Warner RobiNs AiR Force Base


OppoRTUNiTiES Assessment WoRkshop


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SpoNsoREd by:

Warner RobiNs AiR Force Base
AiR Force Center (or EnvIronmentaI ExceIIence




Warner-Robins Air Force Base
September 28-30, 1992

Lt.Col. Laven Alsten
Scott AFB, ll

Capt. Rich Anaya
Wright-Patterson AFB, OH

Linda Anderson-Camahan
EPA Region IV

Adam Antwine
HQ USAF/LGMM, Pentagon

Denice Austell
Robins AFB, GA

Linda Barnwell
Robins AFB, GA

Lt. James Beam
Charleston AFB, SC

Lt. Perry Beaver
Robins AFB, GA

Carole Bell
SAIC, Newport, Rl

Curtis Bowling
Boiling AFB, DC

Paula Brewer
Arnold AFB, TN

Lt. Warren Brown
Arnold AFB, TN

Capt. Dave Bury
Robins AFB, GA

Steve Cameron
Tinker AFB, OK

loseph Candella

Nat. Guard, Niagar Falls, NY

Mara Cherkasky
SAIC, Newport Rl

Sam Clinton
Keesler AFB, MS

Dale E. Cook
Charleston AFB, SC

Melvin Cruver

Lasunda Davis
Hurlburt Field, FL

CMS Dehtre
Robins AFB, GA

Capt. Gwendolyn Dargara
Scott AFB, IL

Capt. Alan Dooley
Robins AFB, GA

Carroll Duggan
TVA, Chattanooga, TN

Dave Ellicks
Robins AFB, GA

Bobby Ficquette
Air Force Region IV

Carol Foley
Ga Tech, Atlanta, GA

Angie Fugo
EPA Region IV

Bill Fuller
Robins AFB, GA

Margaret Harris

Jim Hayes

Susan Hendricks

Don Hise
Robins AFB, GA

TSgL Charles Holland
Robins AFB, GA

David Holroyd
EPA/Fed Fac

Marion Hopkins
EPA/Fed Fac

Capt. Eric Hopwood
Brooks AFB, TX

Hal Huddleston
Dobbins AFB, GA

Greg Hulet
EG&G Idaho

Tommy Kenerly
Robins AFB, GA

Randy King
Robins AFB, GA

Mike Klug
Robins AFB, GA

1 Lt. Sadine Langhill
Kunsan AFB, Korea

Linda Larson
Robins AFB, GA

Barry M. Larson
Robins AFB, GA

Art Linton
EPA/Fed Fac

Grant Lynch
Dobbins AFB, GA

Capt. Nathan Marias

Lt. Matt Mangan
Robins AFP, GA

Kim Martin
SAIC, Newport, Rl

Joe Martine
Tinker AFB, OK

Wayne Mathis
EPA/Fed Fac

David Melgaard
EPA/Fed Fac

Capt. Miller
Osan AFB, Korea

Becky Mitchell
Robins AFB, GA

Elaine Morrison
So. Div. Nav. Fac.

Capt. William B. Owens
Eglin AFB, FL

Debra Peterman
Wright-Patterson AFB, OH

Claire Plugeman
Eglin AFB, FL

Paul Powell
Kadena AFB, Korea

Capt. Tom Radamacher
Edwards AFB, CA

Capt. Marc Richard

Mark Robertson
EPA/Fed Fac

TSgt Benjamin Robinson
Nellis AFB, NV

Tom Russell

Richard Satterfie/d

Karrie Jo Shell
EPA Region IV

Max Shifflet
Youngstown AFRS, OH

Lt. Teresa Smith
Grisson AFB, IN

Debra Snoha
Randolph AFB, TX

MSgt. Frederick Sparks
Pope AFB, NC

Bill Stewart

SMSgt. Randall Straw
Scott AFB, IL

Parrish Swearingten
Robins AFB, GA

Capt. Gwen Vercara
Scott AFB, IL

Debra Warneking
Edwards AFB, CA

Matt Waters
NAS, Jacksonville, FL

Rupert Webb
Robins AFB, GA

Mike Willard
Patrick AFB, FL

Michael Wojcinski
CEEV, Niagara Falls, NY


United States Air Force

ROBINS AIR FORCE BASE, GEORGIA	Telephone 912-926-2137


Major General William P. Hallin is
commander of the Warner Robins Air Logistics
Center at Robins Air Force Base, Ga. The
center is one of the U.S. Air Force's five
air logistics centers and is Georgia's
largest industrial complex. The ceneral is
responsible for worldwide logistics support
of most transport aircraft, F-15 air
superiority	fighters,	helicopters,

air-to-air missiles, surface motor vehicles
and high-technology airborne electronics.

