibilities.
4-404. Federal agencies shall place high priority on obtaining funding and resources
needed for implementing all aspects of this order, including the pollution prevention strategies,
plans, and assessments required by this order, by identifying, requesting, and allocating funds
through line-item or direct funding requests. Federal agencies shall make such requests as re-
quired in the Federal Agency Pollution Prevention and Abatement Planning Process and through
agency budget requests as outlined in office of Management and Budget (OMB) Circulars A-106
and A-l 1, respectively. Federal agencies should apply, to the maximum extent practicable, a life
cycle analysis and total cost accounting principles to all projects needed to meet the requirements
of this order.
4-405. Federal Government Environmental Challenge Program. The Administrator shall
establish a "Federal Government Environmental Challenge Program" to recognize outstanding
environmental management performance in Federal agencies and facilities. The program shall
consist of two components that challenge Federal agencies; (a) to agree to a code of environmen-
tal principles to be developed by EPA, in cooperation with other agencies, that emphasizes
pollution prevention, sustainable development and state-of-the-art environmental management
programs and (b) to submit applications to EPA for individual Federal agency facilities for
recognition as "Model Installations." The program shall also include a means for recognizing
individual Federal employees who demonstrate outstanding leadership in pollution prevention.
Sec. 5-5 Compliance
5-501 By December 31, 1993, the head of each Federal agency shall provide the Admin-
istrator with a preliminary list of facilities that potentially meet the requirements for reporting
under the threshold provisions of EPCRA, PPA, and this order.
5-502 The head of each Federal agency is responsible for ensuring that such agency take
all necessary actions to prevent pollution in accordance with this order, and for that agency's
compliance with the provisions of EPCRA and PPA. Compliance with EPCRA and PPA means
compliance with the same substantive, procedural, and other statutory and regulatory require-
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ments that would apply to a private person. Nothing in this order shall be construed as making
the provisions of sections 325 and 326 of EPCRA applicable to any Federal agency or facility,
except to the extent that such Federal agency or facility would independently be subject to such
provisions. EPA shall consult with Federal agencies, if requested, to determine the applicability
of this order to particular agency facilities.
5-503. Each Federal agency subject to this order shall conduct internal reviews and
audits, and take such other steps, as may be necessary to monitor compliance with sections 3-304
and 3-305 of this order.
5-504. The Administrator, in consultation with the heads of Federal agencies, may con-
duct such reviews and inspections as may be necessary to monitor compliance with sections 3-304
and 3-305 of this order. Except as excluded under section 6-601 of this order, all Federal
agencies are encouraged to cooperate fully with the efforts of the Administrator to ensure compli-
ance with sections 3-304 and 3-305 of this order.
5-505. Federal agencies are further encouraged to comply with all state and local right-
to-know and pollution prevention requirements to the extent that compliance with such laws and
requirements is not otherwise already mandated.
5-506. Whenever the Administrator notifies a Federal agency that it is not in compliance
with an applicable provision of this order, the Federal agency shall achieve compliance as promptly
as is practicable.
5-507. The EPA shall report annually to the President on Federal agency compliance
with the provisions of section 3-304 of this order.
5-508. To the extent permitted by law and unless such documentation is withheld pursu-
ant to section 6-601 of this order, the public shall be afforded ready access to all strategies, plans,
and reports required to be prepared by Federal agencies under this order by the agency preparing
the strategy, plan, or report. When the reports are submitted to EPA, EPA shall compile the
strategies, plans, and reports and make them publicly available as well. Federal agencies are
encouraged to provide such strategies, plans, and reports to the State and local authorities where
their facilities are located for an additional point of access to the public.
Sec. 6-6. Exemption
6-601. In the interest of national security, the head of a Federal agency may request from
the President an exemption from complying with the provisions of any or all aspects of this order
for particular Federal agency facilities, provided that the procedures set forth in section 120(j),(l)
of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as
amended (42 U.S.C. 9620(j)(l)), are followed. To the maximum extent practicable, and without
compromising national security, all Federal agencies shall strive to comply with the purposes,
goals, and implementation steps set forth in this order.
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Sec. 7-7. General Provisions
7-701. Nothing in this order shall create any right or benefit, substantive or procedural,
enforceable by a party against the United States, its agencies or instrumentalities, its officers or
employees, or any other person.
WILLIAM J. CLINTON
THE WHITE HOUSE,
Augusts, 1993.
October 20, 1993
EXECUTIVE ORDER 12873
FEDERAL ACQUISITION, RECYCLING, AND WASTE PREVENTION
WHEREAS, the Nation's interest is served when the Federal Government can make more
efficient use of natural resources by maximizing recycling and preventing waste wherever pos-
sible;
WHEREAS, this Administration is determined to strengthen the role of the Federal Gov-
ernment as an enlightened, environmentally conscious and concerned consumer;
WHEREAS, the Federal Government should—through cost-effective waste prevention
and recycling activities—work to conserve disposal capacity, and serve as a model in this regard
for private and other public institutions; and
WHEREAS, the use of recycled and environmentally preferable products and services by
the Federal Government can spur private sector development of new technologies and use of such
products, thereby creating business and employment opportunities and enhancing regional and
local economies and the national economy;
NOW, THEREFORE, I, WILLIAM J. CLINTON, by the authority vested in me as
President by the Constitution and the laws of the United States of America, including the Solid
Waste Disposal Act, Public Law 89-272, 79 Stat. 997, as amended by the Resource Conservation
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and Recovery Act ("RCRA'), Public Law 94-580, 90 Stat. 2795 as amended (42 U.S.C. 6901-
6907), and section 301 of title 3, United States Code, hereby order as follows:
PART 1-PREAMBLE
Section 101. Consistent with the demands of efficiency and cost effectiveness, the head of each
Executive agency shall incorporate waste prevention and recycling in the agency's daily opera-
tions and work to increase and expand markets for recovered materials through greater Federal
Government preference and demand for such products.
Sec. 102. Consistent with policies established by Office of Federal Procurement Policy ("OFPP")
Policy Letter 92-4, agencies shall comply with executive branch policies for the acquisition and
use of environmentally preferable products and services and implement cost-effective procure-
ment preference programs favoring the purchase of these products and services.
Sec. 103. This order creates a Federal Environmental Executive and establishes high-level
Environmental Executive positions within each agency to be responsible for expediting the imple-
mentation of this order and statutes that pertain to this order.
PART 2—DEFINITIONS
For the purposes of this order:
Sec. 201. "Environmentally preferable" means products or services that have a lesser or reduced
effect on human health and the environment when compared with competing products or services
that serve the same purpose. This comparison may consider raw materials acquisition, produc-
tion, manufacturing, packaging, distribution, reuse, operation, maintenance, or disposal of the
product or service.
Sec. 202. "Executive agency" or "agency" means an Executive agency as defined in 5 U.S.C.
105. For the purpose of this order, military departments, as defined in 5 U.S.C. 102, are
covered under the auspices of the Department of Defense.
Sec. 203. "Postconsumer material" means a material or finished product that has served its
intended use and has been discarded for disposal or recovery, having completed its life as a
consumer item. "Postconsumer material" is a part of the broader category of "recovered mate-
rial".
Sec. 204. "Acquisition" means the acquiring by contract with appropriated funds for supplies or
services (including construction) by and for the use of the Federal Government through purchase
or lease, whether the supplies or services are already in existence or must be created, developed,
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demonstrated and evaluated. Acquisition begins at the point when agency needs are established
and includes the description of requirements to satisfy agency needs, solicitation and selection of
sources, award of contracts, contract financing, contract performance, contract administration
and those technical and management functions directly related to the process of fulfilling agency
needs by contract.
Sec. 205. "Recovered materials" means waste materials and by-products which have been re-
covered or diverted from solid waste, but such term does not include those materials and by-
products generated from, and commonly reused within, an original manufacturing process (42
U.S.C. 6903(19)).
Sec. 206. "Recyclability" means the ability of a product or material to be recovered from, or
otherwise diverted from, the solid waste stream for the purpose of recycling.
Sec. 207. "Recycling'" means the series of activities, including collection, separation, and pro-
cessing, by which products or other materials are recovered from the solid waste stream for use
in the form of raw materials in the manufacture of new products other than fuel for producing
heat or power by combustion.
Sec. 208. "Waste prevention," also known as "source reduction," means any change in the
design, manufacturing, purchase or use of materials or products (including packaging) to reduce
their amount or toxicity before they become municipal solid waste. Waste prevention also refers
to the reuse of products or materials.
Sec. 209. "Waste reduction" means preventing or decreasing the amount of waste being gener-
ated through waste prevention, recycling, or purchasing recycled and environmentally preferable
products.
Sec. 210. "Life Cycle Cost" means the amortized annual cost of a product, including capital
costs, installation costs, operating costs, maintenance costs and disposal costs discounted over the
lifetime of the product.
Sec. 211. "Life Cycle Analysis" means the comprehensive examination of a product's environ-
mental and economic effects throughout its lifetime including new material extraction, transpor-
tation, manufacturing, use, and disposal.
PART 3-THE ROLE OF THE FEDERAL ENVIRONMENTAL EXECUTIVE AND
AGENCY ENVIRONMENTAL EXECUTIVES
Sec. 301. Federal Environmental Executive, (a) A Federal Environmental Executive shall be
designated by the President and shall be located within the Environmental Protection Agency
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("EPA"). The Federal Environmental Executive shall take all actions necessary to ensure that
the agencies comply with the requirements of this order and shall generate an annual report to the
Office of Management and Budget ("OMB"), at the time of agency budget submissions, on the
actions taken by the agencies to comply with the requirements of this order. In carrying out his
or her functions, the Federal Environmental Executive shall consult with the Director of the
White House Office on Environmental Policy.
(b) Staffing. A minimum of four (4) full time staff persons are to be provided by the
agencies listed below to assist the Federal Environmental Executive, one of whom shall have
experience in specification review and program requirements, one of whom shall have experi-
ence in procurement practices, and one of whom shall have experience in solid waste prevention
and recycling. These four staff persons shall be appointed and replaced as follows:
(1) a representative from the Department of Defense shall be detailed for not less than one
year and no more than two years;
(2) a representative from the General Services Administration ("GSA") shall be detailed
for not less than one year and no more than two years;
(3) a representative from EPA shall be detailed for not less than one year and no more
than two years; and
(4) a representative from one other agency determined by the Federal Environmental Ex-
ecutive shall be detailed on a rotational basis for not more than one year.
(c) Administration. Agencies are requested to make their services, personnel and facili-
ties available to the Federal Environmental Executive to the maximum extent practicable for the
performance of functions under this order.
(d) Committees and Work Groups. The Federal Environmental Executive shall establish
committees and work groups to identify, assess, and recommend actions to be taken to fulfill the
goals, responsibilities, and initiatives of the Federal Environmental Executive. As these commit-
tees and work groups are created, agencies are requested to designate appropriate personnel in the
areas of procurement and acquisition, standards and specifications, electronic commerce, facili-
ties management, waste prevention, and recycling, and others as needed to staff and work on the
initiatives of the Executive.
(e) Duties. The Federal Environmental Executive, in consultation with the Agency
Environmental Executives, shall:
(1) identify and recommend initiatives for government-wide implementation that will pro-
mote the purposes of this order, including:
(A) the development of a federal plan for agency implementation of this order and
appropriate incentives to encourage the acquisition of recycled and environmentally
preferable products by the Federal Government;
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(B) the development of a federal implementation plan and guidance for instituting
economically efficient federal waste prevention, energy and water efficiency programs,
and recycling programs within each agency; and
(C) the development of a plan for making maximum use of available funding assistance
programs;
(2) collect and disseminate information electronically concerning methods to reduce waste,
materials that can be recycled, costs and savings associated with waste prevention and
recycling, and current market sources of products that are environmentally preferable
or produced with recovered materials;
(3) provide guidance and assistance to the agencies in setting up and reporting on agency
programs and monitoring their effectiveness; and
(4) coordinate appropriate government-wide education and training programs for agencies.
Sec. 302. Agency Environmental Executives. Within 90 days after the effective date of this
order, the head of each Executive department and major procuring agency shall designate an
Agency Environmental Executive from among his or her staff, who serves at a level no lower
than at the Deputy Assistant Secretary level or equivalent. The Agency Environmental Executive
will be responsible for:
(a) coordinating all environmental programs in the areas of procurement and acquisition,
standards and specification review, facilities management, waste prevention and recycling, and
logistics;
(b) participating in the interagency development of a Federal plan to:
(1) create an awareness and outreach program for the private sector to facilitate markets for
environmentally preferable and recycled products and services, promote new technolo-
gies, improve awareness about federal efforts in this area, and expedite agency efforts
to procure new products identified under this order;
(2) establish incentives, provide guidance and coordinate appropriate educational programs
for agency employees; and
(3) coordinate the development of standard agency reports required by this order;
(c) reviewing agency programs and acquisitions to ensure compliance with this order.
PART 4-ACQUISITION PLANNING AND AFFIRMATIVE PROCUREMENT PRO-
GRAMS
Sec. 401. Acquisition Planning. In developing plans, drawings, work statements, specifica-
tions, or other product descriptions, agencies shall consider the following factors: elimination of
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virgin material requirements; use of recovered materials; reuse of product; life cycle cost;
recyclability; use of environmentally preferable products; waste prevention (including toxicity
reduction or elimination); and ultimate disposal, as appropriate. These factors should be consid-
ered in acquisition planning for all procurements and in the evaluation and award of contracts, as
appropriate. Program and acquisition managers should take an active role in these activities.
Sec. 402. Affirmative Procurement Programs. The head of each Executive agency shall develop
and implement affirmative procurement programs in accordance with RCRA section 6002 (42
U.S.C. 6962) and this order. Agencies shall ensure that responsibilities for preparation, imple-
mentation and monitoring of affirmative procurement programs are shared between the program
personnel and procurement personnel. For the purposes of all purchases made pursuant to this
order, EPA, in consultation with such other Federal agencies as appropriate, shall endeavor to
maximize environmental benefits, consistent with price, performance and availability consider-
ations, and shall adjust bid solicitation guidelines as necessary in order to accomplish this goal.
(a) Agencies shall establish affirmative procurement programs for all designated EPA
guideline items purchased by their agency. For newly designated items, agencies shall revise
their internal programs within one year from the date EPA designated the new items.
(b) For the currently designated EPA guideline items, which are: (i) concrete and
cement containing fly ash; (ii) recycled paper products; (iii) re-refined lubricating oil; (iv) re-
tread tires; and (v) insulation containing recovered materials; and for all future guideline items,
agencies shall ensure that their affirmative procurement programs require that 100 percent of
their purchases of products meet or exceed the EPA guideline standards unless written justifica-
tion is provided that a product is not available competitively within a reasonable time frame, does
not meet appropriate performance standards, or is only available at an unreasonable price.
(c) The Agency Environmental Executives will track agencies' purchases of designated
EPA guideline items and report agencies' purchases of such guideline items to the Federal Envi-
ronmental Executive. Agency Environmental Executives will be required to justify to the Fed-
eral Environmental Executive as to why the item(s) have not been purchased or submit a plan for
how the agencies intend to increase their purchases of the designated item(s).
(d) Agency affirmative procurement programs, to the maximum extent practicable, shall
encourage that:
(1) documents be transferred electronically,
(2) all government documents printed internally be printed double-sided, and
(3) contracts, grants, and cooperative agreements issued after the effective date of this or-
der include provisions that require documents to be printed double-sided on recycled
paper meeting or exceeding the standards established in this order or in future EPA
guidelines.
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Sec. 403. Procurement of Existing Guideline Items. Within 90 days after the effective date of
this order, the head of each Executive agency that has not implemented an affirmative procure-
ment program shall ensure that the affirmative procurement program has been established and is
being implemented to the maximum extent practicable.
Sec. 404. Electronic Acquisition System. To reduce waste by eliminating unnecessary paper
transactions in the acquisition process and to foster accurate data collection and reporting of
agencies' purchases of recycled content and environmentally preferred products, the executive
branch will implement an electronic commerce system consistent with the recommendations
adopted as a result of the National Performance Review.
PART 5-STANDARDS, SPECIFICATIONS AND DESIGNATION OF ITEMS
Sec. 501. Specifications, Product Descriptions and Standards. Where applicable, Executive
agencies shall review and revise federal and military specifications, product descriptions and
standards to enhance Federal procurement of products made from recovered materials or that are
environmentally preferable. When converting to a Commercial Item Description (CID), agen-
cies shall ensure that environmental factors have been considered and that the CID meets or
exceeds the environmentally preferable criteria of the government specification or product de-
scription. Agencies shall report annually on their compliance with this section to the Federal
Environmental Executive for incorporation into the annual report to OMB referred to in section
301 of this order.
(a) If an inconsistency with RCRA Section 6002 or this order is identified in a specifica-
tion, standard, or product description, the Federal Environmental Executive shall request that the
Environmental Executive of the pertinent agency advise the Federal Environmental Executive as
to why the specification cannot be revised or submit a plan for revising it within 60 days.
(b) If an agency is able to revise an inconsistent specification by cannot do so within 60
days, it is the responsibility of that agency's Environmental Executive to monitor and implement
the plan for revising it.
Sec. 502. Designation of Items that Contain Recovered Materials. In order to expedite the
process of designating items that are or can be made with recovered materials, EPA shall institute
a new process for designating these items in accordance with RCRA section 6002(e) as follows.
(a) EPA shall issue a Comprehensive Procurement Guideline containing designated items
that are or can be made with recovered materials.
(1) The proposed guideline shall be published for public comment in the Federal Regis-
ter within 180 days after the effective date of this order and shall be updated annually after
publication for comment to include additional items.
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(2) Once items containing recovered materials have been designated by EPA through the
new process established pursuant to this section and in compliance with RCRA section 6002,
agencies shall modify their affirmative procurement programs to require that, to the maximum
extent practicable, their purchases of products meet or exceed the EPA guideline standards unless
written justification is provided that a product is not available competitively, not available within
a reasonable time frame, does not meet appropriate performance standards, or is only available at
an unreasonable price.
(b) Concurrent with the issuance of the Comprehensive Procurement Guideline required
by section 502(a) of this order, EPA shall publish for public comment in the Federal Register
Recovered Material Advisory Notice(s) that present the range of recovered material content
levels within which the designated recycled items are currently available. These levels shall be
undated periodically after publication for comment to reflect changes in market conditions.
Sec. 503. Guidance for Environmentally Preferable Products. In accordance with this order,
EPA shall issue guidance that recommends principles that Executive agencies should use in
making determinations for the preference and purchase of environmentally preferable products.
(a) Proposed guidance shall be published for public comment in the Federal Register
within 180 days after the effective date of this order, and may be updated after public comment,
as necessary, thereafter. To the extent necessary, EPA may issue additional guidance for public
comment on how the principles can be applied to specific product categories.
(b) Once final guidance for environmentally preferable products has been issued by EPA,
executive agencies shall use these principles, to the maximum extent practicable, in identifying
and purchasing environmentally preferable products and shall modify their procurement pro-
grams be reviewing and revising specifications, solicitation procedures, and polices as appropri-
ate.
Sec. 504. Minimum Content Standard for Printing and Writing Paper. Executive agency heads
shall ensure that agencies shall meet or exceed the following minimum materials content stan-
dards when purchasing or causing the purchase of printing and writing paper.
(a) For high speed copier paper, offset paper, forms bond, computer printout paper,
carbonless paper, file folders, and white woven envelopes, the minimum content standard shall
be no less than 20 percent postconsumer materials beginning December 31, 1994. This minimum
content standard shall be increased to 30 percent beginning on December 31, 1998.
(b) For other uncoated printing and writing paper, such as writing and office paper, book
paper, cotton fiber paper, and cover stock, the minimum content standard shall be 50 percent
recovered materials, including 20 percent postconsumer materials beginning on December 31,
1994. This standard shall be increased to 30 percent beginning on December 31, 1998.
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(c) As an alternative to meeting the standards in sections 504(a) and (b), for all printing
and writing papers, the minimum content standard shall be no less than 50 percent recovered
materials that are a waste materials by-product of a finished product other than a paper or textile
product which would otherwise be disposed of in a landfill, as determined by the State in which
the facility is located.
