.              . •   '-   '             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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