General Hallin was born Dec. 8, 1941,
in New Britain, Conn., where he graduated
from high school in 1959. He earned a
bachelor of arts degree in economics from
Trinity College in 1963 and a master's
degree in logistics management, with
distinction, from the Air Force Institute

The general completed Air Command and Staff College in 1974,
Industrial College of the Armed Forces in 1979 and the senior
executive program at Harvard University in 1988.

A distinguished graduate of Officer Training School, Lackland
Air Force Base, Texas, the general was commissioned in February
1964. General Hallin then attended Supply Officers School, where he
was an honor graduate. He subseguently was assigned as a wing
materiel control officer with the 340th Bombardment Wing, Bergstrom
Air Force Base, Texas. In November 1965 he transferred to
Headguarters Strategic Air Command, Offutt Air Force Base, Neb., as
a supply staff officer.

After graduating from the School of Systems and Logistics, Air
Force Institute of Technology, he served at Tan Son Nhut Air Base,
South Vietnam, from October 1968 to October 1969. He then was
assigned to Headguarters U.S. Air Forces in Europe, Lindsey Air
Station, West Germany, where he served in supply requirements,
policy and financial management positions.

Upon his return to the United States in June 1973, General
Hallin entered Air Command and Staff College and was a distinguished

- MORE -



of Technology in 1968.

(Current as of July 1992)

graduate in June 1974. He then was assigned to the Directorate of
Logistics Plans and Programs, Office of the Deputy Chief of Staff,
Logistics and Engineering, Headquarters U.S. Air Force, Washington,
D.C., from June 1974 to July 1978. During his Air Staff tour of
duty he developed policy and programmed resources for key logistics
support areas.

The general completed Industrial College of the Armed Forces in
July 1979 and was assigned as chief of the Item Management Division,
Directorate of Materiel Management, Kelly Air Force Base, Texas,
then as chief, Resources Management Division. In October 1981 he
was assigned to Air Force Logistics Command headquarters,
Wright-Patterson Air Force Base, Ohio, as deputy director and,
later, as director of materiel requirements and financial resource
management. In July 1983 he became assistant deputy chief of staff
for materiel management at Wright-Patterson.

He transferred to the Warner Robins Air Logistics Center in
April 1984 as director of materiel management. In this position
General Hallin was responsible for providing worldwide logistics
support for assigned weapon systems, commodities, and such items as
the F-15, C-130, C-141, vehicles, electronic warfare systems and
avionics. In August 1986 the general became competition advocate
general of the Air Force, Office of the Secretary of the Air Force
for Research, Development and Logistics, Air Force headquarters. In
this position he established Air Force policy, interfaced with
industry and the Congress, and set the goals for the Air Force
contract competition program. In July 1987 the general was assigned
to the Joint Staff Directorate of Logistics, where he was deputy
director .for. plans, concepts and. analysis.. His responsibilities
included deliberate planning, mobilization, acquisition and mobility
analysis. He was commander of the Logistics Operations Center, Air
Force Logistics Command, from July 1989 until November 1990, when he
became deputy chief of staff for materiel management. In April 1991
the title of the position was changed to deputy chief of staff
for requirements due to a major reorganization of the command's
headquarters. He assumed his current position in July 1992.

His military awards and decorations include the Defense
Superior Service Medal, Legion of Merit with oak leaf cluster,
Bronze Star Medal, Meritorious Service Medal with oak leaf cluster
and Air Force Commendation Medal with two oak leaf clusters.

He was promoted to major general May 1, 1990, with the same
date of rank.

General Hallin is married to the former Susan Kay Callahan of
Springboro, Ohio. They have two daughters, Mindy and Holly.


WALSH, JAMES L.f JR.	Senior Research Engineer

Environmental Science and Technology Laboratory


M.S., Systems Management, University of Southern California	1973

M.S., Aerospace Engineering, Georgia Institute of Technology	1970

Bachelor of Aerospace Engineering, Georgia Institute of Technology	1969

Employment History

Georgia Institute of Technology Branch Head, Environmental
Engineering Branch

Senior Research Engineer
Research Engineer II

Research Assistant, Aerospace Engineering
EBASCO Services, Inc., Mechanical Engineer
United States Air Force, Project Engineer
United States Air Force, Missile Launch Crew Commander