(1) The decision not to procure recycled content printing and writing paper meeting the
standards specified in this section shall be based solely on a determination by the con-
tracting officer that a satisfactory level of competition does not exist, that the items are
not available within a reasonable time period, or that the available items fail to meet
reasonable performance standards established by the agency or are only available at an
unreasonable price.
(2) Each agency should implement waste prevention techniques, as specified in section
402(d) of this order, so that total annual expenditures for recycled content printing and
writing paper do not exceed current annual budgets for paper products as measured by
average annual expenditures, adjusted for inflation based on the Consumer Price Index
or other suitable indices. In determining a target budget for printing and writing paper,
agencies may take into account such factors as employee increases or decreases, new
agency or statutory initiatives, and episodic or unique requirements (e.g., census).
(3) Effective immediately, all agencies making solicitations for the purchase of printing
and writing paper shall seek bids for paper with postconsumer material or recovered
waste material as described in section 504(c).
Sec. 505. Revision of Brightness Specifications and Standards. The General Services Adminis-
tration and other Federal agencies are directed to identify, evaluate and revise or eliminate any
standards or specifications unrelated to performance that present barriers to the purchase of paper
or paper products made by production processes that minimize emissions of harmful by-products.
This evaluation shall include a review of unnecessary brightness and stock clause provisions,
such as lignin content arid chemical pulp requirements. The GSA shall complete the review and
revision of such specifications within six months after the effective date of this order, and shall
consult closely with the Joint Committee on Printing during such process. The GSA shall also
compile any information or market studies that may be necessary to accomplish the objectives of
this provision.
Sec. 506. Procurement of Re-refined Lubricating Oil and Retread Tires. Within 180 days after
the effective date of this order, agencies shall implement the EPA procurement guidelines for re-
refined lubricating oil and retread tires.
(a) Commodity managers shall finalize revisions to specifications for re-refined oil and
retread tires, and develop and issue specifications for tire retreading services, as commodity
managers shall take affirmative steps to procure these items in accordance with RCRA section
6002.
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(b) Once these items become available, fleet managers shall take affirmative steps to
procure these items in accordance with RCRA section 6002.
Sec. 507. Product Testing. The Secretary of Commerce, through the National Institute of
Standards and Technology ("NIST"), shall establish a program for testing the performance of
products containing recovered materials or deemed to be environmentally preferable. NIST shall
work with EPA, GSA and other public and private sector organizations that conduct appropriate
life cycle analyses to gather information that will assist agencies in making selections of products
and services that are environmentally preferable.
(a) NIST shall publish appropriate reports describing testing programs, their results, and
recommendations for testing methods and related specifications for use by Executive agencies
and other interested parties.
(b) NIST shall coordinate with other Executive and State agencies to avoid duplication
with existing testing programs.
PART 6-AGENCY GOALS AND REPORTING REQUIREMENTS
Sec. 601. Goals for Waste Reduction. Each agency shall establish a goal for solid waste preven-
tion and a goal for recycling to be achieved by the year 1995. These goals shall be submitted to
the Federal Environmental Executive within 180 days after the effective date of this order.
Progress on attaining these goals be reported by the agencies to the Federal Environmental Ex-
ecutive for the annual report specified in section 301 of this order.
Sec 602. Goal for Increasing the Procurement of Recycled and Other Environmentally Prefer-
able Products. Agencies shall strive to increase the procurement of products that are environ-
mentally preferable or that are made with recovered materials and set annual goals to maximize
the number of recycled products purchased, relative to non-recycled alternatives.
Sec. 603. Review of Implementation. The President's Council on Integrity and Efficiency
("PCIE") will request that tie Inspectors General periodically review agencies' affirmative pro-
curement programs and reporting procedures to ensure their compliance with this order.
PART 7—APPLICABILITY AND OTHER REQUIREMENTS
Sec. 701. Contractor Operated Facilities. Contracts that provide for contractor operation of a
government-owned or leased facility, awarded after the effective date of this order, shall include
provisions that obligate the contractor to comply with the requirements of this order within the
scope of its operations. In addition, to the extent permitted by law and where economically
feasible, existing contracts should be modified.
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Sec. 702. Real Property Acquisition and Management. Within 90 days after the effective date of
this order, and to the extent permitted by law and where economically feasible, Executive agen-
cies shall ensure compliance with the provisions of this order in the acquisition and management
of federally owned and leased space. GSA and other Executive agencies shall also include
environmental and recycling provisions in the acquisition of all leased space and in the construc-
tion of new federal buildings.
Sec. 703. Retention of Funds. Within 90 days after the effective date of this order, the Admin-
istrator of GSA shall develop a legislative proposal providing authority for Executive agencies to
retain a share of the proceeds from the sale of materials recovered through recycling or waste
prevention programs and specifying the eligibility requirements for the materials being recycled.
Sec. 704. Model Facility Programs. Each Executive department and major procuring agency
shall establish model facility demonstration programs that include comprehensive waste preven-
tion and recycling programs and emphasize the procurement of recycled and environmentally
preferable products and services using an electronic data interchange (EDI) system.
Sec. 705. Recycling Programs. Each Executive agency that has not already done so shall initiate
a program to promote cost effective waste prevention and recycling of reusable materials in all of
its facilities. The recycling programs implemented pursuant to this section must be compatible
with applicable State and local recycling requirements. Federal agencies shall also consider
cooperative ventures with State and local governments to promote recycling and waste reduction
in the community.
PART 8-AWARENESS
Sec. 801. Agency Awards Program. A government-wide award will be presented annually by
the White House to the best, most innovative program implementing the objectives of this order
to give greater visibility to these efforts so that they can be incorporated government-wide.
Sec. 802. Internal Agency Awards Programs. Each agency shall develop an internal agency-
wide awards program, as appropriate, to reward its most innovative environmental programs.
Winners of agency-wide awards will be eligible for the White House award program.
PART 9—REVOCATION, LIMITATION AND IMPLEMENTATION
Sec. 901. Executive Order No. 12780, dated October 31, 1991, is hereby revoked.
Sec. 902. This order is intended only to improve the internal management of the executive
branch and is not intended to create any right or benefit, substantive or procedural, enforceable at
law by a party against the United States, its agencies, its officers, or any other person.
190
-------
Executive Orders
Sec. 903. The policies expressed in this order, including the requirements and elements for
effective agency affirmative procurement programs, shall be implemented and incorporated in
the Federal Acquisition Regulation (FAR) within 180 days after the effective date of this order.
The implementation language shall consist of providing specific direction and guidance on agency
programs for preference, promotion, estimation, certification, reviewing and monitoring.
Sec. 904. This order shall be effective immediately.
[Signed] WILLIAM J. CLINTON
THE WHITE HOUSE
October 20, 1993.
191
-------
-------
APPENDIX E
STATE POLLUTION PREVENTION PROGRAMS
193
-------
Appendix E
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194
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State Pollution Prevention Programs
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Appendix E
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196
-------
State Pollution Prevention Programs
State Energy Offices
ALABAMA
K. David Shropshire
Alabama Dept. of Economic and Community
Affairs
P.O. Box 5690
Montgomery, AL 36103-5690
(205) 242-5292
ALASKA
Robert Breen
Dept. of Community and Regional Affairs
Rural Development Division
949 East 36th Avenue, Suite 403
Anchorage, AK 99508
(907) 563-1073
AMERICAN SAMOA
Matt Le'i
Office of the Governor
Territorial Energy Office
Pago, AS 96799
(684)633-1306
ARIZONA
Jack Haenichen
Arizona Dept. of Commerce
Arizona Energy Office
3800 North Central, Suite 1200
Phoenix, AZ 85012
(602) 280-1300
ARKANSAS
Jim Blakley
Arkansas Energy Office
One State Capitol Mall, Suite 4B/215
Little Rock, AR 72201
(501)682-7315
CALIFORNIA
Charles Imbrecht
California Energy Commission
1516 9th Street
Sacramento, CA95814
(916) 324-3326
Richard Sybert
Governor's Office of Planning and Research
1400 10th Street
Sacramento, CA 95814
(916)322-2318
COLORADO
Karen Reinertson
Colorado Office of Energy Conservation
1675 Broadway, Suite 1300
Denver, CO 80202
(303) 894-620-4292
CONNECTICUT
Susan Shimelman
Policy Development and Planning
Office of Policy and Management
80 Washington Street
Hartford, CT -6-16
(203) 566-2800
DELAWARE
George P. Donnelly
Division of Facilities Management
Energy Office, P.O. Box 1401
Dover, DE 19901
(302) 739-5644
DISTRICT OF COLUMBIA
Charles Clinton
District of Columbia Energy Office
613 G Street, NW, 5th Floor
Washington, DC 20001
(202)727-1800
197
-------
Appendix E
EASTERN CAROLINE ISLAND
Marcelino Actouki
Federated States of Micronesia
Dept. of Resources and Development
Energy Division of Micronesia
P.O. Box 190
Kolonia, Pohnpei, EC 96941
Energy Planner
State of Truk
State Planning Office
P.O. Box 189
Moen, Truk, EC 96942
FED. STS. MICRONESIA
Timothy P. Timothy
P.O. Box AD
Kosray State, FS 96944
FLORIDA
Jim Tait
Florida Energy Office
Dept. Of Community Affairs
2740 Centerview Drive
Tallahassee, FL 32399-2100
(904) 488-2475
GEORGIA
Paul Burks
Office of Energy Resources
254 Washington Street, SW
Room 401
Atlanta, GA 30334
(404)656-5176
GUAM
Jerry Rivera
Guam Energy Office
P.O. Box 2950
Agana, GU 96910
(671)472-8711
HAWAII
Murray E. Towill
Dept. of Planning and Economic Development
Energy Division
335 Merchant Street, Room 110
Honolulu, HI 96813
(808) 548-2306
IDAHO
Robert Hoppie
Idaho Dept. of Water Resources
Energy Division
1301 North Orchard
Boise, ID 83706
(208) 327-7900
ILLINOIS
John S. Moore
Dept. of Energy and Natural Resources
325 West Adams Street, Room 300
Springfield, IL 62704-1892
(217)785-2002
INDIANA
Amy Stewart
Dept. of Commerce Office of Energy Policy
1 North Capitol, Suite 700
Indianapolis, IN 46204-2248
(317)232-8940
IOWA
Larry Bean
Iowa Energy Bureau
Transportation and Planning Section
Wallace State Office Building
DesMoines, IA 50319
(515)281-8681
KANSAS
Jim Robinson
Kansas Corporation and Commission
Energy Programs Section
1500 SW Arrowhead Road
Topeka, KS 66604
(913)271-3100
198
-------
State Pollution Prevention Programs
KENTUCKY
John Stapleton
Kentucky Division of Energy
691 Teton Trail
Frankfort, KY 40601
(502)564-7192
LOUISIANA
Jack McClanahan
Louisiana Dept. of Natural Resources
P.O. Box 94396
Baton Rouge, LA 70804-9396
(504) 342-4503
MAINE
Leonard A. Dow
Dept. of Economic and Community
Development
219 Capital Street
Augusta, ME 04333
(207) 289-6800
MARYLAND
Gerald L. Thorpe
Maryland Energy Administration
45 Calvert Street
Annapolis, MD 21401
(301) 974-3755
MASSACHUSETTS
Paul W. Gromer
Massachusetts Division of Energy Resources
Leverett Saltonstall Building
100 Cambridge Street, Room 1500
Boston, MA 02202
(617) 727-4732
MICHIGAN
Steven M. Fetter
Michigan Public Service Commission
P.O. Box 30221
6545 Mercantile Way
Lansing, MI 48909
(517) 334-6270
MINNESOTA
Krista L. Sanda
Minnesota Dept. of Energy and Economic
Development
900 American Center Building
150 East Kellogg Blvd.
St. Paul, MN 55101
(612)296-6035
Andrew Jenkins
Mississippi Dept. of Economic and
Community Development
Energy and Transportation Division
510 George Street, Suite 101
Jackson, MS 39202-3096
(601) 359-6600
MISSOURI
Robert Jackson
Missouri Dept. of Natural Resources
Division of Energy, P.O. Box 176
Jefferson City, MO 65102
(314)751-4000
MONTANA
Van Jamison
Dept. of Natural Resources and Conservation
Energy Division
1520 East Sixth Avenue
Helena, MT 59620-2301
(406) 444-6697
NEBRASKA
Robert Harris
Nebraska Energy Office
P.O. Box 95085
State Capitol Building, 9th Floor
Lincoln, NE 68509
(402)471-2867
199
-------
Appendix E
NEVADA
James Hawke
Nevada Office of Community Services
Capitol Complex
Carson City, NV 89701
(702) 687-4990
NEW HAMPSHIRE
Jonathans. Osgood
Governor's Office of Energy and Community
Services
57 Regional Drive
Concord, NH 03301-8506
(603)271-2611
NEW JERSEY
Scott A. Weiner
Dept. of Environmental Protection and Energy
401 E. State Street
Trenton, NJ 08625
(609) 292-2885
NEW MEXICO
Dianne Car on
Dept. of Energy, Minerals and Natural
Resources
Energy Conservation and Management Division
2040 South Pacheco
Santa Fe, NM 87505
(505) 827-5917
NEW YORK
William D. Cotter
New York State Energy Office
Division of Conservation
2 Rockefeller Plaza
Albany, NY 12223
(518)473-4376
NORTH CAROLINA
Carson D. Culbreth, Jr.
North Carolina Dept. of Economic and
Community Development
Energy Division
430 North Salisbury Street
Raleigh, NC27611
(191)733-2230
NORTH DAKOTA
Shirley R. Dykahoorn
Office of Intergovernmental Assistance
State Capitol Building
Bismarck, ND 58505
(701) 224-2094
NORTHERN MARIANA ISLAND
Jocelyn Guerrero
Commonwealth Energy Office
P.O. Box 340
Siapan, CM 96950
(855)099-7174
OHIO
Paul R. Leonard
Ohio Dept. of Development
Community Development Division
Office of Energy Conservation
77 S. High Street, 24th Floor
Columbus, OH 43266-0413
(614) 466-3465
OKLAHOMA
Sherwood Washington
Oklahoma Dept. of Commerce
Division of Community Affairs and
Development
P.O. Box 26980
Oklahoma City, OK 73126-0980
(405) 843-9770
200
-------
State Pollution Prevention Programs
OREGON
Christine Ervin
Oregon Dept. of Energy
Conservation Division
625 Marion Street, NE
Salem, OR 97310-0831
(503) 378-6063
PENNSYLVANIA
Brian T. Castelli
Pennsylvania Energy Office
116 Pine Street
Harrisburg, PA 17101-1227
(717)783-9981
PUERTO RICO
Luis R. Pinero
Dept. of Consumer Affairs
P.O. Box 41059
Minillas Station
San Juan, PR 00902-1059
(809)721-0809
REPUBLIC OF PALAD
Greg Decherong
Republic of Palau
Ministry, National Resources
Palau Energy Office
P.O. Box 100
Koror, Palau, RP 96940
RHODE ISLAND
J. Scott Wolf
Governor's Office of Housing, Energy and
Intergovernmental Relations
State House
275 Westminster Street, Room 111
Providence, RI 02903-5872
(401) 277-2850
SOUTH CAROLINA
Carlisle Roberts, Jr.
Office of the Governor
Division of Finance and Administration
Office of Energy Programs
1205 Pendleton Street, 3rd Floor
Columbia, SC 29201
(803)734-0310
SOUTH DAKOTA
Ron Reed
Governor's Office of Energy Policy
217 1/2 West Missouri
Pierre, SD 57501
(605) 773-3603
TENNESSEE
Carl Johnson
Tennessee Dept. of Economic and Community
Development
Energy Division
320 6th Avenue North, 8th Floor
Nashville, TN 37219-5308
(615)741-2373
TEXAS
Harris E. Worcester
Governor's Energy Office
Capitol Station, P.O. Box 12428
Austin, TX78711
(512)463-1931
UTAH
Richard M. Anderson
Utah Energy Office
355 West North Temple
3 Triad Center, Suite 450
Salt Lake City, UT 84180-1204
(801) 538-5428
201
-------
Appendix E
VERMONT
V. Louise McCarren
Dept. of Public Services
Energy Efficiency Division
120 State Street
Montpelier, VT 05620
(802)828-2811
VIRGIN ISLANDS
Claudette Young-Hinds
Virgin Islands Energy Office
81 Castle Coakley
Christiansted
St. Croix, VI 00823
(809) 772-2616
VIRGINIA
Ronald J. DesRoches
Dept. of Mines, Minerals and Energy
2201 West Broad Street
Richmond, VA 23220
(804) 367-0979
WASHINGTON
Amy Bell
Washington State Energy Office
Conservation Division
809 Legion Way, SE
Olympia, WA 98504
(206) 956-2001
WEST VIRGINIA
John F. Herholdt, Jr.
Governor's Office of Community and Industrial
Development
Fuel and Energy Office
State Capitol Complex
Building 6, Room 553
Charleston, WV 25305
(304) 348-8860
WESTERN CAROLINE ISLAND
Godfrey E. Chochol
State of YAP
Office of Planning and Budget
P.O. Box 471
Kolonia, YAP, WC 96943
WISCONSIN
John Bilotti
Wisconsin Division of Energy and
Intergovernmental Relations
101 South Webster Street
P.O. Box 7868
Madison, WI 53707-7868
(608) 266-8234
WYOMING
Steven Schmitz
Division of Economic and Community
Development
Energy Division
Herschler Building, 2nd Floor
Cheyenne, WY 82002
(307) 777-7284
202
-------
APPENDIX F
PROVISIONS OF TWELVE STATE LAWS
203
-------
Appendix F
State
Facility Pollution Prevention Planning:
A Matrix of the Provisions of Twelve State Laws
Statutory Authorization
Date
Implementing Agency
California
Georgia
Maine
Massachusetts
Minnesota
Mississippi
New York
North Carolina
Oregon
Tennessee
Vermont
Washington
S.B. 14
Hazardous Waste Source Reduction
Management and Review Act
S.B. 519
Amendment to the Hazardous Waste
Management Act
Chapter 929
An Act to Clean the Environment by
the Reduction of Toxics Use, Waste
and Release
H. 6161
Toxics Use Reduction Act
Toxic Pollution Prevention Act
S.B. 2568
Comprehensive Multimedia Waste
Minimization Act
S. 5276-B
An Act to Amend the Environmental
Conservation Law, in Relation to the
Management of Hazardous Waste
S.B. 324
Hazardous Waste Management
Commission Act
H.B. 3515
Toxics Use Reduction and Hazardous
Waste Reduction Act
H.B. 2217
Hazardous Waste Reduction Act
H. 733
An Act Relating to the Management
of Hazardous Waste
H.B. 2390 Hazardous Waste and
Substance Reduction Act
1989 Department of Health Services
(DHS)
1990 Department of Natural
Resources
1990 Department of Environmental
Protection (DEP)
1989 Department of Environmental
Protection (DEP)
1990 Pollution Control Agency (PCA)
Office of Waste Management
1990 Department of Environmental
Quality (DEQ)
1990 Department of Environmental
Conservation (DEC)
1989 Department of Natural
Resources and Community
Development (DNRCD)
1989 Department of Environmental
Quality
1990 Department of Health and
Environment (DHE)
1990 Agency of Natural Resources
(ANR)
1990 Department of Ecology (DE)
Source: The following state matrix was adapted from material prepared by the Ohio Environmental
Protection Agency as reprinted in the U.S. Environmental Protection Agency's Pollution Prevention
1991. EPA/21P-3003. October 1991.
204
-------
Provisions of Twelve State Laws
CALIFORNIA; Hazardous Waste Source Reduction Management and Review Act
Persons Required to Prepare Plan
Generators who, by site, routinely
generate, through ongoing
processes and operations, more
than 26,460 Ibs of hazardous
waste per year or more than 26.46
Ibs of extremely hazardous waste
per year.
