. . '- ' EPA/30 5/S-9 7/0 0/6
ENVIRONMENTAL LEADERSHIP PROGRAM
SUMMARY OF THE 19Q5-Q6 PILOTS
Introduction
Fifteen facilities representing twelve
companies or organizations participated in
the year-long pilot phase of EPA's
Environmental Leadership Program (ELP).
Located in 11 states, the facilities selected to
participate represent a variety of industry
groups, including utilities, chemical
manufacturing, electronics, waste
management, printing, and pulp and paper.
In addition, two federal facilities were
selected to participate in the pilot. The
specific facilities included:
Arizona Public Service (APS), Deer
Valley Facility (Arizona)
. Salt River Project (SRP) (Arizona)
Duke Power River Bend Steam Station
(North Carolina)
Ocean State Power (OSP) (Rhode
Island) .
Ciba-Geigy St. Gabriel Facility
(Louisiana)
Motorola Oak Hill facility (Texas)
WMK Technologies, Inc. (2 facilities in
Oregon)
The Gillette Company (South Boston,
MA; North Chicago, IL; and Santa
Monica, CA manufacturing facilities)
The John Roberts Company (Minnesota)
Simpson Tacotna Kraft Company
(Washington)
McClellan Air Force Base (California)
Puget Sound Naval. Shipyard
(Washington). *
All of the facilities selected for the pilot
showcased at least one or more of the
characteristics EPA considered indicative of
environmental leadership. Those"
characteristics included implementation of:
1) environmental management systems
(EMSs), 2) environmental auditing, 3)
community outreach and employee
involvement programs (including public
accountability), 4) mentoring, and 5)
pollution prevention.,
ENVIRONMENTAL MANAGEMENT
SYSTEMS (EMS)
Nine of the ELP pilot participants
demonstrated their EMSs (APS, Ciba-Geigy,
Duke, Gillette, John Roberts, McClellan,
Motorola, OSP, and WMX). Specifically,
McClellan and Motorola compared their
EMSs to the emerging ISO 14001 EMS
standards; APS demonstrated an EMS
assessment tool at three of its Arizona
facilities (each of a different size). APS then
implemented changes identified through the
assessment process. .
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WMX focused on the compliance
management aspects of its EMS.
Specifically, it demonstrated its compliance
management process, including two
databases the Compliance Management
System (CMS) and the Corrective Action
Reporting System (CARS) - that help it
track compliance and corrective action. The
compliance management process
implemented by WMX included several
steps: 1) identifying new regulatory
requirements to which their facilities would
be subject, 2) using a technique called "Info-
Mapping" to convert regulatory
requirements into distinct tasks for facility
personnel, and 3) tracking compliance and
corrective action using the two databases.
Also during the pilot, the CMS was the
subject of a quality assurance check. The
check was conducted at both WMX pilot
facilities by EPA and state team members,
as well as by WMX facility and corporate
staff. CMS tasks were reviewed against
source documents (e.g., regulations, rules,
permit requirements, and corporate policy)
for accuracy and completeness.
Several of the EMSs demonstrated during
the pilot, including those at APS, Gillette,
Motorola, and'WMX, were developed at the
corporate level and then specifically
implemented at the facility level. Others,
including John Roberts, McClellan, and
OSP, developed and implemented their own
facility-specific EMSs. In yet another case,
Ciba-Geigy based its EMS on the
requirements of the Chemical Manufacturers
Association's Responsible Care Program.
The John Rpberts' EMS demonstrated that
an EMS can be sized for a small- to mid-
sized facility. The EMSs demonstrated
during the pilots generally were found to be
effective in identifying the significant
environmental impacts of the facilities'
operations and preventing, detecting, and
correcting compliance issues on an on-going
basis.
EMS-associated products resulting from the
pilots include:
+ Ocean State Power: Development of an
EMS, this manual discusses factors to
consider when developing an EMS and,
once implemented, how to sustain an
EMS
+ Rewrote in "plain English" an Oregon
solid waste regulation (Division 95) and
selected sections of the Guidance for
Oregon Permitting Rules using the
InfoMap technique
+ Modified version of CARS for use by
the Oregon Department of
Environmental Quality in tracking its
inspection and enforcement activities.