Experience Summary

Currently director of the Georgia Tech Hazardous Waste Technical Assistance Program.
Engaged in work on waste handling and treatment; waste minimization and recycling; and
pollution prevention. Also involved in research related to design and analysis of advanced
pollution control systems for food processing wastes and biomass energy systems. As a
research assistant, conducted combustion instability studies for the National Aeronautics
and Space Administration. At EBASCO Services, designed and analyzed steam electric
power plant mechanical systems, wastewater treatment systems, and coal preparation
plants. Specific experience includes calculation of system design requirements,
specification and selection of power plant equipment, and preparation of operating
procedures. As a missile launch crew commander (rank, Captain), was responsible for ten
nuclear armed missiles and operation of equipment in control center. As a project
engineer, managed unmanned satellite design and projection contracts for prototype
military space missions. Also developed schedules, budgets, and technical plans for new

Current Fields of Interest

Management, treatment, and disposal of hazardous and non-hazardous waste. Food
industry environmental control systems research and development. Modification of
existing energy systems for biomass fuels, solid fuels or cogeneration; advanced energy
conversion systems; synthetic fuel production.






Professional Activities and Honors

Registered Professional Engineer, Georgia

Chairman, American Society for Testing and Materials Subcommittee E48.05 on Biomass

Conversion Systems

Vice Chairman, American Society for Testing and Materials Committee E48 on


Member, Water Pollution Control Federation

Major Reports, Publications and Presentations

1.	"Using the Toxic Release Inventory to Identify Firms for Technical Assistance,"
Proceedings, 1992 Technology Transfer Society Annual Meeting, Atlanta, Georgia,
June 1992, with C. Foley.

2.	"Energy Recovery from Food Processing Industry Wastewater Pretreatment
Sludges," 1992 University System Symposium on Research, University of Georgia,
May 8-9, 1992.

3.	"Pollution Prevention and Technical Assistance: Using the Toxic Release Inventory
to Identify Processes and Industries in Georgia," 1992 University System
Symposium on Research, University of Georgia, May 8-9, 1992, with C. Foley, et

4.	"An Integrated Optics Sensor for In-Situ Measurement of Environmental
Contaminants," 1992 University System Symposium on Research, University of
Georgia, May 8-9, 1992, with C. Ross, et al.

5.	"Environmental Assessment of Master Specification - Walt Disney Imagineering,"
Final Report, Project No. E-20-623, Glendale, California, March 15, 1992, with F.M.
Saunders, et al.

6.	"An Update of SARA Title III: Toxic Release Inventory Reports for the Food
Processing Industry - 1991," Proceedings, the 1991 Food Industry Environmental
Conference, Georgia Institute of Technology, November 1991, with C.C. Foley.

7.	"Using the Toxic Release Inventory Database to Target Technical Assistance,"

World Energy and Environmental Conference, Atlanta, Georgia, October 1991, with
C.C. Foley.

8.	"Development of a Field Worthy Sensor System to Monitor Gaseous Nitrogen
Transfer from Agricultural Cropland," Phase I Final Report Project No. A-8511, Sept
1991, with D.P. Campbell, N.F. Hartman, and C.C. Ross.

9.	"Pollution Prevention Technical Assistance for Selected Industries Research and
Technology Transfer," Final Report Project No. A-8865, Sept 1991.



10.	"Agricultural Wastes," Research Journal Water Pollution Control Federation, 63,
Number, June 1991, with C.C. Ross and G.E. Valentine.

11.	"Integrated Optic Sensor for Cropland Ammonia Volatilization Measurement," ASAE
Paper No. 90-1632, December 20, 1990 with C.C. Ross, N.F. Hartman, D.P.
Campbell, F.C. Boswell and W.L. Hargrove.

12.	"An Assessment of Toxic Emissions from the Food Processing Industry,"
Proceedings of the Sixth International Symposium on Agricultural and Food
Processing Wastes, Chicago, Illinois, December 17-18, 1990, with C.C. Foley.



Received Bachelors Degree from Tennessee Technological University and Masters Degree
from East Tennessee State University.

Employed by TVA for 25 years, having been involved in a variety of municipal, industrial,
agricultural, and utility waste management projects. Served as TVA's representative in
organizing and chartering the Southeastern Hazardous Waste Management Roundtable.

Served as Project Manager for Hazardous Waste and Wastewater Projects in TVA's
Regional Waste Management Department, Valley Resource Center.

Presently is Manager of Waste Reduction and Management for TVA's Regional Waste
Management Department and manages TVA's Waste Reduction Assessment and
Technology Transfer Project (WRATT) retiree program.