Performance Goals of Facility Plans
Specific numeric performance goals are not
required, however, plan must include a
timetable for making reasonable and
measurable progress toward implementing
selected source reduction methods
Agency Review of Facility Plans
Generators must retain a copy of the
current source reduction evaluation
review plan and plan summary at
each site (or central location) and
upon request shall make it available
during any DHS inspection
Statutory Objectives
To reduce the generation of
hazardous waste; to reduce
chemical contaminant releases
Waste Management Hierarchy
1) source reduction
2) recycling
3) treatment
Exceptions
Selected measure is not technically feasible or
economically practicable; attempts to
implement the measure reveal that it would
result in: (1) increased hazardous waste
generation; (2) increased hazardous chemical
releases to other environmental media; (3)
adverse impacts on product quality; (4)
significant increase in risks of an adverse
impact to human health or environment
Frequency of Facility Progress Report
Submission
Every 4 years beginning 1 991,
generators must prepare a hazardous
waste management report and
summary
Administrative Penalties
Civil penalties in an amount not
greater than $1,000 may be imposed
if a generator fails to submit a revised
source reduction evaluation review
and plan, plan summary, hazardous
waste management performance
report, or report summary
Guidelines for Facility Plans
Identification of hazardous waste
streams which result from ongoing
processes or operations that have
an annual volume >5% total
annual volume
Estimate of quantity of hazardous
waste generated
Evaluation of viable source
reduction options
Specification of, and rationale for,
source reduction measures which
will be taken for each waste
stream; rationale for rejecting any
available source reduction
approach
Evaluation and quantification of
effects of chosen source reduction
measures on emissions and
discharges to air, water, or land
Timetable for making reasonable
and measurable progress towards
mplementing source reduction
measures
Certification by professional
engineer; process or operations
personnel on-site; or an
nvironmental assessor with
expertise in hazardous waste
management
Exemptions from Completing Plan
DHS shall adopt regulations to establish
procedures for exempting generators where
the department determines no source
reduction opportunities exist
Public Access to Facility Plans
Any person may request DHS to
certify that a generator is in
compliance with statutory
requirements
Requirements of Facility Progress Report
Estimate of quantity of hazardous waste
generated and managed onsite and offsite
during the current reporting year and baseline
reporting year
Assessment of the effect, during the current
year, of each hazardous waste management
measure implemented since the baseline year
upon onsite and offsite hazardous waste
generation, including source reduction,
recycling, and treatment measures
Description of factors during the current year
that have affected onsite and offsite
hazardous waste generation since the baseline
year
Certification by a professional engineer;
process or operations personnel onsite;
environmental assessor with expertise in
hazardous waste management
Plan Approval Criteria
DHS shall not judge the
appropriateness of any decision or
proposed measures contained in a
review and plan, plan summary,
report or report summary, but shall
only determine whether the
document is complete, prepared and
implemented in accordance with the
statute.
205
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Appendix F
GEORGIA: Amendment to the Hazardous Waste Management Act
Persons Required to Prepaire Plan
Large quantity hazardous waste
generators
Out-of-state large quantity
hazardous waste generators who
use Georgia's hazardous waste
treatment, storage and disposal
Performance Goals of Facility Plans
Specific performance goals for hazardous
waste reduction must be expressed in
lumeric terms wherever technically and
economically practicable, If numeric terms
are not practical, plan must include a
statement of objectives designed to lead to
the establishment of numeric goals as soon
as practicable. Rationale for each
performance goal must be explained,
including any impediment to hazardous
/vaste reduction
Agency Review of Facility Plans
All plans must be completed and
submitted to DNR on or before 3/1/92.
lans shall be updated and submitted
to DNR on a biennial basis
Statutory Objectives
To provide for the preparation of
hazardous waste reduction plans
and biennial progress reports
Waste Management Hierarchy
Specified in the original act:
1) source reduction
2) recycling
3) treatment
4) disposal
Exceptions
For valid reasons of priority, a company
chooses to address other more serious
hazardous waste reduction concerns.
Necessary steps to reduce hazardous waste
will likely have significant adverse impacts
on product quality. Legal or existing
contractual obligations interfere with the
necessary steps that would lead to
Hazardous waste reduction
Frequency of Facility Progress Report
Submission
Generators must biennially complete a
hazardous waste reduction progress
report
Administrative Penalties
Criminal penalties will be imposed for
false statements made by a company
in certifying that it is unable to meet
the requirements because of the nature
of its business operation or process, or
by out-of-state generators in certifying
that they are in compliance with the
law
Guidelines for Facility Plans
Policy statement of upper
management and corporate
support for the plan and
commitment to implement plan
goals
Plan scope and objectives,
including the evaluation of
technologies, procedures and
personnel training programs to
ensure unnecessary hazardous
waste is not generated; specific
goals for hazardous waste:
reduction, based on what is
economically practical
Analysis of hazardous waste
streams; identification of
opportunities for hazardous waste
reduction; evaluation of where and
why waste was generated;
potential reduction and recycled
techniques
Accounting systems which identify
waste management costs and
factor in liability, compliance and
oversight costs
Employee awareness and training
programs to involve employees in
hazardous waste reduction
planning and implementation
Incorporation of plan into
management practice and
procedure to institutionalize plan
Plan for implementing reduction
options
Exemptions from Completing Plan
Waste resulting from remediation or cleanup
programs. Commercial hazardous waste
treatment, storage and disposal facilities
upon certification to DNR that because of
the nature of its business operation or
process, the facility cannot meet the waste
reduction requirements
Public Access to Facility Plans
DNR shall maintain a copy of each
hazardous waste reduction plan and
biennial progress report received. This
information shall be available to the
public at the director's office
Requirements of Facility Progress Report
Analyze and quantify progress made, if any,
in hazardous waste reduction, relative to
each performance goal established in the
plan. Set forth amendments to the plan and
explain the need for the amendments
Plan Approval Criteria
Not specified
206
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Provisions of Twelve State Laws
MAINE: An
Act to Clean the Environment by the Reduction of
Toxics Use, Waste and Release
Persons Required to Prepare Plan
Generators of > than 220.5 Ibs o
hazardous waste per month for
more than 3 months per year.
Facility owners or operators
required to report under SARA,
Title III, Section 313 (toxics
releasers). Persons required to
report the presence of extremely
hazardous substances under
SARA, Title III, Section 312
(toxics users).
Statutory Objectives
To reduce the volume of toxic
substances used, toxics released
and hazardous waste generated:
10% by 1993, 20% by 1995,
30% by 1997.
Waste Management Hierarchy
1) Toxics use reduction, toxics
release reduction and hazardous
waste reduction.
Performance Goals of Facility Plans
Facilities must achieve toxics release and
hazardous waste reduction goals of 10% by
1993; 20% by 1995; 30% by 1997. DEP wi
track generator progress by manifest data.
Exceptions
Practicable hazardous waste or toxic release
reduction methods do not exist. All
practicable reductions or actions have been
previously implemented or are currently being
implemented. Practicable steps necessary to
reduce hazardous waste or toxic releases
would be an unreasonable adverse impact on
product quality or quantity. Legal or
contractual obligations prohibit steps
necessary to reduce hazardous waste
generation or toxic releases.
Agency Review of Facility Plans
After 1/1/93, DEP may require a
toxics releaser/hazardous waste
generator to submit a summary of
the toxics releaser/hazardous waste
reduction plan when:
- A facility fails to meet reduction
goals
- An exempted facility fails to meet
alternative reduction goals
established by DEP
- Toxic release rates or hazardous
waste generation in a new facility is
significantly greater per production
unit than in similar facility of the
same SIC code
Owners and operators of facilities
shall keep a complete copy of the
plan and any back-up data on the
premises of that facility for at least 5
years and make the copy and data
available to DEP upon request.
Frequency of Facility Progress Report
Submission
Toxics users and toxics releasers
must annually report progress
toward meeting reduction goals.
Progress in hazardous waste
reduction will be tracked through
manifest data.
Administrative Penalties
Toxic users are not subject to
penalties under this statute, except
:or the requirement to pay an annual
ee. Toxic releasers that fail to meet
any statutory requirement, including,
but not limited to, achievement of
toxics release reduction goals and
:he preparation and submission of
equired plan summaries, are subject
:o enforcement action and fees of up
:o $25,000/day. Hazardous waste
generators that fail to meet any
itatutory requirement, including, but
not limited to achievement of
hazardous waste reduction goals and
he preparation and submission of
equired plans, may be subject to
enforcement action, civil or criminal
penalties and fees as follows:
Hazardous waste transported
iffsite for disposal: $0.18/lb.
Hazardous waste transported
iffsite for treatment, storage, or
ther handling, including beneficial
3use, reclamation or recycling:
0.135/lb.
207
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Appendix F
MAINE: An Act to Clean the Environment by the Reduction of
Toxics Use, Waste and Release (con't.)
Guidelines for Facility Plans
Statement of facility-wide
management policy for toxics use,
toxics release and hazardous waste
reduction.
Identification and characterization
of types and amounts of all toxics
used, toxics released and
hazardous waste generated.
Evaluation of any appropriate
technologies, procedures,
processes, equipment or production
changes that may be utilized to
reduce the amount or toxicity of
toxics used, toxics released or
hazardous waste generated.
Strategy and schedule for
implementing reduction options for
each production process.
Identification of available markets
or recycling opportunities for
hazardous waste.
Program for maintaining records or
toxics use, toxics release and
hazardous waste generation rates
and management costs.
Employee awareness and training
program to involve employees in
toxics use, toxics release and
hazardous waste reduction
planning and implementation.
Exemptions from Completing Plan:
Hazardous waste reduction exemptions:
- Commercial hazardous waste treatment or
storage facilities
- Pilot plants or pilot production units.
- Hazardous waste transporters
- Hazardous waste generated as a result of
remedial or corrective actions or facility
closures
Toxics release reduction exemptions:
- Water supply treatment facilities
- Municipal wastewater treatment facilities
- Retail and wholesale motor fuel and heating
oil distributors
- Agricultural operations
Requirements of Facility Progress Report
Toxics use and toxics release reports must
state progress toward meeting toxics use and
toxics release goals, respectively. Hazardous
waste generators are not required to complete
a progress report, but DEP will track progress
through hazardous waste manifest data.
Public Access to Facility Plans
Public access is not explicitly stated
in this statute, but policy was set in
another law. Public has access to
any plan summary submitted to DEP
unless the facility has met provisions
for confidentiality.
Plan Approval Criteria
In reviewing the adequacy of any
plan summary, the commissioner
shall base a determination on
whether the plan summary is
compete and prepared in accordance
with requirements established by
statute, regulations or guidelines.
208
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Provisions of Twelve State Laws
MASSACHUSETTS: Toxics Use Reduction Act
Persons Required to Prepare Plan
Initially facility owners or operators
required to report under SARA,
Title III, Section 313, then
expanding by 1995 to include
other SIC groups and facilities
which use chemicals on the
CERCLA list (large quantity toxics
users).
Performance Goals of Facility Plans
If a majority of toxics users in a priority user
segment fall significantly below standard
achievements of by-product generated per
unit of product, DEP may require priority user
segments to achieve a specified level of by-
product generated per unit of product, within
a specified time frame.
Agency Review of Facility Plans
Plans are kept at the facility and
must be made available to DEP upon
request.
Statutory Objectives
To reduce toxic waste generated
by 50% by 1 997 using toxics use
reduction as the means for
meeting this goal.
Waste Management Hierarchy
1) Toxics use reduction
Exceptions
Not specified.
Frequency of Facility Progress
Report Submission
Toxic or hazardous substance
reports must be submitted to DEP
annually.
Administrative Penalties
Any individual or toxics user who
violates the requirements of toxics
use reduction planning or annual
toxics and hazardous substance
reporting shall be punished by a fine
in an amount between $2,500 and
$25,000, or by imprisonment for
not more than one year, or by both.
Guidelines for Facility Plans
Statement of facility-wide
management policy for toxics use
reduction.
Plan scope and objectives,
including planned reductions in
facility-wide use and by-product
generation from the relevant base
year for each toxic or hazardous
substance during the next 2 years
and 5 years.
Economic and technical evaluation
of technologies, procedures and
training programs for achieving
toxics use reduction.
Analysis of current and projected
toxics use, by-product generation
and emissions.
Economic impacts of toxics use,
including costs of raw material and
by-product storage, potential
liability and regulatory compliance.
Plan implementation schedule.
2 year and 5 year goals for the by-
product reduction index for each
toxic or hazardous substance.
Plan certification by a toxics use
reduction planner.
Exemptions from Completing Plan
Pilot plants and pilot production units. Start-
up production units for a specified time
period.
Public Access to Facility Plans
Any 10 residents living within 10
miles of a facility required to prepare
a toxics use reduction plan may
petition DEP to examine the plan,
plan summary and any required back
up data and determine their
adequacy.
DEP shall make available for resident
review all toxics use reduction plan
summaries, provided that trade
secret information is protected.
Requirements of Facility Progress Report
Quantities of toxic or hazardous substances
which are manufactured, processed,
otherwise used, generated as by-product, or
shipped in product.
Indication of whether the substance was used
in the production unit in amounts:
- less than or equal to 5,000 pounds;
- greater than 5,000 pounds but less than or
equal to 10,000 pounds; and
- greater than 10,000 pounds.
Reporting base year. By-product reduction
index. Emissions reduction index.
Matrix form of methods by which by-product
reduction index was achieved for each
production operation.
Plan Approval Criteria
DEP shall specify criteria for
acceptable plans according to
statutory requirements. Plans must
be certified by a toxics use
reduction planner as meeting the
department's criteria for acceptable
plans.
209
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Appendix F
'arsons Required to Prepare Plan
Facility owners or operators
equired to report under SARA,
itle III, Section 313.
MINNESOTA: Toxic Pollution Prevention Act
Statutory Objectives
To protect public health, welfare
and the environment; to encourage
toxic pollution prevention.
Waste Management Hierarchy
1) Source reduction and processes
that minimize cross-media pollutant
transfers
Guidelines for Facility Plans
Policy statement of upper
management support for toxics
reduction.
Description of current processes
generating or releasing toxics,
describing types, sources and
quantities of toxics currently being
generated or released.
Description of current and past
toxics reduction practices and
evaluation of their effectiveness.
Assessment of technically and
economically practicable options
available to eliminate or reduce the
generation of toxics, which may
include cost-benefit analysis.
Plan objectives and schedule for
achieving objectives.
Explanation of the rationale for
each objective.
List of options considered to be
economically or technically
impracticable.
Certification by facility manager
and a company officer attesting
the plan's accuracy.
erformance Goals of Facility Plans
Vherever technically and practicable,
bjectives for eliminating or reducing the
eneration or release of each toxic pollutant
must be expressed in numeric terms.
Otherwise objectives must include a clearly
tated list of actions designed to lead to the
stablishment of numeric goals as soon as
racticable.
Exceptions
vJot specified.
Exemptions from Completing Plan
Toxic pollutants resulting solely from research
and development activities need not be
ncluded in the plan.
Requirements of Facility Progress Report
Summary of each objective established in the
plan, including schedule for meeting
objectives.
Summary of progress made during past year,
if any, toward meeting each plan objective,
including quantity of each toxic pollutant
eliminated or reduced.
Statement of methods through which
elimination or reduction has been achieved.
Explanation of reasons objectives were not
achieved (if applicable), including identification
of any technical, economic or other
impediments.
Certification by facility manager and a
company officer attesting the report's
accuracy.
gency Review of Facility Plans
lans must be kept at the facility.
CA shall be given access to a
acility plan if the progress report
oes not meet statutory
iquirements relating to progress
iport content.
requency of Facility Progress Report
Submission
'CA shall review all progress reports
o determine if they meet statutory
equirements.
Administrative Penalties
Annual progress reports must be
iubmitted to PCA beginning in
October 1992.
Public Access to Facility Plans
'lans are nonpublic data.
25 or more persons living within 10
miles of the facility may submit a
petition that identifies specific
deficiencies in the progress report
and requests PCA to review the
:aci!ity plan. Within 30 days after
•eceipt of the petition, PCA shall
respond in writing. If the
lommissioner agrees that the
arogress report does not meet
statutory requirements, PCA shall be
given access to the facility plan.
Plan Approval Criteria
After reviewing the plan and progress
report with any modifications
submitted, the commissioner shall
state in writing whether the progress
report meets statutory requirements.
210
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Provisions of Twelve State Laws
MISSISSIPPI: Comprehensive Multimedia Waste Minimization Act
Persons Required to Prepare Plan
Large quantity hazardous waste
generators. Small quantity
hazardous waste generators.
Facility owners or operators
required to report under SARA,
Title III, Section 313.
Statutory Objectives
To reduce or minimize the
generation and toxicity of waste by
a minimum of 25% by January 1,
1996.
Waste Management Hierarchy
1) Source reduction
2) Recycling
3) Treatment
4) Disposal
Guidelines for Facility Plans
Policy statement of management
support for waste minimization and
plan implementation.
Plan scope and objectives,
including evaluation of
technologies, procedures and
personnel training programs to
ensure waste minimization.
Explanation and documentation of
previous waste minimization
efforts.
Analysis of waste streams and
dentification of opportunities to
eliminate waste generation,
ncluding review of waste
generating processes, evaluation of
data on types, amounts and
hazardous constituents of waste
generated and potential waste
minimization techniques.
dentification of waste
management costs.
Employee awareness and training
programs to involve employees in
iwaste management planning and
mplementation.
Performance goals which shall be
expressed in numeric terms
whenever practicable.
Performance Goals of Facility Plans
Performance goals for waste minimization
must be set in numeric terms to the extent
practical.
Exceptions
Not specified.
Exemptions from Completing Plan
Commission of Environmental Quality is
authorized to make exceptions to an grant
exemptions and variances from rules and
regulations implementing the statute.
Requirements of Facility Progress Report
Annual plan updates are required in lieu of
progress reports, and must include:
- Analysis and quantification of progress
made, if any, in waste minimization, relative
to each performance goal.
- Amendments, if any, to the plan and
explanation of the need for amendments.
Agency Review of Facility Plans
A generator or facility operator shall
permit any designee of DEQ to
review the waste minimization plan.
Frequency of Facility Progress
Report Submission
Annual plan updates must be
prepared and must include
quantification of progress in
achieving performance goals.
Administrative Penalties
No penalties.
Public Access to Facility Plans
A waste minimization plan and any
updates shall be retained at the
facility and shall not be subject to
inspection, examination, copying or
reproduction.
Plan Approval Criteria
Not specified.
211
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Appendix F
NEW YORK: An Act to Amend the Environmental Conservation Law,
in Relation to the Management of Hazardous Waste
ersons Required to Prepare Plan
enerators of equal to or greater
ban 25 tons of hazardous waste
er year. Generators required to
old a hazardous waste treatment,
torage or disposal facility permit.
Statutory Objectives
o reduce hazardous waste
eneration and release by 50%
ver the next 10 years.
Waste Management Hierarchy
Source reduction
2) Recycling
3) Treatment
4) Disposal
Guidelines for Facility Plans
dentification of amounts and types
of acute hazardous waste.
dentification of amounts and types
of hazardous wastes generated
during previous year.
Description of the process that
resulted in such waste.
alculation of the amount of waste
generated per unit of production
output, raw material used or other
appropriate index. Estimate of
waste management costs,
including storage, treatment,
transportation, disposal and
regulatory fees.
Evaluation of feasibility of
implementing waste reduction
processes for each waste.
Program to implement feasible
waste reduction alternatives.
Evaluation of anticipated reduction
in amount of hazardous waste
produced as a result of
implementing each waste reduction
option.
Evaluation of cross-media transfers
of waste reduction options.
erformance Goals of Facility Plans
valuation of the anticipated reduction, in
ons or other appropriate measurement, in
he amount of hazardous wastes produced as
result of the implementation of each of the
ichnically feasible and economically
racticable waste reduction options.
xceptions
vlot specified.
Exemptions from Completing Plan
Hazardous waste generated by:
Corrective action for a release from a hazardous
waste treatment, storage or disposal facility
Remediation of inactive disposal sites
- Cleanup of environmental releases
- Demolition and construction debris.
Requirements of Facility Progress Report
3rogress in achieving time schedule for
mplementing waste reduction alternatives.
Reasons for not implementing any waste
reduction technology, process or operational
change identified in the plan. Explanation of
why any waste reduction method chosen and
implemented did not achieve anticipated
waste reduction.
gency Review of Facility Plans
)EC must review each plan according
o a schedule established by statute.
requency of Facility Progress Report
lubmission
Annual status reports must be
ubmitted to DEC.