Auditing
Twenty-one EMS, compliance, or combined
EMS/ compliance audits were conducted
during the pilot phase of the ELP. For the
most part, all of the audits yielded positive
results. These audits were led by a variety
of individuals, including facility staff,
corporate auditors, auditors from another
ELP pilot facility as part of an auditor
exchange program, or external
environmental auditors. The six external
environmental audits were conducted at
John Roberts (by the Printing Industry of
Minnesota), at Ciba-Geigy, Gillette, and
SRP by EPA's National Enforcement
Investigation Center (NEIC), and also at the
Gillette facilities by ERM, an environmental
auditing firm. EPA and state staff
participated in all of the audits.
As a result of these audits, an approximate
total of 31 compliance issues were identified
at the 15 participating facilities. Examples
of the compliance issues identified include:
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» Incomplete list of materials used
Missed weekly self-inspections
Late submittal of reports to local ,
agencies
Missing drum labels
Equipment leaks. -'
It should be noted that all compliance issues
through the audits were corrected within the
90-day correction period provided through
the ELP pilot agreements.
In addition to the compliance issues
identified, there were also positive findings
regarding facility EMSs. Examples of those
include:
Well-defined operational control
procedures . .
Excellent internal communication
. processes " . ',
Ability to identify and correct
deficiencies, including the need for-
additional benchmarking and better
assessment of the facility' s training
needs.
Although the pilot leadership agreements
indicated EPA's and the states' intent not to
conduct discretionary inspections, some of
the facilities offered, or agreed, to be
inspected as a further demonstration of their
leadership status. During the pilot phase of
the program, the Texas Natural Resource
Conservation Commission (TNRCC)
conducted multimedia compliance
inspections at both the Ciba-Geigy and
Motorola facilities. Both facilities were ,
found to be in compliance with all ,
environmental requirements:
Audit-related products resulting from the
pilots included:
> Compliance and EMS Auditing
Guidances (produced by the Gillette
team)
f Model for Self-Certification of
Environmental Compliance (SRP)
+ An Audit-Sharing Matrix (Simpson),
which identified audit findings and
shared information with the community.;
Community Outreach,
Employee Involvement, and
Public Accountability
Every pilot facility demonstrated some
aspect of this element of the ELP. However,
the most.extensive examination occurred on
those programs implemented by Ciba-
Geigy, McClellan, Motorola, and Simpson.
Ciba Geigy developed an extensive
community and employee outreach program.
" For the past 8 years, it has conducted' a
survey of the residents of East Iberville
Parish asking general and specific questions
on local problems, pollution, employment,
emergency response, education, and public
perception of the facility. It has also
developed a series of community outreach
programs, including a citizens advisory
panel, community newsletter, odor response
program, summer teachers program, and
employment opportunities for local
residents. Ciba also has the Ciba
.Ambassadors Program, which addresses
employees' environmental concerns and
trains and encourages employees to act as
ambassadors to the public. Specifically, the
program encourages employees to be active
in the community, and share information on
. the environmental aspects of the facility,
including pollution prevention and waste
management activities.
McClellan's initiatives included college
intern partnerships, pollution prevention
grant projects with community colleges, and
sponsorship of teacher training in
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environmental studies. Motorola also
worked with local schools, although at
another level. It provided all 4th graders in
the area with "Discovery Packs," which
contained pollution prevention information
and hands-on experiments. Motorola also
conducted ELP-related presentations,
presented its "Protecting Our Environment"
course for members of the "Leadership
Austin" class, and worked with the TNRCC
to develop a small business assistance
conference.
Simpson continued to work with its
community advisory group throughout the
ELP pilot. The group provides feedback to
Simpson regarding environmental activities.
The purpose of the group is to keep
community members informed, as well as to
establish and expand relationships with the
local community.