BS - Chemical Engineering, Penn State University

Worked for 1 year as a Patent Examiner for Chemical Engineering processes at the U.S.
Patent & Trademark Office, Washington, D.C.

Worked in Region IV's Water Division for 4 & 1/2 years.

Did a 3-month detail to Pollution Prevention Unit last year to work on Pollution Prevention
in NPDES Permitting and is currently on detail again as Acting Chief of the Unit.


Colonel Jose L. Saenz is the director of environmental
services for the Air Force Center for Environmental Excellence at
Brooks AFB, Texas.

Colonel Saenz was born Dec. 23,1943, in Weslaso, Texas. He
earned a bachelor of science degree in civil engineering from
Texas A&M University in 1967. He completed Squadron Officer's
School in 1973, Air Command and Staff College in 1979 and Air War
College in 1989.

He was a distinguished graduate of Air Force Officer
Training School at Lackland AFB, Texas, and entered active duty
in February 1968. His first assignment was as a missile facility
design engineer at Little Rock AFB, Ark.

In 1968, he went to the National Aeronautic and Space
Administration's Manned Spacecraft Center at Houston, Texas, as a
trajectory determination specialist.

From November 1970 to November 1971 Colonel Saenz served as
a developer of Vietnamese air base facilities at headquarters 7th
Air Force at Tan Son Nhut AB, Republic of Vietnam.

In November 1971, he began a four-year tour of duty at
Howard AFB, Republic of Panama. While there he served as an air
base facility developer and as chief of operations and

In October 1975, Colonel Saenz was assigned to the Defense
Mapping Agency Aerospace Center in St. Louis, Mo., as the chief
of field engineering operations.

In October 1979, he became the chief of the Civil
Engineering and Services Force Development Division for the Air
Training Command at Randolph AFB, Texas.

In 1980, he was selected to become the chief of the Civil
Engineering Field Office for the $110 million A-10 weapons system
beddown at Suwan AB, Korea.

Colonel Saenz returned to the Air Training Command at
Randolph AFB, Texas, in 1981 as chief of the Civil Engineering
and Services Inspection Branch.

In July 1983, he became the commander of the 3480th Civil
Engineering Squadron at Goodfellow AFB, Texas. In July 1936, he
returned again to Air Training Command headquarters at Randolph
AFB, Texas, as chief of environmental planning for the deputy
chief of staff, engineering and services.

Colonel Saenz assumed his present position in March 1991.

Colonel Saenz is a member of the Society of American
Military Engineers.

Colonel Saenz is married to the former Gloria Alice Daniel
of Houston, Texas. They have two sons, Mike and Joe.

Don Guinyard
Assistant Regional Administrator
Office of Policy and Management

Don Guinyard is a native of Orlando, Florida, where he attended and
graduated from Jones High School. He is a graduate of Bishop
College, Dallas, Texas, with a degree in Biology.and Chemistry. Don
has also pursued graduate studies in Governmental Administration from
Georgia State University, Atlanta, Georgia.

Don started his federal career with the U.S. Department of
Agriculture Research Service as a Research Physical Science
Technician and Biologist. He has worked with the U.S. Public Health
Service and the Department of Health and Human Services where he held
positions as Vector Control Specialist in the Aedes Aeypti
Eradication Program (yellow Fever Mosquito) and Public Health Advisor
in Rodent Control Program, respectively. In these positions he was
responsible for coordinating vector control and municipal solid waste
management practices with the cities of Tampa, Florida; Philadelphia,
Pennsylvania and Atlanta, Georgia.

Don started his career with the Environmental Protection Agency in
1971 with the Water Division, while employed in the Water Division,
he has served as Municipal NPDES Coordinator, Chief, NPDES Compliance
Unit, Chief, Underground injection Control Section and Chief, Water
Supply Branch.

From 1986 to 1988 he was Deputy Director, Environmental Services
Division, responsible for providing analytical and field support
services to other EPA programs.

Prior to becoming Director, Waste Management Division, he served as
the Associate Director from 1988 to October 1990. From October 1990
to October 1991, he served as Acting Director until his appointment
as Director, as Director his responsibilities include implementing
the Superfund program under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) and Resource Conservation
and Recovery Act (RCRA) programs.

In March 1992, Don was named the Assistant Regional Administrator
(ARA) for the Office of Policy and Management. As ARA, he is the
Region'b Chief Financial Officer and Senior Procurement Official.

He was awarded the 1990 Lee M. Thomas Excellence in Management
Award. This award is granted only to selective management employees
of the Environmental Protection Agency. Don was one of ten other
recipients of this award.