Administrative Penalties
Any generator whose plan has been
ejected by DEC is not allowed to
make the hazardous waste manifest
certification, and, per a condition of
any permit issued for onsite
reatment, storage or disposal of
lazardous waste, is not allowed to
make the annual report certification.
ublic Access to Facility Plans
Not specified.
Plan Approval Criteria
Review of hazardous waste reduction
plans shall be subject to the following
standards. DEC may reject any plan or
biennial update which:
- fails to contain all components required
by statute
- fails to apply generally accepted
engineering, scientific or economic
principles and practices
- accomplishes waste reduction by
transfers to other environmental media
without an environmental benefit from
such transfers
- is inconsistent with the preferred
hazardous waste management practices
hierarchy
- involves conduct prohibited by any
applicable law or regulation
- fails to provide a basis for charting
waste reduction trends over time
- beginning with the 1 st biennial update,
fails to demonstrate reasonable progress
in implementing chosen waste reduction
alternatives according to the established
time schedule; or fails to reevaluate
alternatives.
212
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Provisions of Twelve State Laws
NORTH CAROLINA: Hazardous Waste Management Commission Act
Persons Required to Prepare Plan
Hazardous waste generators and
operators of hazardous waste
treatment facilities which treat
waste on-site who are required to
pay an annual fee under North
Carolina law. Persons required to
hold a water quality permit.
Persons required to hold an air
quality permit.
Statutory Objectives
To encourage voluntary waste and
pollution reduction efforts.
Waste Management Hierarchy
Not mentioned in this statute, but
specified in an earlier law:
1) Source reduction
2) Recycling
3) Treatment
4) Disposal
Guidelines for Facility Plans
For hazardous waste permits:
- written description of any
program to minimize or reduce the
volume and quantity of toxicity of
waste
For water quality permits:
- written description of current and
projected plans to reduce the
discharge of waste and pollutants
by source reduction or recycling
For air quality permits:
written description of current and
projected plans to reduce the
emission of air contaminants by
ource reduction or recycling
Performance Goals of Facility Plans
Not specified.
Exceptions
Not specified.
Exemptions from Completing Plan
Not specified.
Requirements of Facility Progress Report
Progress reports are not required.
Agency Review of Facility Plans
All written descriptions of current
and projected plans to reduce
hazardous wastes, waste water and
pollutant discharges and air
contaminant emissions shall be
transmitted to the Solid Waste
Management Division for review and
analysis.
Frequency of Facility Progress Report
Submission
Progress reports are not required,
however, plans are required annually.
Administrative Penalties
Penalty for failure to submit a
hazardous waste minimization plan
along with the annual fee is an
administrative fine. Penalty for
failure to submit a plan along with an
air or water quality permit fee is an
administrative fine or permit
revocation.
'ublic Access to Facility Plans
Not specified in statute, however,
pollution prevention plans become
part of the facility permit and
compliance files, and air available for
Dublic review.
Plan Approval Criteria
specified.
213
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Appendix F
OREGON: Toxics Use Reduction and Hazardous Waste Reduction Act
Persons Required to Prepare Plan
Large quantity hazardous waste
generators. Small quantity
hazardous waste generators.
Facility owners or operators
required to report under the SARA,
Title III, Section 313 (large users)
'erformance Goals of Facility Plans
Establish specific numeric performance goals
for the following categories of toxic
substances and hazardous wastes:
Any toxic substance used in quantities in
xcess of 10,000 pounds a year;
- Any toxic substance used in quantities in
ixcess of 1,000 pounds a year that
constitutes 10% or more of the total toxics
us,ed; and
- l:or large quantity generators, any waste
representing 10% or more by weight of the
cumulative waste stream generated per year.
Agency Review of Facility Plans
Upon coming completing a plan, the
user must notify DEQ in writing on a
form supplied by DEQ. Plans shall be
retained at the facility. Toxics users
shall permit any DEQ employee to
nspect the plan.
Statutory Objectives
To encourage toxic substance use
and hazardous waste generation
reduction without shifting risks
from one environmental medium to
another.
Waste Management Hierarchy
1) Toxics use reduction
2) Hazardous waste reduction
Guidelines for Facility Plans
Policy statement of upper
management and corporate
support for the plan and
commitment to implement plan
goals.
Plan scope and objectives,
including evaluation of
technologies, procedures and
personnel training programs.
Internal analysis of toxics usage
and hazardous waste streams,
including evaluation of typeis and
amounts of toxics used and waste
generated, where and why toxics
were used and waste was
generated, potential reduction and
recycling techniques.
Exceptions
Impediments may include the availability of
technically practicable toxics use reduction
and hazardous waste reduction methods, and
the economic practicability of available toxics
use reduction and hazardous waste reduction
methods, including any anticipated changes in
the future. Examples of situations where
reduction may not be economically practicable
may include:
- For valid reasons of priority, a company
chooses to first other more serious toxics use
reduction or hazardous waste reduction or
hazardous waste reduction concerns
- Necessary steps to reduce toxics use and
hazardous waste will likely have significant
adverse impacts on product quality
- Legal or contractual obligations interfere
with the necessary steps that would lead to
toxics use reduction or hazardous waste
reduction.
Frequency of Facility Progress Report
Submission
All toxics users shall annually
complete a toxic use reduction and
hazardous waste reduction progress
report.
Administrative Penalties
If a toxics user fails to develop an
adequate plan or progress report
according to DEQ's required
modifications, DEQ may issue an
administrative order requiring the
user to submit a plan or progress
report. If the user fails to submit an
adequate plan or progress reports
within the time specified, DEQ shall
conduct a public hearing on the plan
or progress report. In any hearing,
the relevant plan or progress report
shall be considered public record,
except for trade secret information.
Guidelines for Facility Plans
Policy statement of upper management and
corporate support for the plan and
commitment to implement plan goals.
Plan scope and objectives, including
evaluation of technologies, procedures and
personnel training programs.
Internal analysis of toxics usage and
hazardous waste streams, including
evaluation of types and amounts of toxics
used and waste generated, where and why
toxics were used and waste was generated,
potential reduction and recycling techniques.
Public Access to Facility Plans
DEQ shall maintain a log of each plan
or progress report it reviews, a list of
all plans or progress reports that
have been found to be inadequate
and descriptions of corrective actions
taken. This information shall be
available to the public at DEQ.
If a public hearing is held on any plan
or progress report, the relevant plan
or progress report, excepting trade
secret information, shall be
considered a public record.
214
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Provisions of Twelve State Laws
OREGON: Toxics Use Reduction and Hazardous Waste Reduction Act (con't.)
Guidelines for Facility Plans
(con't.)
Accounting systems that identify
toxic use and waste management
costs and factor in liability,
compliance and oversight costs.
Employee awareness and training
programs.
Institutionalization of plan by
incorporation of plan info
management practice and
procedure.
Plan for implementing technically
and economically practicable
toxics use and hazardous waste
reduction options.
Requirements of Facility Progress Report
Analyze progress made, if any, in toxics use
reduction and hazardous waste reduction,
relative to each performance goal established
in the plan. Set forth amendments to the plan
and explain the need for amendments.
Submit report to DEQ on quantities of toxics
used and wastes generated that meet
performance goal criteria, and a narrative
explaining the data.
Plan Approval Criteria
In reviewing the adequacy of any
plan or progress report, DEQ shall
base its determination solely on
whether the document is complete
and prepared in accordance with
planning guidelines.
215
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Appendix F
TENNESSEE: Hazardous Waste Reduction Act
Persons Required to Prepare Plan
Large quantity hazardous waste
generators. Small quantity
hazardous waste generators.
Performance Goals of Facility Plans
Specific performance goals shall be
quantitative goals, expressed in numeric
terms, established for the source reduction of
each waste stream. When possible, units of
measurement should be in pounds (or tons) of
waste generated per standard unit of
production, as defined by the generator. If
numeric performance goals are not practical,
performance goals shall include a clearly
stated list of actions designed to lead to the
establishment of numeric goals as soon as
practical.
Agency Review of Facility Plans
Upon completing a plan, the
generator shall maintain a current
copy of the plan at the facility.
Generators shall permit the
commissioner's designee to inspect
the plan. Generators shall permit
any officer, employee or DHE
representative to have access to the
plan. Generators shall furnish a copy
of the plan upon request to DHE.
Statutory Objectives
To reduce the aggregate level of
hazardous waste generated by
25% by June 30, 1995.
Waste Management Hierarchy
1) Reduce or prevent hazardous
waste generation
2) Storage, treatment and disposal
Exceptions
For valid reasons of priority, a company
chooses to first address other more serious
hazardous waste reduction concerns.
Necessary steps to reduce hazardous waste
will likely have significant adverse impacts on
product quality. Legal or contractual
obligations interfere with the necessary steps
that would lead to hazardous waste
reduction.
Frequency of Facility Progress Report
Submission
Based on their annual progress
report, generators shall annually
submit to DHE summary information
on waste reduction activities.
Administrative Penalties
Civil penalties of up to $10,000 shall
be imposed on any generator or
person who:
- fails to file any required reports,
records or documents
- fails, neglects or refuses to comply
with any statutory provisions or
orders issued pursuant to the statute
- knowingly gives false information in
any required report, record or
document.
Guidelines for Facility Plans
Policy statement of management
support for the plan.
Plan scope and objectives, including
evaluation of technologies,
procedures and personnel training
programs to ensure that
unnecessary waste is not
generated.
Description of hazardous wiaste
reduction options and an
implementation schedule. Options
must be based on internal analysis
of waste streams, including
evaluation of types and amounts of
waste generated, where and why
waste was generated, potential
reduction and recycling techniques.
Accounting systems that identify
waste management costs and factor
in liability, compliance and oversight
costs.
Employee awareness and training
programs.
Description of how plan has; been or
will be incorporated into
management practices and
procedures to insure an ongoing
effort.
E xemptions from Completing Plan
Waste shall not include wastewater streams
containing hazardous wastes that are
collected and treated in onsite wastewater
treatment systems, the discharge of which is
the subject of a NPDES permit.
Public Access to Facility Plans
Plans shall not be considered public
record.
Requirements of Facility Progress Report
Analyze and quantify progress made, if any,
in hazardous waste reduction, relative to each
performance goal established in the plan. Set
forth amendments, if needed, to the plan and
explain the need for amendments. The
following summary information must be
Eiubmitted to DHE as an element of the annual
generator report:
- For each hazardous waste stream, one of
the following as appropriate:
ci) a statement of specific performance goals
and a report on progress made in achieving
these goals. Results should be in numeric
terms.
b) a report on the actions taken toward
establishing numeric goals.
Plan Approval Criteria
DHS may review a plan or annual
progress report to determine whether
the document reasonably contains
the elements specified by statute.
216
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Provisions of Twelve State Laws
VERMONT: An Act Relating to the Management of Hazardous Waste
Persons Required to Prepare Plan
Persons who routinely generate,
through ongoing process and
operation, more than 26,460 Ibs
of hazardous waste per year or
more than 26.46 Ibs of acutely
hazardous waste per year.
Performance Goals of Facility Plans
Specific performance goals are not required,
however, plan must include a timetable and
measurable progress toward implementing
selected source reduction methods.
Agency Review of Facility Plans
Every 2 years, beginning 7/1/92,
ANR shall select at least 2
categories of generators by SIC cod
with potential for source reduction
and must examine their source
reduction review and plans to
determine whether generators have
complied with statutory
requirements.
On or after 7/1/92, ANR may
request a copy of the source
reduction review and plan from any
generator and may evaluate any
document to determine whether it
satisfies statutory requirements
Statutory Objectives
To safeguard public health,
promote worker safety and
protect the environment by
establishing toxic use reduction as
the top priority for hazardous
waste and toxics management.
Exceptions
Not specified.
Frequency of Facility Progress
Report Submission
Hazardous materials management
performance reports must be
submitted annually.
Waste Management Hierarchy
1) Source reduction
2) Recycling
3) Treatment
Administrative Penalties
No penalties.
Guidelines for Facility Plans
Name, location, SIC code of site.
Identification of each routinely
generated hazardous waste
resulting from ongoing processes
or operations that have a yearly
weight > 5% of total yearly weight
of hazardous waste or hazardous
materials released into the
environment; or acute hazardous
waste >5% of total yearly weight.
Estimate of quantity of hazardous
waste generated.
Evaluation of feasible source
reduction methods.
Specification of, and rationale for,
feasible source reduction methods
which will be taken for each waste
stream; rationale for rejecting any
available source reduction method.
Evaluation of effects of chosen
source reduction methods so as
not to adversely affect compliance
with applicable laws and
egulations on emissions and
discharges to air, water or land.
Timetable for making reasonable
and measurable progress toward
mplementing selected source
eduction methods.
Exemptions from Completing Plan
ANR shall adopt rules for exempting from
facility planning requirements generators for
whom the secretary determines no source
reduction opportunities exist.
Public Access to Facility Plans
Not specified.
Requirements of Facility Progress Report
Name, location, SIC code of site. Quantity of
hazardous waste generated and managed
onsite and offsite, during the current reporting
year and baseline reporting year. Assessment
of the effect, during the current year, of each
hazardous materials management measure
implemented since the baseline year, upon
onsite and offsite hazardous waste generation.
Description of factors during the current year
that have affected hazardous waste
generation, hazardous materials releases and
onsite and offsite hazardous waste
management since the baseline year.
Certification by a professional engineer; or a
process or operations personnel onsite.
Plan Approval Criteria
ANR may evaluate any of the
documents submitted to determine
whether they satisfy statutory
requirements.
217
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Appendix F
WASHINGTON:: Hazardous Waste and Substance Reduction Act
Persons Required to Prepare Plan
Persons who generate more than
2,640 pounds of hazardous waste per
year. Facility owners or operators
required to report under SARA, Title III,
Section 313 except those facilities that
are primarily permitted treatment,
storage and disposal facilities or
recycling facilities (hazardous
substance users).
Performance Goals of Facility Plans
Specific performance goals must be
expressed in numeric terms for each of
the following categories:
- hazardous substance use reduction or
elimination
- waste elimination or reduction
- recycled materials or wastes
- treated wastes.
If the establishment of numeric
performance goals is not practical, goals
shall include a clearly stated list of
objectives designed to lead to numeric
goals as soon as practical.
Agency Review of Facility Plans
Upon completing a plan, executive
summaries of the plan shall be
submitted to DE. DE may review a
plan or executive summary to
determine whether the document is
adequate pursuant to rules developed
under statute and with statutory
provisions. Plans shall be retained at
the facility. Generators shall permit a
DE representative to review the plan to
determine its adequacy.
Statutory Objectives
To reduce hazardous waste generation
by 50% by 1995 through hazardous
substance use reduction and waste
reduction techniques.
Exceptions
Not specified.
Frequency of Facility Progress Report
Submission
Annual progress reports must be
submitted to DE.
Waste Management Hierarchy
1) Hazardous substance use reduction
2) Hazardous waste reduction
3) Recycling
4) Treatment
Administrative Penalties
A penalty fee of either $1,000 or 3
times of amount of the generator's
previous year's fee or current year's
fee, whichever is greater, shall be
charged if a generator fails to complete
plan, executive summary or progress
report modifications required by DE.
Guidelines for Facility Plans;
Policy statement of corporate support
for plan.
Analysis of current hazardous
substance use and waste generation
and current reduction, recycling and
treatment options.
Analysis of impediments to
implementing options.
Policy stating that in implementing
selected options risks will not be
shifted from one process,
environmental media or product to
another.
Hazardous waste accounting systems
which factor in liability, compliance
and oversight costs.
Financial description of plan.
Employee training and involvement
programs.
5 year plan implementation schedule.
Documentation of previous waste
reduction efforts.
Executive summary of plan.
Exemptions from Completing Plan
Persons required to prepare a plan may
petition the DE to be excused from
planning requirements, because of the
quantity of hazardous waste generated.
Persons must demonstrate to the
director's satisfaction that the quantity
of hazardous waste generated was due
to unique circumstances not likely to be
repeated and that the person is unlikely
to generate sufficient hazardous waste
to require a plan in the next 5 years.
Public Access to Facility Plans
DE shall make available for public
inspection any submitted executive
plan summary, protecting confidential
information. Any 10 persons residing
within 10 miles of a facility required to
prepare a plan may file a petition
requesting DE to examine a plan to
determine its adequacy. DE shall
maintain and make available to the
public, a record of each plan, executive
summary or progress report it reviews,
determines to be inadequate, or for
which corrective action is taken.
Requirements of Facility Progress Report
Description of progress made toward
achieving the specific performance goals
established in the plan.
Plan Approval Criteria
In determining the adequacy of any
plan, executive summary or annual
progress report, DE shall base its
determination solely on whether the
document is complete and prepared in
accordance with statutory provisions.
218
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APPENDIX G
ESTABLISHING A RECYCLING PROGRAM
219
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Appendix G
Establishing a Recycling Program
The following background information for establishing a recycling program has been
adapted from the US Air Force Installation Pollution Prevention Program Manual because it
applies to all Federal facilities.
Setting Up A Recycling Program
Careful planning is required before beginning a recycling program. Operators of recy-
cling programs must decide on the method of collection and identify equipment, site, and facility
requirements. A business and financing plan should be developed. Program operators must
decide what to collect and who to collect it from, and how much material can be collected.
Ongoing public education, information, and promotion will increase the quantity and quality of
materials collected.
Materials Specifications
Recyclable materials recovered from solid waste must meet certain quality and purity
specifications if they are to be utilized in current manufacturing processes. The condition of the
materials plays a key role in setting the buyer's price.
Selling Recyclable Materials
A necessary component of recycling program is finding buyers for recovered materials.
Prices fluctuate so it is important to check prices prior to making an economic assessment of the
feasibility of a source separation project. The cost of transporting recyclable materials to a
market is often a major expense of the program.
Buyers may sell or loan equipment such as balers or crushers to recycling programs, but
for some programs it may be more economical to receive a lower price for less prepared materials
(e.g., whole bottles or aluminum cans) than to spend time and money to partially process mate-
rials (e.g., crush glass and compact cans).
Market Demand
A demand must exist for recyclable materials before they can be reused in other products.
Demand for recyclable materials is influences by the availability of substitute materials, industry's
overall ability to use those materials, the state of the economy, and energy costs.
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Establishing a Recycling Program
Purchasing Products Made From Recycled Materials
The standard three-arrow recycling symbol represents not only collection of recyclable
materials, but also manufacturing and use of recycled products. Recycling can succeed in divert-
ing materials from landfills only if markets for products made from recycled materials expand.
Recyclable Materials
Paper, in the form of newspaper, corrugated, and high grade office paper, represents the
bulk of waste from households and businesses, and is a steady component of installation waste
streams. Much of it can easily be recovered through source separation. The benefits of recycling
paper include conservation of trees and valuable landfill space, and energy savings realized
through use of recycled fiber rather than virgin fiber in manufacturing new paper products.
Newspaper is the easiest paper to recycle and is typically the largest portion of recyclable
material in households. Most old newspapers can be collected and sold to de-inking newsprint
mills and remade into newspaper. Newsprint can also be made into products such as packing
materials, insulation, and roofing materials. An increasing percentage of recycled newsprint is
exported for remanufactured into newspaper or other products.
Corrugated cardboard boxes also account for a major portion of recycled paper; typically,
it is baled and shipped to mills where it is made into new corrugated boxes or paperboard for
cardboard boxes.
High grade office paper may be one of several grades or types. To be recycled at
a high grade, it must be free from contaminants such as tape, metal objects, gummed
labels, plastic, string, and carbon paper. Computer paper, tab cards, stationery bond, and
miscellaneous plan paper are among the types of recyclable high grade paper. Maga-
zines and slick advertising from newspapers are difficult to recycle and market demand is
low because of the high clay content which gives them their shiny appearance.
Many offices have recycling programs where employees collect white paper at their desks
and take it to a central storage point in the office. From there it is taken to a storage area and is
picked up by a waste paper dealer or recycling business when sufficient quantity accumulates.