During the pilot phase of the ELP, four
public forums were held -- one each in
Baton Rouge, Louisiana; Phoenix, Arizona;
Austin, Texas; and Washington, DC. The
first forum, in Baton Rouge, was held in
February 1996 and was sponsored by Ciba-
Geigy, EPA, and the State of Louisiana. It
was attended by approximately 60 people
representing the local community, local and
regional environmental groups, academia,
and industry groups. The last forum was
held in November 1996 hi Washington, D.C.
It was designed as a national stakeholders
conference and was attended by 160 people.
Mentoring
Five of the pilot facilities conducted the
majority of mentoring activities associated
with the pilot John Roberts, Motorola,
Ocean State Power, SRP, and Simpson.
Mentors not only provided guidance on
basic technical and environmental practices,
but also shared their knowledge and
expertise in environmental management and
pollution prevention with companies who,
. have more limited resources.
Through the five specific mentoring
projects, hands-on assistance was provided
to 10 facilities. The environmental manager
at John Roberts provided hands-on
assistance to four smaller printers in the
Minneapolis, Minnesota, area. Simpson
assisted its mentoree, a local supplier, with
the development of a spill response plan.
The plan was modeled after'one already
implemented at the Simpson facility.
Simpson also developed a format for the
mentoree's oil/water separator inspection
maintenance records. Motorola also
provided assistance to a firm in its
supplier/distributor chain. The company
provided equipment maintenance services to
Motorola.
The focus of OSP's mentoring project was
to provide a network of experts on various
topics to its mentoree. The mentoree had
specific issues and was seeking assistance
on those issues. OSP attempted to match the
needs of the mentoree to its network of
experts.
At no cost to the attendees, SRP sponsored
three, 4-hour environmental awareness ,
workshops. More than 60 companies
attended. Three companies requested
follow-up site visits for hands-on assistance.
t SRP learned that one facility modified and
i upgraded its compliance procedures as a
result of the workshop and site visit.
i Due to the benefits that resulted from the
pilots' mentoring activities, EPA decided the
full-scale ELP should include an expectation
! that facilities mentor or make a good faith
effort to mentor during their participation in
, ELP.
f ' ,: ;;,: "
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Pollution Prevention
This aspect of environmental leadership was
not assessed to the same degree as some of
the other aspects in the pilot phase. This is
. due to the wealth of information available on
the benefits of and opportunities for"
pollution prevention that have been garnered
from a variety of other pilots and case
studies. There were, however, several .
pollution prevention activities undertaken or
demonstrated during the pilots. For
example, Ciba-Geigy conducted a pollution
prevention assessment at its facility. Other
pilot facilities shared previously identified
pollution prevention opportunities and the
resulting steps to reduce or eliminate
pollution at the source.
McClellan Air Force Base demonstrated its
Pollution Prevention Program, which is
implementing moire than 10.0 projects to
reduce or eliminate hazardous materials. In
addition, it has the largest operating
alternative vehicle fleet in the world with 60
electric vehicles. These vehicles log more
than 5,000 miles monthly and reduce an ;
estimated 2 tons of pollution annually.
OSP eliminated oil waste by. capturing the
oil for reuse. The plant performs test oil
firing on the turbines for. 15 minutes each
week. If ignition does not occur within the
programmed time, the unit automatically
shuts down and the oil has to be purged
from the system to allow for a clean retiring.
In the past, the plant disposed of this oil as
waste. -
Puget Sound Naval Shipyard is the only
U.S. Navy shipyard that "recycles" entire
ships. During the ELP pilot, PSNS worked
to identify laws and regulations that may be
contradictory or impede pollution
prevention, used stakeholder teams to
provide green solutions to such problems,
and was developing procedures and metrics
to demonstrate the suitability of these
proposed solutions.
Additional
Information
Detailed final reports on each of the twelve
' pilots are available on the Internet at
http://es.inel.gov/elp or from the Pollution
Prevention Information Clearinghouse,
Environmental Protection Agency, 401 M
Street, S.W., Washington, D.C. 20460,
phone (202)260-1023.
For further information, contact:
Tai-ming Chang, Director
Environmental Leadership Program
U.S. EPA, OECA/Office of Compliance
401 M Street, S.W. (2223A)
Washington, D.C. 20460, ,
tel. 202-564-5081, fax 202-564-0050
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