He is a member of the American Biological Society, National Alliance
of Business (Youth Motivation Task Force) Big Brothers of Atlanta;
Christian Businessman Committee and EPA's Senior Executive Service.

He is one of the Agency's Campus Executive in the Academic Relations
Program. A program designed to enhance minority recruiting at
Historical Black Colleges and Universities.







Office of Pollution Prevention
U.S. Environmental Protection

"Preventing pollution is a far more efficient
strategy than struggling to deal with problems
once they 've occurred. For too long, we've
focused on cleanup and penalties after the
damage is done. It's time to reorient ourselves
using technologies and processes that reduce
or prevent pollution — to stop it before it starts."



Pollution prevention is a top priority for EPA

Federal role in promoting pollution prevention is

Congress has directed EPA to encourage pollution
prevention in Federal agencies:

-	Pollution Prevention Act of 1990

-	Conference Committee Report

Pollution Prevention fkt

•	Definition: Multi-Media Source

•	Environmental Protection Hierarchy




Pollution Prevention fkt:
Federal flgencies

Congress directs EPA to:

(1)	"Promote source reduction practices in other
Federal agencies"

(2)	"Identify opportunities to use Federal
procurement to encourage source reduction."

EPfi's Pollution Prevention

Issued by EPA Administrator in February 1991
The Strategy:

(1)	Provides guidance for integrating prevention into
EPA programs and functions;

(2)	Initiates the "33/50 Program," which seeks 50%
reductions for a target list of 17 chemicals;

(3)	Calls for separate prevention strategies for:

-	Agriculture

-	Energy and Transportation

-	Consumers

-	Federal Government

Goal of Federal Sector Strategy

Establish the Federal government as the national leader
in implementing pollution prevention policies and
in order to:

promote the sustainable use of natural resources

protect human health and the environment

Objectives set for three areas in which Federal
Government has a major role.

Federal Government's Role
Pollution Prevention

Federal Role as Generator


To significantly reduce quantity and toxicity of
pollutants released and wastes generated by Federal
facilities and on public lands ...

Voluntary Targets:

•	50% reduction in releases of 33/50 chemicals at all
GOCO facilities by end of CY 1995

•	33% reduction in releases of 33/50 chemicals for
other selected Federal facilities by end of CY 1995

V	• Pollution Prevention Facility Plans for selected

V	Federal facilities beginning in FY92-93.


Other Major Initiatives:

Expand "Model Community" demonstration program for
Federal facilities

"TIPPP" Guidance Manual (EPA/Army)

-	Meet new energy efficiency goals set forth in
Executive Order No. 12759 (April 1991)

-	Reduce energy use in Federal buildings by 20% by

-	20% increase in energy efficiency by 2000

-	Minimize use of petroleum products at Federal

Implement "Green Lights" partners program for Federal
agencies in FY92-93

Voluntary accelerated phaseout of ozone-depleting
chemicals by end of 1995

Federal Role in


To implement affirmative environmental
procurement programs and life-cycle costing
practices throughout the Federal government...


•	By end of FY 1993, review Federal procurement
specifications and identify opportunities to
substitute or reduce use of 33/50 chemicals

•	Screen all Federal procurement specifications
and standards for environmental considerations
by end of FY 1993; complete review within five

Other Major Initiatives:

Make recommendations for changes in Federal
Acquisition Regulations

Cooperatively develop a Federal government life-cycle
costing model which builds environmental
considerations into procurement/acquisition decisions

Implement new E.O. 12780 - Federal Recycling and
Procurement (October 1991)

Ensure that each Federal agency procures the most
cost-effective energy-efficient goods and products

Ensure that, by end of 1995, Federal agencies are
annually acquiring the maximum number practicable of
alternative fuel vehicles

Proposed Joint DOE/EPfi
Pollution Prevention Initiative
April 1992

Strive to achieve (by 1995) participation in EPA 33/50

Strive to reduce release of 17 chemicals of concern
(33/50) DOE-wide for installations not required to
report under SARA Title III

Review specifications by end of 1993 to reduce use
of the 17 chemicals of concern

By end of 1993, initiate standardized procedure for
periodic review of specifications to allow continuous
environmental improvement

Draft Joint DOD/EPfi Pollution
Prevention lnitiative:Toxics Reduction
in the Military (TRIM) - fipril 1992

Encourage GOCO facility operators to voluntarily
participate in the 33/50 program
Initiate voluntary reporting of all TRI chemicals for