The price paid by buyers of waste paper depends on the demand for products made out of
recycled paper, the type or grade of paper (e.g., corrugated and newspaper are lower grades than
white office paper), and the quality of paper (amount of contamination). Paper grades are
established by the Paper Stock Institute of America, a division of the Institute of Scrap Recycling
Industries. DRMO offices at most Air Force bases continue to be responsible for determining
market process for base recyclables. Air Force bases can help increase the demand for recycled
paper by specifying that their letterhead and other paper products are recyclables.
221
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Appendix G
Glass
Recyclable glass consists mainly of clear (flint), brown (amber), and green glass contain-
ers. About 2.5 billion pounds of glass containers are collected annually. The glass is crushed
into cullet (crushed glass) and purchased by glass container manufacturers, who make it into new
bottles and jars. Every pound of cullet used saves approximately the same amount of raw
materials used to make glass, namely sand, soda ash, and limestone.
Cullet prices are generally highest for clear glass, and lowest for mixed colored glass.
Prices paid by glass companies for large quantities of crushed cullet fluctuate depending on
demand and freedom from contamination. Demand for cullet sometimes depends on what color
glass a company produces (e.g., a company may only make brown beer bottles so it does not
need to buy green glass).
Aluminum
Aluminum is one of the most important materials collected in recycling programs because
the demand and high prices paid by aluminum manufacturers make it profitable for groups and
recycling businesses. Aluminum is easily remelted and remolded into new products. It requires
95 percent less energy to process aluminum metal from scrap than to produce it from raw re-
sources. Recycling eliminates all of the energy required for major steps in aluminum production,
from the mining of the bauxite ore through the reduction process.
Aluminum beer and soda cans have become the largest source of aluminum scrap used by
the aluminum industry. Aluminum manufacturing plants purchase large quantities of aluminum
cans from recycling businesses and programs.
Other all-aluminum items such as TV dinner and foil pie plates, foil food wrap, aluminum
siding, storm doors, windows, and lawn furniture also can be recycled. These items are recycled
separately from aluminum cans because of their different aluminum composition.
Tin and Bi-Metal Cans
Cans made of tin-coated steel (food cans) and bi-metal cans (which are tin-coated steel
with an aluminum end, usually a beverage can) are recyclable. Tin-coated and bi-metal cans can
be used directly as steel scrap in steel manufacturing furnaces. The material must be baled and
delivered in truckload quantities. Only a small percentage of bi-metal cans can be used in steel
furnaces because of the aluminum content of the cans.
Scrap Metal
Ferrous metal items (other than cans) which are made of cast iron and steel sheet metal,
and nonferrous metal items made of nickel, bronze, copper, brass, and lead can be recycled.
Most ferrous and nonferrous metal is collected by scrap metal dealers from industrial businesses.
There are a number of small businesses, however, which collect much metal scrap from non-
222
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Establishing a Recycling Program
industrial sources. The price paid by scrap dealers depends on the market price for the various
types of metal and their priority of scrap.
Plastics
Plastics recycling generally fits into three main categories:
Polyethylene - These plastics can consist of:
• HDPE (high-density polyethylene)
• PET (polyethylene terepthalate)
• LDPE (low-density polyethylene)
Polyethylene plastics are obtained from many sources including milk jugs, plastic oil bottles,
laundry detergent containers, soft drink bottles, and plastic bags.
Mixed plastics - Consists of items made from various combinations of HDPE, PET,
LDPE, PVC, polystyrene, and polypropylene. They may be recycled to produce a variety of
products such as cable reels, paving blocks, flower pots, drain pipe, and fencing.
Polyvinvl chloride (PVC)- Used primarily for piping and is not a major component of
plastic recycling.
Collected PET and HDPE are generally sold in baled form, but can also be chopped into
small flakes or granules, or pelletized (most closely approximating the component resins). The
primary consumers of old plastic beverage containers are plastic fiber manufacturers. PET scrap
is successfully being employed in the manufacture of fiber fill for jackets, pillows, and sleeping
bags, as an interliner in upholstery, as a fiber in carpet construction, and as filler media. Addi-
tional end uses include the manufacture of industrial strapping, wall tile, flooring, and tail light
lenses, HDPE plastic can be used to make lumber boards for boat piers and garden furniture,
flower pots, toys, trash cans, and plastic containers for sorting recyclable materials at home.
The use of these types of plastics at Air Force installations is quite common. Learning to
identify when this material is ready for replacement, how it can be segregated as waste, and what
to do with it involves dealing with scheduling, procurement, contractors, and base administra-
tion.
Used Oil
The recycling and reuse of used oil is a waste minimization effort widely used throughout
Air Force installations. Recycling of used oil from the crankcases of cars, motorcycles, boats,
and lawnmowers, keeps the oil out of waterways and saves energy over the use of virgin oil. Oil
can be turned in at all auto-hobby shops and base service stations for recycling. Most collected
used oil is cleaned and recycled into industrial fuel oil.
223
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Appendix G
Waste oil is not considered a hazardous waste under federal regulations if it is recycled.
Waste oil contaminated by other hazardous wastes (such as solvents) cannot be recycled, and
disposing of such oil is very expensive. Precautions should be taken to properly segregate waste
oil from other materials to prevent it from becoming contaminated.
Under some states' regulations, used oil is regulated as a hazardous waste. Air Force
installations that are located in these states are required to comply with state guidelines concern-
ing the management of hazardous waste (i.e., hazard determination, manifesting, labeling, re-
cordkeeping) when handling waste oil.
Household Yard Wastes
Leaves, grass, clippings, prunings, wood waste, and other vegetative debris can exceed
20 percent of municipal solid waste in many urban areas, especially during the autumn leaf
season. Volume at Air Force locations varies by geographic location, but the cumulative volume
represents a significant single waste source.
Leaves and other yard clippings can best be recycled by composting. Compost provides
excellent soil conditioner and mulch, and adds important nutrients to soil. Compost can be sold
to landscape contractors and nurseries as a soil conditioner. A list of such establishments may
exist or be developed for the communities around a base. This provides a good public relations
opportunity.
White Goods
The term "white goods" refers to bulky items such as large electrical appliances (e.g.,
refrigerators, stoves) and metal furnishings which are occasionally discarded by homes and busi-
nesses. These items are usually recyclable as low grade scrap metal. The collection of
white goods for recycling typically occurs at waste disposal facilities, such as landfills,
rather than at community recycling centers.
White goods contain increasing amounts of plastics and other non-metal parts which has
lessened the demand for white goods as a source of metal scrap. Some scrap processors no longer
accept white goods on a regular basis or have become more cautious about which items they will
accept because of potential problems with hazardous materials in certain items. For example,
some refrigerators made before 1979 might have polychlorinated biphenyls (PCBs) in their elec-
trical components. Some scrap processors will only accept such appliances if the electrical
components have been stripped out, or will accept them but will not pay for them.
Tires
Tires can be recycled in many ways. They can be:
• Retread;
224
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Establishing a Recycling Program
• Split and die punched to make assorted products such as gaskets, bumpers, and mats.
• Ground into a fine crumb rubber for use in tire manufacturing (limited use), molded
products, paved sports surfaces, roofing materials, and asphalt road paving materials.
• Shredded or cut into small chips for use as a fuel, usually for co-burning with wood
waste, coal, or solid waste;
• Thermal processed (pyrolysis) to recover oils, gas, carbon, and other products;
• Burned whole as a fuel to produce steam and electricity; and
• Used for miscellaneous projects such as flower pots and fishing reefs.
Several of these procedures occur on-base because of the abundance of tires used. Considerable
sources and amounts of tires end up as bulk waste at Air Force bases every year.
Clothing, Furniture, and Other Reusable Items
In addition to organizations involved in recycling materials for processing into new manu-
factured goods, there are organizations that specialize in collecting particular items for direct
reuse, sometimes after repairing them. These include charitable organizations such as the Salva-
tion Army, Am Vets, and Goodwill, as well as commercial organizations such as used clothing
and furniture stores, and local flea markets. Thrift and consignment shops and used book and
furniture dealers are usually identified in telephone directory yellow pages. Used books and
records can sometimes be donated to libraries, schools, day care centers, senior citizens centers,
and other charitable organizations, depending on organization needs.
Some communities have developed special programs for using surplus (usually not used)
materials. Lumber, plumbing fixtures, doors, windows, and other materials which have been
donated are distributed to non-profit organizations. Instead of being discarded, these miscella-
neous items may be reused by the base or may benefit local communities, hospitals, schools, and
churches.
Create a list of recycle/re-use possibilities and conduct a public outreach campaign. It
will serve as positive public relations for the base and provide additional information and poten-
tial business to your solid waste management program, and will also help focus other components
of the PPP at the same time
Guidelines for Preparation of Recyclable Materials
Recycling centers and curbside collection systems generally require some minor prepara-
tion of materials before acceptance for recycling. This preparation is necessary to meet buyer
specifications or the specifications of manufacturers who will make new products out of the
recycled materials. Basic preparation may involve separation of different types of materials and
225
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Appendix G
removal of contaminants such as food wastes. General guidelines for each material are listed
blow.
Paper Products
Newspaper
• Tie with twine in a bundle about 1 ft high or put in brown grocery bags (check
with collection center to see if they accept bagged newspapers).
Corrugated Cardboard Boxes
• Flatten, remove tape and bundle.
• Do not include plastic coated corrugated.
• Brown grocery bags and brown wrapping paper are sometimes accepted. If they
are, keep separate from corrugated.
High Grade Office Paper
• White typing, bond, and photography paper, tablet paper, computer printout, and
tabulating cards can be recycled.
• Ask collection center about specific instructions and types of paper accepted.
• Do not include colored paper, carbon paper, tape, gummed labels, window enve-
lopes, plastic coated paper, cardboard, or magazines.
• Remove large stapes and paper clips.
Magazines, Telephone Books, Miscellaneous Paper
• Bundle separately from newspapers or office paper
• Do not include carbon paper.
• Ask collection center for specific instructions and types of paper accepted.
Cans
Aluminum Cans
These are usually cans without side seams, which often say 100 percent alumi-
•
num.
Cans should be reasonably clean (no dirt or food residue).
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Establishing a Recycling Program
Bi-Metal Cans
• These are usually beverage cans with steel seamed sides and one or two aluminum
ends.
• Bi-metal carts must be kept separate from aluminum cans.
• Markets are limited, so check with the recycling center to see if they are accepted.
• To determine metal type, test with magnet. Magnets will not stick to aluminum.
• Remove the ends.
• Flatten.
Tin (Steel) Cans
• Rinse to remove food residue. This is very important, because excessive contamination
interferes with the recycling process.
• Remove paper label is possible.
• Storage is easier if ends of can are removed and flattened.
Glass Bottles and Jars
• Rinse to remove food residue.
• Paper labels may be left on.
• Remove metal caps and lids.
• Some collection centers require removal of metal neck rings on glass beverage contain-
ers. Check with your collection center to be sure what their requirements are.
• Leave glass containers intact and separate by color. Some collection centers will accept
mixed brown and green glass.
• Do not include milk-white glass, plate glass, dinnerware, and light bulbs.
Scrap Metal
• Rinse foil food wrap, TV dinner trays, and aluminum pie pans to remove food residue.
• Call collection center for specific preparation instructions for aluminum siding, storm
doors, windows, and lawn furniture.
Other Metal Scraps
• Ask collection center for specific preparation instructions.
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Appendix G
• Do not mix ferrous (steel, cast-iron) and nonferrous (brass, copper, lead, aluminum)
scrap.
Plastic Soft Drink and Milk Bottles
• Very few collection centers accept plastic. Find a collection center before saving plas-
tic bottles.
• Remove metal rings and caps/rinse.
• Flatten to use less storage space.
• Separate PET (soft drink) and HOPE (milk) containers.
Used Oil
• Drain oil into a non-breakable container with a tight-fitting cap, such as a sturdy plastic
bottle.
• Do not mix with gasoline, antifreeze, solvents, brake fluid, or refrigerator oil.
• Do not put in garbage cans, pour down sewers or storm drains, or dump on the ground
or in streams, rivers, or lakes.
• Take oil to a local collection center such as a participating service station.
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Establishing a Recycling Program
229
-------
Appendix G
GOALS (RECYCLING/REDUCTION/DIVERSION)
State
Alabama
Arkansas
California
Connecticutt
District of Columbia (DC)
Florida
Georgia
Hawaii
Illinois
Indiana
Iowa
Kentucky
Louisiana
Maine
Maryland
Massachusettes
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
Goal (%)
25
40
50
25
45
30
25
50
25
50
50
25
25
50
20
56
40 to 60
25
25
40
25
50
25
By Year
2000
2000
1991
1991
1996
1994
1996
2000
2000
2001
2000
1997
1992
1994
1994
2000
2005
1993
1996
1998
1996
2002
230
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Establishing a Recycling Program
GOALS (RECYCLING/REDUCTION/DIVERSION)
State
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Vermont
Virginia
Washington
West Virginia
Goal (%)
40
60
50
50
25
40
25
50
25
70
30
50
25
40
40
25
50
50
By Year
2000
1995
2000
1997
1993
1994
2000
1997
1997
2001
1995
1994
2000
1995
1995
2010
231
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APPENDIX H
POLLUTION PREVENTION OPPORTUNITY
ASSESSMENT WORKSHEETS
233
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Appendix H
(Source: The following information is reproduced from the EPA's Facility Pollution Prevention
Guide. EPA/600/R-92/088, May 1992)
The worksheets in this appendix were designed to be useful at various point is the
development of a pollution prevention program. Table H-l lists the worksheets and describes the
purpose of each.
Since these worksheets are intentionally generic, you may decide to redesign some or all
of them to be more specific to your facility once you have your program underway. The
checklists in Appendix B, of the above referenced document, contains information that
your may find helpful in deciding how to customize these worksheets to fit your situation.
Appendix C (also of the above reference document) contains examples of worksheets as
they might be customized for a pharmaceutical company.
TABLE H-l. LIST OF POLLUTION PREVENTION ASSESSMENT WORKSHEETS
Phase
Number and Title
Purpose/Remarks
1. Assessment Overview
Assessment Phase
2. Sice Description
3. Process Infoimation
4. Input Materials Summary
5. Products Summary
6. Waste Stream Summary
7. Option Generation
8. Option Description
Feasibility Analysis Phase
9. Profitability
Summarizes the overall program.
Lists background information about the facility, including
location, products, and operations.
This is a checklist of process information that can be collected
before the assessment effort begins.
Records input material information for a specific production
or process area. This includes name, supplier, hazardous
component or properties, cost, delivery and shelf-life
information, and possible substitutes.
Identifies hazardous components, production rate, revenues,
and other information about products.
Summarizes the information collected for several waste
streams. This sheet can be used to prioritize waste streams
to assess.
Records options proposed during brainstorming or nominal
group technique sessions. Includes the rationale for
proposing each option.
Describes and summarizes information about a proposed
options. Also notes approval of promising options.
This worksheet is used to identify capital and operating costs
and to calculate the payback period.
234
-------
Pollution Prevention Opportunity Assessment Worksheets
Firm
Site
Date
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By
Checked By
Sheet of
of Page of
WORKSHEET
1
ASSESSMENT OVERVIEW
Eatablleh the Pollution Prevention Program
• EMCUIM lev* Decision
• Policy Statement
• Consensus Bulking
Organlsa Program
* Name Task Foroa
• Stale Goals
Do Preliminary Aaaeeamenl
» Collect Oca
• Review Stan
• Establish Priorities
Writ* Program Plan
Consider Exltmal Group*
D«ffn* Objactvti
IdMttfy Potonual ObstadM
Devrtop Schedule
Do Detailed AteeMmanl
Name Ast«f sment Team(i)
Review Data and Srta(«)
Organtza and Document Information
Define Pollution Prevention Option*
• Propose Option*
• SoMnOpton*
Do Feasibility Analytea
• Technical
• Environmental
• Eoonomic
Write At*e**ment Report
tmplemenl the Plan
• Select Projeeu
• Obtain Funding
• Install
Measure Progresa
• Acquire Data
• Analyze Results
T
| M»lnUln Pollution Pnvenllon Program I
235
-------
Appendix H
Firm
Site
Date
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By _
Checked By _
Sheet of
Page
of
WORKSHEET
SITE DESCRIPTION
Firm:
Plant:
Deoartment:
Area:
Street Address:
Citv:
State/Zio Code:
Teleohone:
Major Products:
SIC Codes:
EPA Generator Number:
Major Unit:
Product or Service:
Operations:
Facilities/Equipment Age:
236
-------
Pollution Prevention Opportunity Assessment Worksheets
Firm ^
Site
Date Proj.
Pollution Prevention
kssMsment Worksheets
No.
WORKSHEET PROCESS INFORMATION
3
P
C
s
reoared Bv
becked Bv
heet .,. of Page of
Process Unit/Ooeration:
Operation Type: Q Continuous Q Discrete
D Batch or Semi-Batch Q Other
Document
Process Flow Diagram
Material/Enerqv Balance
Design
Operating
Flow/Amount Measurements
Stream
Analyses/Assays
Stream
Process Descriotion
Operating Manuals
Equipment List
Equipment Specifications
Piping and Instrument Diagrams
Plot and Elevation Plants}
Work Flow Diagrams
Hazardous Waste Manifests
Emission Inventories
Annual/Biennial Reports
Environmental Audit Reports
Permit/Permit Aoolications
Batch Sheet(s)
Materials Application Diagrams
Product Composition Sheets
Material Safety Data Sheets
Inventory Records
Operator Logs
Production Schedules
Status
Complete?
(Y/N)
Current?
(Y/N)
Last
Used in this
Report (Y/N)
Document
237
-------
Appendix H
p
Firm At*
Site , ,__
Dilution Prevention
essment Worksheets
Date Proi. No.
Preoared Bv
Checked Bv
Sheet of Pane of
WORKSHEET INPUT MATERIALS SUMMARY
Attribute
Name/ID
Source/Supplier
Component/Attribute of Concern
Annual Consumption Rate
Overall
Components) of Concern
Purchase Price. $ per
Overall Annual Cost
Delivery Mode1
Shipping Container Size & Type2
Storage Mode3
Transfer Mode4
Empty Container Disposal Management5
Shelf Life
Supplier Would
— accept expired material? (Y/N)
— accept shipping containers? (Y/N)
— revise expiration date? (Y/N)
Acceptable Substitute(s), if any
Alternate Supplier(s)
Description
Stream No.
Stream No.
Stream No.
Notes: 1. e.g., pipeline, tank car, 100 bbl tank truck, truck, etc.
2. e.g., 55 gal drum 100 Ib paper bag, tank, etc.
3. e.g., outdoor, warehouse, underground, aboveground, etc.
4. e.g., pump, forldift, pneumatic transport, conveyor, etc.
5. e.g., crush and landfill, clean and recycle, return to supplier, etc.
238
-------
Pollution Prevention Opportunity Assessment Worksheets
_.
Firm —. At
Site
Pollution Prevention
sessment Worksheets
Date Prnj. No.
Prepared Bv
Checked Bv
Sheet of Paae of
WORKSHEET PRODUCTS SUMMARY
5
Attribute
Name/ID
Component/Attribute of Concern
Annual Production Rate
Overall
Component(s) of Concern
Annual Revenues, $
Shipping Mode
Shipping Container Size & Type
Onsite Storage Mode
Containers Returnable (Y/N)
Shelf Life
Rework Possible (Y/N)
Customer Would
— relax specification (Y/N)
— accept larger containers (Y/N)
Description
Stream No.
Stream No.
Stream No.
239
-------
Appendix H
Firm
Site
Date
Pollution Prevention
Assessment Worksheets
Proi. No.
Prepared Bv
Checked Bv
Sheet of Paae of
WORKSHEET WASTE STREAM SUMMARY
Attribute
Waste ID/Name:
Source/Origin
Component or Property of Concern
Annual Generation Rate (units )
Overall
Component(s) of Concern
Cost of Disposal
Unit Cost ($ per: )
Overall (per year)
Method of Management1
Priority Rating Criteria2
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Relative
Wt. (W)
Sum of Priority Rating Scores
Priority Rank
Description
Stream No.
Rating
(R) R x W
Z(RxW)
Stream No.