Continue to study possible prevention progress
measurement techniques
By end of 1993, complete review of military
specifications to identify reduction opportunities for the
17 chemicals of concern for the 33/50 program
By the end of 1993, complete standardized procedure
for the periodic review of military specifications and
standards to allow continuous environmental

Federal Role in Policy-Making


• Utilize NEPA and other tools to help ensure that
Federal agencies incorporate pollution prevention
concepts; provide appropriate incentives for the
affected community and offer tech


Use NEPA as mechanism for incorporating prevention
into Federal agency decisions:

„	- Issue new NEPA guidance to direct Federal

agencies to incorporate pollution prevention



approaches into agency EISs (CEQ)

Federal Role in Policy-Making

-	Develop pollution prevention guidelines for
reviewing EISs, environmental assessments, etc.

-Target Federal policies and regulations for pollution
prevention emphasis under NEPA (CEQ and EPA,
plus interagency environmental policy review

Launch major pollution prevention initiative for

public lands management in FY 1993

Technical Assistance/Technology Transfer:

-	Waste Reduction Evaluations at Federal Sites
(WREAFS) Program (EPA/ORD)

Federal Role in Policy-Making

Interagency Pollution Prevention Grants Programs:

•	Agriculture in Concert with the Environment (ACE)

•	National Industrial Competitiveness through
efficiency; Energy, Environment, and Economics
(NICE3) (EPA, DOE, Commerce)

Pollution Prevention Information Clearinghouse
(PPIC/PIES): by end of FY 92, establish a separate
Federal mini-exchange/database (FAME)

Environmental Executive Order

Last environmental executive order for Federal facilities
was issued in 1978, emphasizes pollution control

New priorities, approaches indicate need for new
environmental executive order

Pollution prevention would be featured as a major theme
in a new executive order

Strategy calls for an Interagency Workgroup to jointly
draft the new executive order

Comments on Draft Strategy

Comments received from:

-	DOD, DOE, CEQ, Air Force, NASA, TVA, Interior, Forest

-	EPA Headquarters (10 offices) and Regions (6 out of 10)
Overall positive reception. Major issues raised in areas of:

-	Ambitious nature of certain numerical reduction targets

-	Use of NEPA to review Federal programs

-	Pollution prevention definitional and measurement

-	Need to identify specific roles and responsibilities for

Schedule/Next Steps

Revise draft strategy for final round of reviews in Spring

Completed negotiation on separate Federal agency
(DOE, DOD, GSA) pollution prevention National
agreements and incorporate in strategy

Concurrent development of strategy implementation
plan to be issued with final strategy:

-	Agency roles and responsibilities

-	Resources/funding requirements

-	Schedules for specific initiatives

Many individual initiatives already underway


This Act may be cited as the *'Pollution Prevention Act
of 1990*


Sec. 1. Short title and table of contents.

Sec. 2. Findings and policy.

Sec. 3. Definitions.

Sec. 4. EPA activities.

Sec. 5. Grants to States for State technical assistance

Sec. 6. Source reduction clearinghouse.

Sec. 7. Source reduction and recycling data collection.

Sec. 8. EPA report.

Sec. 9. Savings provisions.

Sec. 10. Authorization of appropriations.

Sec. 11. Implementation.


(a) FINDINGS.—The Congress finds that:

(1)	The United States of America annually produces
millions of tons of pollution and spends tens of billions
of dollars per year controlling this pollution.

(2)	There are significant opportunities for industry
to reduce or prevent pollution at the source through
cost-effective changes in production, operation, and raw
materials use. Such changes offer industry substantial
savings in reduced raw material/ pollution control/ and
liability costs as well as help protect the environment
and reduce risks to worker health and safety.

(3)	The opportunities for source reduction are often



1	not realized because existing regulations, and the

2	industrial resources they require for compliar. focus

3	upon treatment and disposal, rather than source

4	reduction; existing regulations do not emphasize

5	multi-media management of pollution; and businesses need

6	information and technical assistance to overcome

7	institutional barriers to the adoption of source

8	reduction practices.

9	(4) Source reduction is fundamentally different and

10	more desirable than waste management and pollution

11	control. The Environmental Protection Agency needs to

12	address the historical lack of attention to source

13	reduction.

14	(5) As a first step in preventing pollution through

15	source reduction, the Environmental Protection Agency

16	must establish a source reduction program which collects

17	and disseminates information, provides financial

18	assistance to States, and implements the other activities

19	provided for in this Act.

20	(b) POLJCYi—The Congress hereby declares it to be the

21	national policy of the United States that pollution should be

22	prevented or reduced at the source whenever feasible;

23	pollution that cannot be prevented should be recycled in an

24	environmentally safe manner, whenever feasible; pollution

25	that cannot be prevented or recycled should be treated in an



1	environmentally safe manner whenever feasible; and disposal

2	or other release into the environment should be employed only

3	as a last resort and should be conducted in an

4	environmentally safe manner.


6	For purposes of this Act—

7	(1) The term *'Administrator" means the

8	Administrator of the Environmental Protection Agency.

9	(2) The term "Agency" means the Environmental

10	Protection Agency.

11	(3J The term "toxic chemical'' means any substance

12	on the list described in section 313(c) of the Superfund

13	Amendments and Reauthorization Act of 1986.

14	(4) The term "release" has the same meaning as

15	provided by section 329(8) of the Superfund Amendments

16	and Reauthorization Act of 1986.

17	(5) (A) The term "source reduction" means any

18	practice which—

19	(i) reduces the amount of any hazardous

20	substance, pollutant, or contaminant entering any

21	waste stream or otherwise released into the

22	environment (including fugitive emissions) prior to

23	recycling, treatment, or disposal; and

24	(ii) reduces the hazards to public health and the

25	environment associated with the release of such



1	substances, pollutants, or contaminants.

2	The term includes equipment or technology modifications,

3	process or procedure modifications, reformulation or

4	redesign of products, substitution of raw materials, and

5	improvements in housekeeping, maintenance, training, or

6	inventory control.

7	(B) The tern **source reduction" does not include

8	any practice which alters the physical, chemical, or

9	biological characteristics or the volume of a hazardous

10	substance, pollutant, or contaminant through a process or

11	activity which itself is not integral to and necessary

12	for the production of a product or the providing of a

13	service.

14	(6) The tera *%multi-media means water, air, and

15	land.

16	(7) The tera **SIC codes" refers to the 2-digit code

17	numbers used for classification of economic activity in

18	the Standard Industrial Classification Manual.


20	(a) AUTHORITIES!—The Administrator shall establish in

21	the Agency an office to carry out the functions of the

22	Administrator under this Act. The office shall be independent

23	of the Agency's single-medium program offices but shall have

24	the authority to review and advise such offices on their

25	activities to promote a multi-media approach to source



1	reduction. The office shall be under the direction of such

2	officer of 'the Agency as the Administrator shall designate.

3	(b) FUNCTIONS^—The Administrator shall develop and

4	implement a strategy to promote source reduction. As part of

5	the strategy, the Administrate: shall—

6	(1) establish standard methods of measurement of

7	source reduction;

8	(2) ensure that the Acency considers the effect of

9	its existing and proposed programs on source reduction

10	efforts and shall review regulations of the Agency prior

11	and subsequent to their proposal to determine their

12	effect on source reduction;

13	(3) coordinate source reduction activities in each

14	Agency Office and coordinate with appropriate offices to

15	promote source reduction practices in other Federal

16	agencies, and generic research and development on

17	techniques and processes which have broad applicability;

18	(4) develop improved cethods of coordinating, and

19	assuring public access to data collected under Federal

20	environmental statutes;

21	(5) facilitate the adcpcion of source reduction

22	techniques by businesses. This strategy shall include the

23	use of the Source Reduction Clearinghouse and State

24	matching grants provided in this Act to foster the

25	exchange of information regarding source reduction

























techniques, the dissemination of such information to
businesses, and the provision of technical assis:ance to
businesses. The strategy shall also consider, the
capabilities of various businesses to make use of source
reduction techniques;

(6)	identify, where appropriate, measurable goals
which reflect the policy of this Act, the tasks necessary
to achieve the goals, dates at which the principal tasks
are to be accomplished, required resources,
organizational responsibilities, and the means by which
progress in meeting the goals will be measured;

(7)	establish an advisory panel of technical experts
comprised of representatives from industry, the States,
and public interest groups, to advise the Administrator
on ways to improve collection and dissemination of data;

(8)	establish a training program on multimedia source
reduction opportunities, including workshops and guidance
documents, for State and Federal permit issuance,
enforcement/ and inspection officials working within all
agency program offices.

(9)	identify and make recommendations to Congress to
eliminate barriers to source reduction including the use
of incentives and disincentives;

(10)	identify opportunities to use Federal
procurement to encourage source reduction;



1	(11) develop, test and disseminate model source

2	reduction auditing procedures designed to highlight

3	source reduction opportunities; and

4	(12) establish an annual award program to recognize a

5	company or companies which operate outstanding or

6	innovative source reduction programs.