Rating
(R) R x W
I(RxW)
Stream No.
Rating
(R) R x W
I(RxW)
Notes: 1 . For example, sanitary landfill, hazardous waste landfill, on-site recycle, incineration, combustion
with heat recovery, distillation, dewatering, etc.
2. Rate each stream in each category on a scale from 0 (none) to 10 (high).
240
-------
Pollution Prevention Opportunity Assessment Worksheets
Firm
Site.
Date
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By _
Checked By _
Sheet of
Page of
WORKSHEET
OPTION GENERATION
Meeting format (e.g., brainstorm!ng, nominal group technique)
Meeting Coordinator ________^__
Meeting Participants
List Suggestion Options
Rationale/Remarks on Option
241
-------
Appendix H
Firm
Site
Date
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By
Checked By
Sheet of Page of
WORKSHEET
8
OPTION DESCRIPTION
Option Name:
Briefly describe the option:
Waste Stream(s) Affected:
Input Material(s) Affected:
Product(s) Affected:
Indicate Type: D Source Reduction
Equipment-Related Change
Personnel/Procedure-Related Change
Materials-Related Change
0 Recycling/Reuse
Onsite
Offsite
Originally proposed by:
Reviewed by:
Approved for study?
yes
Reason for Acceptance or Rejection
Material reused for original purpose
Material used for a lower-quality purpose
Material sold
no By:.
Date:
Date:
242
-------
Pollution Prevention Opportunity Assessment Worksheets
Firm
Site .
Date
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By
Checked By
Sheet of Page
of
WORKSHEET
PROFITABILITY
Capital Costs
Purchased Equipment
Materials
Installation
Utility Connections
Engineering
Start-up and Training
Other Capital Costs
Total Capital Costs
Incremental Annual Operating Costs
Change in Disposal Costs
Change in Raw Material Costs
Change in Other Costs
Annual Net Operating Cost Savings
Payback Period (in years)
Total Capital Costs
Annual Net Operating Cost Savings
243
-------
-------
APPENDIX I
ORDERING POLLUTION PREVENTION
PUBLICATIONS
245
-------
Appendix I
This appendix provides a means to order Pollution Prevention Research Branch (PPRB) publica-
tions and information from the EPA. The documents listed here were generated through PPRB
research, development and demonstration programs, which includes, but is not limited to, the
WREAFS program.
In this appendix, each page is an individual ordering form for pollution prevention guides, re-
search summaries and briefs. To obtain a copy of a publication(s), simply fill out the necessary
form and send it to the CERI Publication Unit, as indicated. There is no charge for these
publications.
Environmental management is a continuously evolving field and the WREAFS Program is com-
mitted to generating accurate, useful guidance and tools for federal managers in achieving the
goal of environmental compliance with mission accomplishment. To that end, this guide will
require regular updates and revision as events dictate. Therefore, this appendix includes a form
for joining the WREAFS Mailing List and receiving future updates. The form also allows the
reader to request further information about WREAFS and to provide commentary and correc-
tions for the updates being planned for this guide.
To conserve on resources and limit publication waste, future updates will be developed on a
section by section basis. That is, when one part of the guide is seen to have been overtaken by
events, or contacts have changed (e.g., individual department pollution prevention policies as
noted in Appendix J, or State program contacts in Appendix E), WREAFS will revise that section
and send it to addressees on the WREAFS Mailing List. Revisions will be individually dated to
assist the reader in maintaining current information.
The reader is encouraged to take advantage of the pollution prevention information available. In
order to keep information current and to ensure the quality of content in future revisions, the
reader is encouraged to offer comments - especially criticism - to improve the guide. The PPRB
would also appreciate any case study examples for future publication.
246
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Ordering Pollution Prevention Publications
WREAFS PROGRAM MAILING LIST
Should any holder of this guide require updates, please fill out this form to be entered on the
WREAFS Mailing List. Note: if you did not receive this guide directly form the PPRB officer,
you must submit this form to be placed on the WREAFS Mailing List.
PLEASE RETURN THIS FORM TO:
The WREAFS Program
Pollution Prevention Research Branch
U.S. EPA, Risk Reduction Engineering Laboratory
26 West Martin Luther King
Cincinnati, Ohio 45268
TO THE POLLUTION PREVENTION RESEARCH BRANCH (PPRB):
Please include my name and address on the WREAFS mailing list:
Name
Address
I would like to receive additional WREAFS Publications and Federal facility
information as it becomes available.
My review comments/critique is enclosed.
A case study/example of a pollution prevention accomplishment at my facility is
enclosed.
247
-------
Appendix I
P2 PUBLICATIONS November 30,1993
PLEASE PLACE A CHECK NEXT TO THE GUIDES YOU WISH TO ORDER AND MAIL TO:
CERI PUBLICATIONS UNIT, US EPA
26 W. MARTIN LUTHER KING DRIVE
CINCINNATI, OH 45268
(513) 569-7562
GUIDES TO POLLUTION PREVENTION:
THE PESTICIDE FORMULATING INDUSTRY EPA/625/7-9Q/004
THE PAINT MANUFACTURING INDUSTRY EPA/625/7-90/005
THE FABRICATED METAL PRODUCTS INDUSTRY EPA/625/7-90/006
THE PRINTED CIRCUIT BOARD MANUFACTURING INDUSTRY EPA/62S/7-90/007
THE COMMERCIAL PRINTING INDUSTRY EPA/62S/7-90/008
SELECTED HOSPITAL WASTE STREAMS EPA/625/7-90/009
RESEARCH AND EDUCATION INSTITUTIONS EPA/62S/7-90/010
THE PHOTOPROCESSING INDUSTRY EPA/625/7-91/012
THE AUTO REPAIR INDUSTRY EPA/625/7-91/013
THE FIBERGLASS REINFORCED AND COMPOSITE PLASTICS INDUSTRIES EPA/625/7-91/014
MARINE MAINTENANCE AND REPAIR INDUSTRY EPA/625/7-91/015
THE AUTOMOTIVE REFINISHING INDUSTRY EPA/625/7-91/016
THE PHARMACEUTICAL INDUSTRY EPA/625/7-91/017
METAL CASTING AND HEAT TREATING INDUSTRY EPA/625/R-92/009
METAL FINISHING INDUSTRY EPA/62S/R-92/011
MECHANICAL EQUIPMENT REPAIR EPA/625yR-92/008
NON-AGRICULTURAL PESTICIDE USERS EPA/625/R-93/009
248
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Ordering Pollution Prevention Publications
OTHER MANUALS:
FACILITY POLLUTION PREVENTION GUIDE
OPPORTUNITIES FOR POLLUTION PREVENTION RESEARCH TO SUPPORT
THE 33/50 PROGRAM
LIFE CYCLE DESIGN GUIDANCE MANUAL
LIFE CYCLE ASSESSMENT: INVENTORY GUIDELINES AND PRINCIPLES
POLLUTION PREVENTION CASE STUDIES COMPENDIUM
INDUSTRIAL POLLUTION PREVENTION OPPORTUNITIES FOR THE 1990fS
ACHIEVEMENTS IN SOURCE REDUCTION AND RECYCLING FOR TEN
INDUSTRIES IN THE UNITED STATES
BACKGROUND DOCUMENT ON CLEAN PRODUCTS RESEARCH
AND IMPLEMENTATION
OPPORTUNITIES FOR POLLUTION PREVENTION RESEARCH TO SUPPORT
THE 33/50 PROGRAM
WASTE MINIMIZATION PRACTICES AT TWO CCA
WOOD-TREATMENT PLANTS
MEASURING POLLUTION PREVENTION PROGRESS PROCEEDINGS
EPA/600/R-92/068
EPA/600/R-92/175
EPA/600/R-92226
EPA/600/R-92/245
EPA/600/R-92/046
EPA/600/B-91/052
EPA/600/2-91/051
EPA/600/2-90/048
EPA/600/R-92/175
EPA/600/R-93fl68
EPA/600/R-93/151
A PRIMER FOR FINANCIAL ANALYSIS OF POLLUTION
PREVENTION PROJECTS
INNOVATIVE GLEAM TECHNOLOGIES CASE STUDIES
EPA/600/R-9Gtf)59
EPA/600/R-93/175
TO CERI PUBLICATIONS UNIT:
PLEASE SEND THE ABOVE GUIDES TO ME AT THE FOLLOWING ADDRESS:
NAME
ADDRESS
249
-------
Appendix I
PROJECT SUMMARIES / PROJECT REPORTS
PLEASE PLACE A CHECK NEXT TO THE GUIDES YOU WISH TO ORDER AND MAIL TO:
CERI PUBLICATIONS UNIT, US EPA
26 W. MARTIN LUTHER KING DRIVE
CINCINNATI, OH 45268
(513) 569-7562
EPA Document
WMOA Report and Project Summary - Fort Riley, Kansas
WMOA Report and Project Summary • Philadelphia Naval Shipyard
WMOA Report and Project Summary - Coast Guard/ Governor's Island
Management of Household and Small-Quantity-Generator Hazardous Waste
in the United States
WMOA Report and Project Summary - Naval Undersea Warfare Engineering
Station, Keyport, WA
WMOA Report and Project Summary - Optical Fabrication Laboratory,
Rtzsimmons Army Medical Center, Denver, Colorado
WMOA Report and Project Summary - A Truck Assembly Plant
WMOA Report and Project Summary - A Photofinishing Facility
WMOA Report and Project Summary - Scon Air Force Base
Guidance Document for the WRITE Pilot Program with State
and Locsil Governments
Machine Coolant Waste Reduction by Optimizing Coolant Life
Recovery of Metals Using Aluminum Displacement
Metal Recovery/Removal Using Non-Electrolytic Metal Recovery
Evaluation of Five Waste Minimization Technologies at the
General Dynamics Pomona Division Plant
An Automated Aqueous Rotary Washer for the Metal Finishing Industry
Automotive and Heavy-Duty Engine Coolant Recycling by Filtration
Automotive and Heavy-Duty Engine Coolant Recycling by Distillation
Onsite Waste Ink Recycling
Diaper Industry Workshop Report
EPA/600/S2-90/031
EPA/600/S2-90/046
EPA/600/S2-90/062
EPA/600/S2-89/064
EPA/600/S2-91/030
EPA/600/S2-91/031
EPA/600/S2-91/038
EPA/600/S2-91/039
EPA/600/S2-91/054
EPA/600/S8-89/070
EPA/600/S2-90/033
EPA/600/S2-90/032
EPA/600/S2-90/035
EPA/600/S2-91/067
EPA/600/SR-92/188
EPA/600/S2-91/066
EPA/600/SR-92/024
EPA/600/SR-92/251
EPA/600/S2-91/018
CONTINUE ON BACK
250
-------
Ordering Pollution Prevention Publications
Industrial Pollution Prevention Opportunities for the 1990s
Hospital Pollution Prevention Case Study
Waste Minimization Audits at Generators of Corrosive and Heavy Metal Wastes
Waste Minimization Audit Report: Case Studies of Minimization of
Cyanide Waste from Electroplating Operations
Waste Minimization Audit Report: Case Studies of Minimization of
Solvent Waste from Parts Cleaning and From Electronic Capacitor
Manufacturing Operations
Waste Minimization in the Printed Circuit Board Industry - Case Studies
Waste Minimization Audit Report: Case Studies of Minimization of
Solvent Wastes and Electroplating Wastes at a OOD Installation
Waste Minimization Audit Report: Case Studies of Minimization of
Mercury-Bearing Wastes at a Mercury Cell Chloral kali Rant
Waste Minimization in the Printed Circuit Board Industry - Case Study
Pollution Prevention Opportunity Assessment: USDA Beltsville Agricultural
Research Center, Beltsville, Maryland
Pollution Prevention Opportunity Assessment for Two Laboratories at
Saridia National Laboratories
Ink and Cleaner Waste Reduction Evaluation for Flexographic Printers
Mobile Onsite Recycling of Metalworking Fluids
Evaluation of Ultrafiltration to Recover Aqueous Iron Phosphating/
Oegreasing Bath
Recycling Nickel Electroplating Rinse Waters by Low Temperature
Evaporation and Reverse Osmosis
A Fluid Sorbent Recycling Device for Industrial Fluid Users
EPA/600/S8-91/052
EPA/600/S2-91/024
EPA/600/S2-87/055
EPA/600/S2-87/056
EPA/600/S2-87/057
EPA/600/S2-88/008
EPA/600/S2-88/010
EPA/600/S2-88/011
EPA/600/S2-88/008
EPA7600/SR-93/008
EPA/600/SR-93/015
EPA/600/SR-93/086
EPA/600/SR-93/114
EPA/600/SR-93/144
EPA/600/SR-93/160
EPA/600/SR-93/154
TO CERI PUBLICATIONS UNIT:
PLEASE SEND THE ABOVE GUIDES TO ME AT THE FOLLOWING ADDRESS:
NAME
ADDRESS
251
-------
Appendix I
ENVIRONMENTAL RESEARCH BRIEFS
PLEASE PLACE A CHECK NEXT TO THE GUIDES YOU WISH TO ORDER AND MAIL TO:
CERI PUBLICATIONS UNIT, US EPA
26 W. MARTIN LUTHER KING DRIVE
CINCINNATI, OH 45268
(513) 569-7562
Waste Minimization Assessment for a:
Manufacturer of Printed Plastic Bags
Metal Parts Coating Plant
Manufacturer of Outdoor Illuminated Signs
Manufacturer of Rebuilt Railway Cars and Components
Manufaicturer of Brazed Aluminum Oil Coolers
Manufacturer of Heating, Ventilating, and Air Conditioning Equipment
Bumper Refinishing Plant
Multilayered Printed Circuit Board Manufacturing
Manufacturer of Printed Circuit Boards
Paint Manufacturing Plant
Manufacturer of Compressed Air Equipment Components
Manufacturer of Aluminum Cans
Manufacturer of Refurbished Railcar Bearing Assemblies
Manufacturer of Prototype Printed Circuit Boards
Manufacturer of Speed Reduction Equipment
Manufacturer of Printed Labels
Manufacturer of Chemicals
A Dairy
Manufacturer of Metal-Cutting Wheels and Components
Manufacturer of Automotive Air Conditioning Condensers and Evaporators
Printed Circuit Board Manufacturer
Manufacturer of Components for Automobile Air Conditioners
Manufacturer of Aluminum Extrusions
Manufacturer Producing Galvanized Steel Parts
252
EPA/600/M-90/017
EPA/600/M-91/015
EPA/600/M-91/016
EPA/600/M-91/017
EPA/600/M-91/018
EPA/600/M-91/019
EPA/600/M-91/020
EPA/600/M-91/021
EPA/600/M-91/022
EPA/600/M-91/023
EPA/600/M-91/024
EPA/600/M-91/025
EPA/600/M-91/044
EPA/600/M-91/045
EPA/600/M-91/046
EPA/600/M-91/047
EPA/600/S-92/004
EPA/600/S-92/005
EPA/600/S-92/006
EPA/600/S-92/007
EPA/600/S-92/008
EPA/600/S-92/009
EPA/600/S-92/010
EPA/600/S-92/011
-------
Ordering Pollution Prevention Publications
Manufacturer of Commercial Ice Machines and Ice Storage Bins
Manufcicturer of Water Analysis Instrumentation
Manufacturer of Can-Manufacturing Equipment
Manufcicturer of Metal Bands, Clamps, Retainers, and Tooling
Manufacturer of Permanent-Magnet OC Electric Motors
Manufacturer of Military Furniture
Aluminum Extrusions Manufacturer
Manufacturer of Metal-Plated Display Racks
Manufacturer of Motor Vehicle Exterior Mirrors
Manufacturer of Sheet Metal Cabinets and Precision Metal Parts
Manufacturer Producing Treated Wood Products
Manufacturer of Industrial Coatings
Manufacturer of Cutting and Welding Equipment
Manufacturer of Finished Metal Components
Manufacturer of Machined Parts
Manufacturer of Injection-Molded Car and Truck Mirrors
Manufacturer Producing Printed Circuit Boards
Manufacturer of Custom Molded Plastic Products
Manufacturer of Sheet Metal Components
Manufacturer of Silicon-Controlled Rectifiers and Schottky Rectifiers
Manufacturer of Penny Blanks and Zinc Products
Manufacturer of Baseball Bats and Golf Clubs
Manufacturer of Product Carriers and Printed Labels
Manufacturer of Rotogravure Printing Cylinders
EPA/600/S-92/012
EPA/600/S-92/013
EPA/600/S-92/014
EPA/600/S-92/015
EPA/600/S-92/016
EPA/600/S-92/017
EPA/600/S-92/018
EPA/600/S-92/019
EPA/600/S-92/020
EPA/600/S-92/021
EPA/600/S-92/022
EPA/600/S-92/028
EPA/600/S-92/029
EPA/600/S-92/030
EPA/600/S-92/031
EPA/600/S-92/032
EPA/600/S-92/033
EPA/600/S-92/034
EPA/600/S-92/035
EPA/600/S-92/036
EPA/600/S-92/037
EPA/600/S-93/007
EPA/600/S-93/008
EPA/600/S-93/009
TO CERI PUBLICATIONS UNIT:
PLEASE SEND THE ABOVE GUIDES TO ME AT THE FOLLOWING ADDRESS:
NAME
ADDRESS
253
-------
Appendix I
New Jersey Research Briefs
PLEASE PLACE A CHECK NEXT TO THE BRIEFS TOU WISH TO ORDER AND MAIL TO:
CERI PUBLICATIONS UNIT, US EPA
26 W. MARTIN LUTHER KING DRIVE
CINCINNATI, OH 45268
(513) 569-7562
Waste Reduction Activities and Options for a:
Printer of Forms and Supplies for the Legal Profession
Nuclear Powered Electrical Generating Station
State DOT Maintenance Facility
Local Board of Education in New Jersey
Manufacturer of Finished Leather
Manufacturer of Paints Primarily for Metal Finishing
Manufacturer of Writing Instruments
Manufacturer of Room .Air Conditioning Units and Humidifiers
Autobody Repair Facility
Fabricator and Finisher of Steel Computer Cabinets
Manufacturer of Artists' Supply Paints
Manufacturer of Wire Stock Used for Production of Metal Items
Manufacturer of Commercial Refrigeration Units
Transporter of Bulk Plastic Pellets
Manufacturer of Electroplated Wire
Manufacturer of Systems to Produce Semiconductors
Remanufacturer of Automobile Radiators
Manufacturer of Fire Retardant Plastic Pellets
and Hot Melt Adhesives
Printing Plate Preparation Section of a Newspaper
Manufacturer of General Purpose Paints and Painting Supplies
EPA/600/S-92/003
EPA/600/S-92/025
EPA/600/S-92/026
EPA/600/S-92/027
EPA/600/S-92/039
EPA/600/S-92/040
EPA/600/S-92/041
EPA/600/S-92/042
EPA/600/S-92/043
EPA/600/S-92/044
EPA/600/S-92/045
EPA/600/S-92/046
EPA/600/S-92/047
EPA/600/S-92/048
EPA/600/S-92/049
EPA/600/S-92/050
EPA/600/S-92/051
EPA/600/S-92/052
EPA/600/S-92/053
EPA/600/S-92/054
254
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Ordering Pollution Prevention Publications
Manufacturer of Fine Chemicals Using Batch Processes EP.fi/600/S-92/055
Laminator of Paper and Cardboard Packages EPA/600/S-92/056
Manufacturer of Hardened Steel Gears EPA/600/S-92/057
Scrap Metal Recovery Facility EPA/600/S-92/058
Manufacturer of Electroplating Chemical Products EPA/600/S-92/059
Manufacturer of Plastic Containers by Injection Molding EPA/600/S-92/060
Fossil Fuel-Fired Electrical Generating Station EPA/600/S-92/061
Manufacturer of Commercial Dry Cleaning Equipment EPA/600/S-92/062
Electrical Utility Transmission System Monitoring
and Maintenances Facility EPA/600/S-92/063
Manufacturer of Orthopedic Implants EPA/600/S-92/064
TO CERI PUBLICATIONS UNIT:
PLEASE: SEND THE ABOVE RESEARCH BRIEFS TO ME AT THE FOLLOWING ADDRESS:
NAME
ADDRESS
255
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-------
APPENDIX J
FEDERAL AGENCY POLLUTION PREVENTION
PROGRAMS
257
-------
Appendix J
Note on the Preparation of Appendix J
The following agencies were contacted during preparation of this report under the as-
sumption that they would be the most likely to have begun Pollution Prevention programs be-
cause of the nature of their operations.
Agencies Described in Detail in Appendix J
Department of Defense - Air Force, Army, Navy
Department of Energy
Department of the Interior
Department of Justice
National Aeronautic Space Administration
Postal Service
Department of Transportation -- Coast Guard
Agencies in the Process of Developing Programs
Department of Agriculture
Department of Health and Human Services -- Food and Drug Administration
General Services Administration
National Security Agency
Agencies With Limited Action as of September, 1993
Central Intelligence Agency
Department of Commerce -- National Oceanic and Atmospheric Administration
Economic Development Administration
Tennessee Valley Authority
Department of Transportation -- Federal Aviation Administration, Federal Highway
Administration, Maritime Administration
Department of the Treasury
Department of Veterans Affairs
258
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Federal Agency Pollution Prevention Programs
DEPARTMENT OF DEFENSE -- U.S. AIR FORCE
Mission: To organize, train, and equip active duty and reserve
forces for the preservation of peace, national security and de-
fense. The Air Force's mission focuses on air operations.
Statement of Commitment: The Air Force Pollution Prevention
Policy sets forth guidelines for the operation and management of
a Pollution Prevention Program (PPP). The Program reduces
hazardous and toxic materials and wastes by means of source re-
duction and environmentally sound recycling at Air Force instal-
lations. PPP also involves efforts to improve personnel awareness
regarding installation operations that pollute so that actions to
in prove environmental compliance can be taken.
Pollution Prevention Goals: The Air Force has established quan-
titative goals for waste reduction and affirmative procurement.
The goals include:
• By the end of 1993, reduce municipal solid waste disposal
by 10% from 1992 baseline;
- At least 10% of all nonpaper products and 50% of all
paper products procured shall contain recycled material.
• By the end of 1996, reduce purchases of EPA 17 Industrial
Toxics by 50% from 1992 baseline.
- Reduce hazardous waste disposal by 25% from 1992
baseline;
- Reduce municipal solid waste disposal by 30% from
1992 baseline.
• By the end of 1997, reduce municipal solid waste disposal
by 50% from 1992 baseline;
• By the end of 1999, reduce hazardous waste disposal by
50% from 1992 baseline.
- Reduce volatile air emissions by 50% from 1993 base-
line.
Program
Planning
Required?
YES!
"...pollution
prevention provides
every installation
with the opportunity
to achieve
environmental
compliance in a
more efficient
manner,"
4 US Air Force Installation
Pollution Prevention Program
Manual. 1992
259
-------
Appendix J
DEPARTMENT OF DEFENSE -- U.S. AIR FORCE
Objectives:
• Reduce hazard-
ous materials in
new weapons
and existing
weapons sys-
tems, at installa-
tion and GOCOs.
• Acquire and apply
state of the art
pollution preven-
tion technologies.
• Establish a pollu-
tion prevention
investment strat-
egy-
A partial list of the qualitative goals and sub-objectives follows.
• Reduce the use of hazardous materials in all phases of new
weapons systems from concept through production, deploy-
ment, an ultimate disposal; find alternative materials and
processes, and measure their life cycle costs.
- By the end of 1994, institutionalize pollution prevention
including hazardous materials minimization and manage-
ment into the system acquisition process through the use
of policies, procedures, training, contract provisions,
and Federal Acquisition Regulation changes.
• Reduce the use of hazardous materials in existing weapons
systems by finding less hazardous materials and processes
and integrating them into TOs, MILSPECS, and
MILDSTDS.
- By the end of 1993, implement proactive procurement
policies and practices to integrate environmental perfor-
mance into the current approach to purchase recycled
materials to the maximum extent practical, and requiring
purchasing activities to use environmental performance
of vendors and products as selection criteria for award-
ing procurement contracts.
- By the end of 1993, prioritize the hazardous material
TOs, MILSPECS, and MILSTDS for existing weapon
systems for review.
- By the end of 1995, complete implementation of a haz-
ardous material identification and tracking capability at
the Air Logistics Centers, and by the end of 1996 export
it to the rest of the Air Force.
• Reduce hazardous materials use and waste generation at in-
stallations and GOCO facilities.
- By the end of 1992, develop installation and GOCOs
Pollution Prevention Plans.
- By the end of 1993
260
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Federal Agency Pollution Prevention Programs
DEPARTMENT OF DEFENSE - U.S. AIR FORCE
• Establish baseline for volatile and other air emis-
sions.
• Characterize installation waste streams to all
media.
• Reduce municipal solid waste disposal by 10%
from 1992 baseline.
• Inventory all existing processes and systems which
use hazardous materials/generate hazardous wastes.
• At least 10% of all non-paper products and 50% of
all paper products procured shall contain recycled ma-
terial.
• Acquire world class pollution prevention technologies and
distribute them throughout the Air Force.
• Apply new technology to pollution prevention.
Develop an Environmental Strategic Research, Develop-
ment, and Acquisition Plan to identify the technologies
needed to achieve pollution prevention.
• Establish an investment strategy in the Air Force to fund the
pollution prevention program.
Agency-specific Requirements: In accordance with the Pollution
Prevention Act of 1990, the Air Force requires all units, installa-
tions, and facilities worldwide (including Air Force units in unified
commands, the Air Force Reserve, the Air National Guard, Gov-
ernment Owned-Government Operated facilities, and Government
Owned-Contractor operated facilities) to develop waste reduction
plans and recycling programs.
"Our goal is to
prevent future
pollution by reducing
use of hazardous
materials and
releases of pollutants
into the environment
to as near zero as
feasible."
^ Air Force Pollution
Prevention Memorandum
261
-------
Appendix J
DEPARTMENT OF DEFENSE - U.S. AIR FORCE
Pmvantion Management Plan Content: Pollution Prevention Management Plans (PPMP) to be
developed at each installation will provide overall strategy that addresses the following areas:
• The installation's pollution prevention goals, objectives, strategies, (technologies and status), pro-
gram scope, and projects
• The selection criteria and prioritizing scheme for equipment upgrades and facility projects
• A summary of prevention opportunities
• Procedures to measure reductions
• Methods for tracking and reporting progress
PPMPs should address each of the following applicable sections:
• Industrial, maintenance, and cleanup operations:
- Hazardous waste
- Air emissions
- Industrial wastewater, sanitary wastewater, stormwater
- Other wastes
• Municipal solid waste
• Nonpoint source pollution
• Hazardous materials
• Integration with existing programs:
- Comprehensive planning
- Energy conservation
- Natural resources
- Water conservation
- Spill prevention and response
- Installation Restoration Program
- Pest management
- Noise abatement
• Education and incentives
262
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Federal Agency Pollution Prevention Programs
DEPARTMENT OF DEFENSE -- U.S. ARMY
Mission: To organize, train, and equip active duty and reserve
forces for the preservation of peace, national security and defense.
The Army's mission focuses on land operations. In addition, the
Army administers programs aimed at protecting the environment,
improving waterway navigation, flood and beach erosion control,
and water resources development.
Statement of Commitment: The Army's Environmental Strategy
into the 21st Century defines the Army's environmental vision: to
be a national leader in environmental and natural resource steward-
ship for present and future generations as an integral part of the
Army's mission. Pollution prevention is one of the strategy's four
major components (compliance, restoration, prevention, conserva-
tion).
Pollution Prevention Goals: The DoD has already reached its
goal of reducing hazardous waste generation by 50% from 1985
disposal levels. DoD has not yet finalized new source reduction
goals, in the interim, the Army's focus in on "continuous improve-
ment". As outlined in the Strategy, qualitative pollution preven-
tion goals include:
• Use a holistic approach to pollution prevention which looks
at all environmental media collectively.
- Establish an investment strategy to fund the Pollution Pre-
vention Program.
- Establish pollution prevention partnerships with industry,
the public, and special interest groups
- Acquire world class pollution prevention technology and
capability, and distribute Army wide.
- Reduce energy use, maximize energy efficiency, and re-
duce pollutants from energy and fuel sources.
• Systematically eliminate hazardous materials use and opera-
tions or processes that produce hazardous/solid waste and
other emissions.
- Meet DoD goals on HW and SW reduction at installations
and GOCOs (CONUS and OCONUS).
The philosophy is
simple: you don't
have a problem if
you don't pollute."
4 Michael P.W. Stone,
Secretary of the Army
263
-------
Appendix J
DEPARTMENT OF DEFENSE - U.S. ARMY
"Programs and
actions will be
...carried out in such
a way as to prevent,
minimize or mitigate
degradation of the
environment or
endangerment of
human health"
AR 200-1
- Reduce or eliminate hazardous or environmentally unac-
ceptable materials in new weapon system acquisition pro-
grams.
- Reduce or eliminate hazardous or environmentally unac-
ceptable materials in existing weapon systems management.
• Minimize environmental risks to operating personnel and
visitors at Army civil works facilities.
- Adopt operating procedures for all equipment which re-
duce or eliminate waste.
- Communicate environmental values to visitors at all
project sites.
- Establish and apply rules which meet national environ-
mental, health, and safety standards.
• Instill the pollution prevention ethic throughout the entire
Army community and all mission areas.
- Obtain command support and involvement.
- Integrate environmental health and safety concerns into all
Army operations and activities.
- Develop multidirectional, open communications through
comprehensive public affairs planning.
Agency-Specific Requirements: Although the Strategy strongly en-
courages installations to develop and implement pollution prevention
plans and programs, it does not specifically require them to do so.
DoD directive 4210.15, Hazardous Material Pollution Prevention,
mandates that "a hazardous material shall be selected, used, and man-
aged over its life-cycle so that the DoD incurs the lowest costs re-
quired to protect health and the environment." To implement DoD
4210.15, the Army has incorporated pollution prevention consider-
ations in its environmental regulation, AR 200-1.
1
Pollution Prevention Plan Content: Although the Army has not required installations to prepare pollution prevention
plans, the Army Environmental Policy Institute has prepared a guidance document explaining how to prepare a plan.
264
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Federal Agency Pollution Prevention Programs
U.S. DEPARTMENT OF ENERGY
Mission: To support the Federal government in implementing
the National Energy Plan through coordination and administra-
tion of long term high risk development of energy technologies.
Responsibilities include marketing federal energy power, energy
conservation, nuclear weapons, and central energy data collection
and analysis.
Statement of Commitment: The DOE waste minimization mis-
sion is:
"To develop, promote, and implement cost-effective waste mini-
mization technologies, practices, and policies, in conjunction with
partners in government and industry; to conduct the Department's
operations in a legally and regulatorily compliant and environ-
mentally sound manner through reducing pollution; and to im-
prove the economic competitiveness, energy security, and
environmental quality of the Nation."
Pollution Prevention Goals: In May, 1992, the Secretary of
Energy released the DOE's Waste Minimization Crosscut Plan.
The Plan sets forth a Department-wide planning structure for co-
ordinating all DOE waste minimization activities. Furthermore,
the plan reaffirms the DOE's commitment to expand use of waste
minimization technologies, processes, and methods in DOE op-
erations as well as to the mission of assisting U.S. business and
industry with their waste minimization activities.
The DOE has not established quantitative goals at the time of this
writing. Seven key objectives are outlined in the Waste Minimi-
zation Crosscut Plan. The objectives are:
• Culture Change - Create a DOE culture that fosters the phi-
losophy of conserving resources and minimizing waste.
• Identify Waste Minimization Options - Foster environmental
compliance and reduce waste management costs and envi-
ronmental impacts for DOE operations by identifying, de-
veloping, implementing, and reporting on WMin options.
• Goal Setting - Develop and implement specific WMin goals
for DOE's production, laboratory, and restoration opera-
tions. Each Program Senior Official organization will iden-
Program
Planning
Required?
YES!
"Our course is clear.
It is time for a
fundamental shift in
emphasis in the way
the DOE generates
and manages waste
-- from pollution
control to pollution
prevention."
4 Secretary of Energy,
James. D. Watkins, Waste
Minimization and Pollution
Prevention Policy
Memorandum, August 20,
1992
265
-------
Appendix J
U.S. DEPARTMENT OF ENERGY
"High priority should
be placed on waste
minimization and
pollution prevention
within the DOE.
This is one where a
modest relative
investment now, can
significantly impact
future cost to the
Department for
waste treatment,
storage, and
disposal...all DOE
programs that are
waste generators
should have well-
developed programs
and request
resources consistent
with the desire to
make near term
investments for
long-term savings..."
Secretary O'Leary
FY 95 IRB Guidance
"All DOE Program
Offices and Field
Operations are
required to institute a
waste reduction policy
to reduce the total
amount of waste that
is generated...through
waste minimization."
^ DOE Waste Reduction
Policy Statement
tify such goals and supporting operations within its area of
responsibility.
• Identify and Develop Technologies and Exchange Informa-
tion - Enhance the effectiveness of WMin by developing and
exchanging applicable technologies and information.
• Waste Minimization in Design, Development, and Produc-
tion - Ensure that WMin principles are applied to and in-
cluded in the design, development, and production of all
products.
• Increase Competitiveness of US Industry - Increase competi-
tiveness of US industry through implementation of WMin to
meet National Energy Strategy Goals.
• Positive Credible Image - Establish a positive, credible DOE
public image with respect to WMin matters.
Agency-specific Requirements: The Waste Minimization and
Pollution Prevention Policy Memorandum released August 20,
1992 makes DOE and DOE-contractor managers accountable for
implementing policies, plans, and programs to promote pollution
prevention. Specifically, managers are required to:
• Emphasize WMin practices, wherever possible;
• Separately identify and provide for sufficient resources, both
funding and personnel, to carry out the assessment, develop-
ment, and implementation of programs to meet the
Department's WMin and pollution prevention goals; and
• Ensure that WMin and pollution prevention accomplish-
ments and awareness are incorporated into training and in-
centive programs.
The Waste Minimization and Pollution Prevention Executive Board
established by SEC-37-92 shall implement the DOE Waste Mini-
mization Crosscut Plan and:
• Oversee development of consistent, Department-wide pro-
grams and objectives for WMin and pollution prevention;
266
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Federal Agency Pollution Prevention Programs
U.S. DEPARTMENT OF ENERGY
• Oversee setting of WMin and pollution prevention goals;
• Establish reporting and tracking systems for WMin and pollu-
tion prevention milestones;
• Formulate a strategy for inclusion of WMin and pollution
prevention requirements in Departmental contract and pro-
curement activities;
• Assure Department-wide compliance with applicable Execu-
tive Orders and environmental laws and regulations pertaining
to WMin and pollution prevention; and
• Report annually to the Secretary of Departmental progress in
WMin and pollution prevention.
Other Requirements: A Secretarial Memorandum issued in Sep-
tember, 1992 formalized DOE's participation in the EPA's 33/50
Program and initiated TRI Reporting under Section 313 of the
Emergency Planning and Community Right to Know Act.
DOE 5820.2A Radioactive Waste Management establishes poli-
cies, guidelines and radioactive, mixed waste and contaminated fa-
cilities requirements. It requires Waste Management Plans with
indication of actions to minimize hazardous waste generation and
establishes an Annual Waste Reduction Report.
DOE 5400.1 General Environmental Protection Program estab-
lishes environmental protection program requirements and respon-
sibilities and instituted Process Waste Assessments. This order
requires Waste Minimization Program Plans, an Annual Waste
Reduction/Minimization Report, and a Pollution Prevention Aware-
ness Program.
267
-------
Appendix J
U.S. DEPARTMENT OF ENERGY
DOE 5400.1, General Environmental Protection Program, requires each Head of Field
Organization to prepare a waste minimization program plan. The program plan includes:
• Goals for minimizing the volume and toxicity of all wastes that are generated, with
annual reductions if programmatic requirements allow.
• A summary of waste reduction achieved in comparison to the previous year.
• A description of the proposed treatment, storage, and disposal options that will
accomplish waste minimization that are technically and economically practicable.
The Plan shall be reviewed annually and updated every 3 years.
In addition, Heads of Field Organizations are required to prepare Pollution Prevention
Awareness Programs. All pollution prevention mission statements and project plans shall
include program description including employee awareness training, special awareness cam-
paigns, and incentives and award programs. The plan shall be reviewed annually and
updated every 3 years.
268
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Federal Agency Pollution Prevention Programs
U.S. DEPARTMENT OF INTERIOR - NATIONAL PARK SERVICE
Mission: To conserve the scenery, natural and historic objects and
wildlife of the National Park System to ensure their enjoyment by
future generations.
Statement of Commitment: Signed on December 14, 1992, the
Department of Interior's (DOI) Order No. 3158 establishes a com-
prehensive approach to waste management. The Order commits
the Department to adopting a waste management strategy founded
on prevention and source reduction. The Interim Acquisition Policy
Release issued in March 1992, establishes an affirmative procure-
ment program for all bureaus and offices within DOI.
Pollution Prevention Goals: The (National Park Service) NPS
has not established quantitative goals, instead, each park is respon-
sible for determining goals and measures of program success.
Agency-Specific Requirements: The NPS initiated an Integrated
Solid Waste Alternative Program (ISWAP) in March 1991 (Special
Directive 91-1). Under ISWAP each park must develop an Inte-
grated Solid Waste Alternative Plan to meet its needs. ISWAP's
program elements include source reduction, recycling, and outreach.
Yosemite National Park prepared a Waste Reduction Action Plan
as part of the President's Commission on Environmental Quality,
Solid Waste Task Force. The Plan identifies 32 waste reduction
initiatives which various organizations within the Park have agreed
to implement. The initiatives fall under three broad areas:
• Education - educate the public, frequently used suppliers, and
employees about the benefits of source reduction and recy-
cling to increase recycling rates and identify further source
reduction ideas.
• Procurement - increase purchase and use of recycled content
products (e.g., modifying contract language to promote the
use of recycled content products).
• Oversight - reinforce management commitment to pollution
prevention.
"...if visitation levels
continue to increase
at the current rate,
the amount of solid
waste generated in
Yosemite National
Park will grow to
more than 5,000
tons per year by
early in the next
century"
4 Waste Reduction in
Yosemite National Park: An
Action Plan 1993
269
-------
Appendix J
U.S. DEPARTMENT OF INTERIOR - NATIONAL PARK SERVICE
Alternative Plan: The ISWAP encourages park managers to
custom design their Plans to be consistent with the park's demographic and waste
stream characteristics and federal, state, and local requirements. As such, rather than
specifying the content of the Plan, the ISWAP Manager's Guide explains general source
reduction and recycling principles for park managers to consider. The ISWAP recom-
mends that parks carry out the following activities in developing the Plan (partial list):
• Identify ways to accomplish source reduction and to minimize waste including
reuse of existing materials.
• Survey the solid waste stream and determine which materials are recyclable.
• Identify markets for recyclables.
• Compost leaves, grass clippings, and saw dust where possible.
• Establish recycling programs in employee housing areas and park campgrounds/
picnic areas.
• Use and promote the use of recycled products.
• Share successes through the Maintenance Newsletter.
270
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Federal Agency Pollution Prevention Programs
U.S. DEPARTMENT OF JUSTICE - FEDERAL BUREAU OF PRISONS
Mission: To protect society by confining offenders in the con-
trolled environments of prisons and community based facilities.
Statement of Commitment: The Department of Justice (DOJ)
has not finalized its Pollution Prevention Policy; however, the
Federal Bureau of Prisons Operations Memorandum No. 034-92
(1640), dated February 2, 1992, establishes a comprehensive en-
vironmental awareness/pollution prevention strategy focused pri-
marily on source reduction, recycling, and an affirmative
procurement program. The Memorandum was issued in response
to Executive Order 12780, Federal Recycling and the Council on
Federal Recycling and Procurement Policy.
Pollution Prevention Goal:
tablished quantitative goals.
The Bureau of Prisons has not es-
Agency-specific Requirements: The Bureau of Prisons requires
all facilities, departments, and offices to establish comprehensive
Environmental Awareness/Pollution Prevention programs to in-
stitute source reduction techniques and sound recycling practices.
In addition, each facility and administrative office must develop a
cost effective Affirmative Procurement Program.
The Environmental Awareness/Pollution Prevention program
should include four elements:
• During procurement procedures, efforts will be made to
purchase items which promote recycling and/or source re-
duction.
• Examine areas where conservation initiatives can be imple-
mented and waste reduction measures employed.
• Initiate a viable cost effective recycling program incorporat-
ing specific core recycling items.
• Establish an institution environmental committee as de-
scribed to address the environmental concerns and recycling
activities.
"...these initiatives
are intended to
promote the
sustainable use of
our nation's
resources, protect
human health and
preserve the
environment."
4 Operations Memorandum
No. 034-92
271
-------
Appendix J
NATIONAL AERONAUTICS AND SPACE ADMINISTRATION
Achievements
• Pollution
Prevention
Program Plan
• Towpreg Study
• Material
Tracking System
Mission: To increase the knowledge and capability of the United
States in a full range of aeronautics disciplines and in selected
space disciplines.
Statement of Commitment: Although NASA has not developed
an agency-wide pollution prevention policy, several facilities have
undertaken pollution prevention projects. The NASA-Langley
Research Center (LaRC) in Hampton, Virginia is a participant in
the Tidewater Interagency Pollution Prevention Program (TIPPP).
LaRC has prepared a pollution prevention program plan and is
expanding its program.
Pollution Prevention Goal: LaRC has not established quantita-
tive goals.
Agency-specific Activities: The LaRC pollution prevention pro-
gram plan:
• Illustrated how to develop a pollution prevention program
plan so that the program can be updated periodically to iden-
tify new opportunities and assess the performance of exist-
ing pollution prevention techniques
• Developed a baseline of LaRC's most significant chemical
uses, activities, waste streams and environmental issues
• Established criteria for ranking pollution prevention oppor-
tunities
• Identified more than 50 pollution prevention opportunities,
ranging from a chemical materials management system to
cardboard recycling
• Developed an implementation plan for the Center
• Created a Recycling Program and an Affirmative Procure-
ment Program for the Center.
Projects: Projects underway include developing a material track-
ing system to allow the center to track materials from delivery
through waste removal; follow-up research in devising less haz-
ardous ways to impregnate carbon fibers with dry powder resin
by using powdered polymers to coat fibers in composite materials
for use in subsonic and supersonic aircraft applications (Towpreg
Study).
272
-------
Federal Agency Pollution Prevention Programs
U.S. POSTAL SERVICE
Mission: To provide prompt, reliable, and efficient postal ser-
vices to all communities.
Statement of Commitment: The Postal Service is committed to a
nationwide pollution prevention program designed to improve en-
vironmental quality and set a positive example for residents and
private businesses in every community we serve. Waste reduc-
tion, a major component of that program, involves implementing
practices that will reduce or eliminate hazardous and nonhazardous
wastes before these wastes are generated. Reducing waste requires
managers to reexamine how they order products and how they use
those products and component materials.
Pollution Prevention Goal: The Postal Service has an overall
goal to reduce waste 25% from 1992 levels by December 1993,
and an additional 25% by December 1995.
Agency-specific Requirements: In accordance with Executive
Order 12780 of October 31, 1991, Federal Agency Recycling and
the Council on Federal Recycling and Procurement Policy, Sec-
tion 6002 of RCRA, and the Pollution Prevention Act of 1990, the
USPS requires all administrative and operational activities to de-
velop waste reduction plans and recycling programs.
Program
Planning
Required?
YES!
"By implementing a
strong waste
reduction program,
the Postal Service
can reduce costs,
paperwork, liability,
and pollution, as
well as create a
cleaner, safer, and
more efficient work
environment."
4 USPS Waste Reduction
Guide 1992
Waste Reduction Plans: Waste reduction plans should include the following elements:
• Wastestream assessment
• Opportunities and priorities
• Identification of waste reduction approaches
• Feasibility analyses
• Facility-specific annual goals
• An annual review of achievements resulting from program tracking and measure-
ment
Recycling Program Development: Each facility should:
• Build a recycling team
• Conduct a waste stream assessment
• Select the best recycling methods
Understand principles of collection, storage, and transfer
273
-------
Appendix J
DEPARTMENT OF TRANSPORTATION - U.S. COAST GUARD
Program
Planning
Required?
NO!
"The key to the
success of this
program is thorough
integration and
effective
implementation of
pollution prevention
practices Coast
Guard-wide."
f USCG Memorandum 11019
Mission: To patrol the waters of the United States and conduct
activities related to the enforcement of maritime law, public safety,
waterway management, and ports safety.
Statement of Commitment: Coast Guard is in the process of fi-
nalizing a Pollution Prevention Policy statement. A Memorandum
issued September 21, 1992 establishes a Pollution Prevention Steer-
ing Committee and gives the Committee a Charter to develop a
comprehensive pollution prevention program.
Pollution Prevention Goal: The Coast Guard has not set quantita-
tive goals.
Agency-specific Requirements: The Charter gives the Committee
the responsibility for developing a comprehensive pollution pre-
vention program for the Coast Guard. The Committee has four
working groups. A summary of the working groups and their mis-
sions follows.
Hazardous Material Management and Control - minimize use of
hazardous material in Coast Guard procurement, operations, and
maintenance evolutions; control required hazardous material use
throughout the life cycle to protect personnel and eliminate releases
to the environment.
Actions include: reviewing hazardous material inventory and iden-
tifying substitutes.
Solid Waste Management Working Group - minimize solid waste
disposal in the Coast Guard through source reduction and recy-
cling; ensure procurement of recycled materials where practical;
oversee transfer of recycling funds to Coast Guard Morale, Recre-
ation, and Welfare Activities.
Actions include: developing actions based on Executive Order 12780
and DLA/Navy policy.
Hazardous Waste Management - where hazardous material must be
used, find ways to recover, recycle, treat, or destroy hazardous
material to minimize hazardous waste disposal; determine and track
progress of hazardous waste generation; ensure proper manage-
ment.
274
-------
Federal Agency Pollution Prevention Programs
DEPARTMENT OF TRANSPORTATION - U.S. COAST GUARD
Actions include: draft procedures to inventory existing hazardous
waste generation and establish a baseline; develop a HAZMIN
awareness videotape for work force; identify training needs
Air Pollution Minimization - minimize releases of airborne pollut-
ants throughout the Coast Guard and ensure compliance with
amended Clean Air Act.
Actions include: develop procedure to comply with CFC/Halon
ban.
275
-------
-------
APPENDIX K
POLLUTION PREVENTION
INFORMATION CLEARINGHOUSE
277
-------
Appendix K
POLLUTION PREVENTION
INFORMATION CLEARINGHOUSE
CALL FOR INFORMATION
Federal Facilities Pollution Prevention Programs and Projects
The Pollution Prevention Information Clearinghouse (PPIC) is establishing a Federal Facilities Mini-
Exchange database on its Pollution Prevention Information Exchange System (PIES). The U.S. Environ-
mental Protection Agency (EPA) is collecting information concerning and Federal facilities pollution
prevention/recycling efforts. EPA is requesting a variety of information from Federal facilities environ-
mental managers on their pollution prevention/waste minimization programs and projects. EPA is solic-
iting Federal facilities to provide the following types of information:
Policy Statements - current Agency and facility
pollution prevention goals, objectives, and policy
statements.
Program Descriptions - formal and informal facil-
ity and Agency pollution prevention programs
that encourage or enhance the implementation of
waste minimization opportunities.
Manuals and Guidance Documents - facility or
Agency pollution prevention reports, articles, di-
rectives, guidance documents, and document or-
dering information.
PPIC is as clearinghouse dedicated to reduc-
ing industrial pollutants through technology
transfer, education, and public awareness.
PPIC helps you to establish a pollution pre-
vention program, identify process options,
locate and order documents, and save money
by reducing your waste and liability.
PIES is an easy-to-use, interactive PC-based
system designed to provide instant access to
database information. With PIES, you can
access technical and programmatic informa-
tion, order documents, locate expert assis-
tance, and solve technical and policy questions
all at your PC.
Conferences, Seminars, and Training Courses -
any upcoming pollution prevention conferences,
seminars, workshops, or training courses that are
scheduled or conducted by your facility or - -
Agency. Calendar submittals should provide date, location, description, and contact.
Case Studies - case studies on successful pollution prevention projects as well as information gath-
efed from waste minimization assessments, procurement activities, audits, process changes Na-
tbnairviroiimen^ Policy Act (NEPA) reviews, and other "lessons learned." Contact the PPIC
for a copy of the case study format.
Thi, information will be collected,
, and shared by Federal facilities and Industries that are
or accessing the Clearinghouse, call PPIC Technical Assistance at (703) 821-4800.
278
-------
APPENDIX L
POLLUTION PREVENTION
REFERENCES
279
-------
Appendix L
General Pollution Prevention Guide
EPA has published a general pollution prevention guide. The Facility Pollution Prevention
Guide (EPA/600/R-92/088) describes how to develop a facility-wide pollution prevention program.
This manual is available through the Pollution Prevention Branch of EPA's Risk Reduction
Engineering Laboratory, Cincinnati, Ohio, 45268.
Industry-Specific Pollution Prevention Guidance
The Pollution Prevention Research Branch of EPA's Office of Research and Development is
publishing a series of industry-specific pollution prevention guidance manuals. These guides list
source reduction and recycling techniques for specific industries. The first 13 manuals in the
series have been published for the industrial categories designated in the titles provided below.
Four more manuals are still forthcoming. Industrial categories that will be addressed and the
publication schedule are listed below.
Guides to Pollution Prevention:
Guides to Pollution Prevention:
Guides to Pollution Prevention:
Guides to Pollution Prevention:
Guides to Pollution Prevention:
Guides to Pollution Prevention:
Guides to Pollution Prevention:
Guides to Pollution Prevention:
Guides to Pollution Prevention:
Guides to Pollution Prevention:
Guides to Pollution Prevention:
Guides to Pollution Prevention:
Guides to Pollution Prevention:
Guides to Pollution Prevention:
Guides to Pollution Prevention:
Automotive Refinishing Industry
Auto Repair Industry
The Commercial Printing Industry
The Fabricated Metal Industry
Fiberglass Reinforced and Composite Plastics
Marine Maintenance and Repair
The Paint Manufacturing Industry
The Pesticide Formulating Industry
Pharmaceutical Preparation
Photoprocessing Industry
The Printed Circuit Board Manufacturing Industry
Research and Educational Institutions
Selected Hospital Waste Streams
Mechanical Equipment Repair
Metal Finishing
EPA/625/7-91/016
EPA/625/7-19/013
EPA/625/7-90/008
EPA/625/7-90/006
EPA/625/7-91/014
EPA/625/7-91/015
EPA/625/7-90/005
EPA/625/7-90/004
EPA/625/7-91/017
EPA/625/7-91/012
EPA/625/7-90/00
EPA/625/7-90/010
EPA/625/7-90/009
EPA/625/R-92/008
EPA/625/R-92/011
Fact Sheets
The fact sheets listed in Exhibit M-l contain overviews, tips, and/or guidelines for pollution
prevention. Some provide only general information or advice on how to set up programs, while
others identify pollution prevention opportunities for specific industries, process, or materials.
EPA State agencies,, and local governments produced the fact sheets. In many cases, multiple
sources have published fact sheets on particular topic. Fact sheets on the topic areas below are
available from the EPA Library, 401 M Street, SW, Washington, DC 20460 (202-260-1963).
280
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Pollution Prevention References
Exhibit M-l. Fact Sheets
General/Introductory Information
Conservation Tips for Business
General Guidelines
Getting More Use Out of What We Have
Glossary of Waste Reduction Terms
Guides to Pollution Prevention
Hazardous Waste Fact Sheet for Minnesota
Generators
Hazardous Waste Minimization
How Business Organizations Can Help
Increase Your Corporate and Product Image
Industrial Hazardous Wastes in Minnesota
Local Governments and Pollution Prevention
Pollution Prevention (General)
Pollution Prevention Fees
Pollution Prevention Training and Education
Pollution Prevention Through Waste Reduction
Recent Publications
Reduce Hazardous Waste
Reuse Strategies for Local Government
Source Reduction Techniques for Local
Government
U.S. EPA's Pollution Prevention Program
Video Tapes Available from the Virginia Waste
Minimization Program
Waste Exchange: Everybody Wins!
Waste Exchange Services
Waste Minimization Fact Sheet
Waste Minimization in the Workplace
Waste Reduction Can Work For You
Waste Reduction Overview
Waste Reduction/Pollution Prevention: Getting
Started
Waste Reduction Tips for All Businesses
Waste Source Reduction
Waste Source Reduction Checklist
What is Pollution Prevention
Why Reduce Waste?
Legislative Information/EPA and State Initiatives
About Minnesota's "But Recycled Campaign" •
Alaska State Agency Waste Reduction and
Recycling •
EPA's 2% Set Aside Pollution Prevention Projects •
EPA's "List of Lists" Projects •
EPA's Pollution Prevention Enforcement •
Settlement Policy
EPA's Pollution Prevention Incentives for States 9
EPA's Pollution Prevention Strategy
Introducing the Colorado Pollution Prevention
Program
Michigan's Solid Waste Reduction Strategy
Minnesota's Toxic Pollution Prevention Act
New Form R Reporting Requirements
Oregon's Toxic Use Reduction Act
Pollution Prevention Act of 1990
Promoting Pollution Prevention in Minnesota State
Government
281
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Pollution Prevention References
Exhibit M-l. Fact Sheets (continued)
Process/Material Specific (continued)
Office Paper Waste Reduction
Plastics:
- The Facts About Production, Use and Disposal
- The Facts on Degradable Plastics
- The Facts on Recycling Plastics
- The Facts on Source Reduction
Printing Equipment
Refrigerant Reclamation Equipment/ Services
Reverse Osmosis
Safety Kleen, Inc. Users
Shop Rags from Printers
Small silver Recover/ Units
Solvents:
- Alternatives to CFC-113 Used in the Cleaning
of Electronic Circuit Boards
- Onsite Solvent Reclamation
- Reducing Shingle Waste at a Manufacturing
Facility
- Reducing solvent Emissions from Vapor
Degreasers
- Small Solvent Recovery Systems
- Solvent Loss Control
- Solvent Management: Fiber Production Plant
- Solvent Reuse: Technical Institute
- Trichloroethylene and Stoddard Solvent
Reduction Alternatives
- Solvent Recovery: Fiber Production Plant
- Solvent Reduction in Metal Parts Cleaning
Ultrafiltration
Used Containers: Management
Used Oil Recycling
Waste Management Guidance for Oil Cleanup
Water and Chemical Reduction for Cooling Tower:
Waste Water Treatment Opportunities
Industry Specific
Aerospace Industry
Auto Body Shops
Automotive Painting
Automotive/Vehicle Repair Shops
Auto Salvage Yards
Asbestos Handling, Transport and Disposal
Chemical Production
Coal Mining
Concrete Panel Manufacturers
Dairy Industry:
- Cut Waste and Reduce Surcharges for You
Dairy Plant
- Dairy CEO's: Do You Have a $500 Million
Opportunity?
- Liquid Assets for Your Dairy Plant
- Water and Wastewater Management in a Dairy
Processing Plant
Dry Cleaners
Electrical Power Generators
Electroplating Industry:
- Dragout Management for Electroplater
- Plating with Trivalent Chrome Instead of Cr+6
- Water Conservation Using Counter Current
Rinsing
283
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Appendix L
Exhibit M-l. Fact Sheets (continued)
Setting Up A Program
1991 Small Business Pollution Prevention Grants
An Organization Strategy for Pollution Prevention
Considerations in Selecting a Still for Onsite
Recycling
Colorado Technical Information Center
Onsite Assistance (Colorado only)
Pollution Prevention Grant Program Summaries
and Reports
Procuring Recycled Products
Recycling Market Development Program
Selecting a Supplier, Hauler and Materials Broker
Solid Waste Management Fimincial Assistance
Program
Source Reduction at Your Facility
Starting Your Own Waste Reduction Program
The Alexander Motor's Success Story
The Eastside Plating Success Story
The Wacker Payoff
Waste Reduction Checklists:
- General
- Cleaning
- Coating/Painting
- Formulating
- Machining
- Operating Procedures
- Plating/Metal Finishing
Waste Source Reduction: Implementing a Program
Process/Material Specific
Aerosol Containers
Aircraft Rinsewater Disposal
Acids/Bases
Chemigation Practices to Prevent Ground Water
Contamination
Corrugated Cardboard Waste Reduction
Demolition
Empty Containers
Gunwasher Maintenance
Lead Acid Batteries
Machine Coolants:
- Prolonging Coolant Life
- Waste Reduction
Metal Recovery:
- Dragout Reduction
- Ion Exchange/Electrolytic Recovery
- Etchant Substitution
Old Paints, Inks, Residuals and Related Materials
Pesticides:
- Disposal of Unused Pesticides, Tank Mixes and
Rinsewater
- In-Filled Sprayer Rinse System to Reduce
Pesticide Wastes
- Pesticide Container Disposal
- Preventing Pesticide Pollution of Surface and
Ground Water
- Preventing Well Contamination by Pesticides
- Protecting Mountain Springs from Pesticide
Contamination
- Reducing and Saving Money Using Integrated
Pest Management
Metals Recycling
282
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Appendix L
Exhibit M-l. Fact Sheets (continued)
Industry Specific (continued)
- Water Conservation: Tank Design
- Water Conservation: Rinsewater Reuse
- What Should I Do With My Electroplating
Sludge?
Fabricated Metal Manufacturers
Fiberglass Fabricators: Volatile Emissions
Reduction
Machine Toolers
Metal Finishers:
- General
- Effluent Minimization
- Rinsewater Reduction
Oil Refiners
Paint Formulators
Paper Manufacturers
Pesticide Formulating Industry
Photofinishers/Photographic Processors
Poultry Industry:
- Poultry CEO's: You May Have a $60 Million
Opportunity?
- Poultry Processor: You Can Reduce Waste Load
and Cut Sewer Surcharges
- Survey Shows That Poultry Processors Can Save
Money By Conserving Water
- Systems for Recycling Water in Poultry
Processing
Printed Circuit board Manufacturers
Printing Industry
Radiator Service Firms
Shrimp Processors
Steel Manufacturers
Textile Industry:
- Dye Bath and Bleach Bath Reconstitution
- Water Conservation
Wire Milling Operations: Process Water Reduction
Source: U.S. EPA, Office of Pollution Prevention and Toxics and Office of Environmental Engineering and Technology
Demonstration, EPA/5650/8-92-002, January 1992, Pollution Prevention Resources and Training Opportunities in 1992.
Energy Conservation and Efficiency
• The NIRS Energy Audit Manual: How to Audit Campus, City and Other Buildings. 1992.
$24.95.
Andrea Carlson
Nuclear Information Resource Service
Introduction - Harvey Wasserman
1424 16th Street W, Suite 601
Washington, B.C. 20036
(202) 328-0002
284
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Pollution Prevention References
This manual describes, in detail, how to do a full-scale energy audit. It includes dozens of
worksheets with calculations to figure out potential energy and cost savings. The manual walks
the potential auditor through the initial site visit and then provides recommendations for installing
money-saving efficiency measures.
• Forty Ways to Make Government Purchasing Green. 1992, $10.00.
Eleanor J. Lewis and Eric Weltman
Center for Study of Responsive Law
Introduction - Ralph Nader
P.O. Box 19367
Washington, D.C. 20036
This book proposes 40 green initiatives, of which 16 deal with energy efficiency, that could
potentially be implemented by government agencies. Each of the individual initiatives is followed
by a list of strategies and examples which government agencies initiated, along with contact
names, addresses and phone numbers, and a list of additional resources.
• Energy Ideas $25.00 a year.
Center for Study of Responsive Law
A monthly newsletter discussing how government can be an environmentally responsible consumer
using energy-efficient and renewable energy technologies. Each issue examines a different
technology. It describes successful projects in federal, state and local agencies nationwide, and
provides contact persons, financing options, information sources and other resources.
U.S. GOVERNMENT PRINTING OFFICE: 1994 — 523-888 /
285
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