9	(a) GENERAL Authority.—The Administrator shall make

10	matching grants to States Cor programs to promote the use of

11	source reduction techniques by businesses.

12	(b) CRITERIA.—When evaluating the requests for grants

13	under this section, the Administrator shall consider, among

14	other things, whether the proposed State program would

15	accomplish the following:

16	(1) Make specific technical assistance available to

17	businesses seeking information about source reduction

18	opportunities, including funding for experts to provide

19	onsite technical advice to business seeking assistance

20	and to assist in the development of source reduction

21	plans.

22	(2) Target assistance to businesses for whom lack of

23	information is an impediment to source reduction.

24	(3) Provide training in source reduction techniques.

25	Such training may be provided through local engineering



1	schools or any other appropriate means.

2	(c) MATCHING Funds.—Federal funds used in any icate

3	program under this section shall provide no more than 50 per

4	centum of the funds made available to a State in each year of

5	that State's participation in the program.

6	(d) EFFECT IVENESSi—The Administrator shall establish

7	appropriate means for measuring the effectiveness of the

8	State grants made under this section in promoting the use of

9	source reduction techniques by businesses.

10	(e) Information.—states receiving grants under this

11	section shall make information generated under the grants

12	available to the Administrator.


14	(a) AUTHORITY.—The Administrator shall establish a

15	Source Reduction Clearinghouse to compile information

16	including a computer data base which contains information on

17	management/ technical, and operational approaches to source

18	reduction. The Administrator shall use the clearinghouse to—

19	(1) serve as a center for source reduction technology

20	transfer;

21	(2) mount active outreach and education programs by

22	the States to further the adoption of source reduction

23	technologies; and

24	(3) collect and compile information reported by

25	States receiving grants under section 5 on the operation



1	and success of State source reduction programs.

2	(b) PUBLIC AvaILABILITY.—The Administrator shall make

3	available to the public such information on source reduction

4	as is gathered pursuant to this Act and such other pertinent

5	information and analysis regarding source reduction as may be

6	available to the Administrator. The data base shall permit

7	entry and retrieval of information to any person.


9	(a) Reporting Requirements.—Each owner or operator of a

10	facility required to file an annual toxic chemical release

11	form under section 313 of the Superfund Amendments and

12	Reauthorization Act of 1986 ("SARA") for any toxic chemical

13	shall include with each such annual filing a toxic chemical

14	source reduction and recycling report for the preceeding

15	calendar year. The toxic chemical source reduction and

16	recycling report shall cover each toxic ctesical required to

17	be reported in the annual toxic chemical release form filed

18	by the owner or operator under section 313(c) of that Act.

19	This section shall take effect with the annual report filed

20	under section 313 for the first full calerdar year beginning

21	after the enactment of this Act.

22	(b) Items Included in Report.—The toxic chemical source

23	reduction and recycling report required urder subsection (a)

24	shall set forth each of the following on a

25	facility-by-facility basis for each toxic chemical:



1	(1) The quantity of the chemical entering any waste

2	stream (-or otherwise released into the envircns.^t) prior

3	to recycling, treatment, or disposal during the calendar

4	year for which the report is filed and the percentage

5	change from the previous year.. The quantity reported

6	shall not include any amount reported under paragraph

7	(7). When actual measurements of the quantity of a toxic

8	chemical entering the waste streams are not readily

9	available, reasonable estimates should be made based on

10	best engineering judgment.

11	(2) The amount of the chemical from the facility

12	which is recycled (at the facility or elsewhere) during

13	such calendar year, the percentage change from the

14	previous year, and the process of recycling used.

15	(3) The source reduction practices used with respect

16	to that chemical during such year at the facility. Such

17	practices shall be reported in accordance with the

18	following categories unless the Administrator finds other

19	categories to be more appropriate:

20	(A) Equipment, technology, process, or procedure

21	modifications.

22	(B) Reformulation or redesign of products.

23	(C) Substitution of raw materials.

24	(D) Improvement in management, training,

25	inventory control, materials handling, or other


























general operational phases of industrial facilities.

(4)	The amount expected to be reported under
paragraph (1) and (2) for the two calendar years
immediately following the calendar year for which the
report is filed. Such amount shall be expressed as a
percentage change from the amount reported in paragraphs
(1) and (2).

(5)	A ratio of production in the reporting year to
production in the previous year. The ratio should be
calculated to most closely reflect all activities
involving the toxic chemical. In specific industrial
classifications subject to this section, where a
feedstock or some variable other than production is the
primary influence on waste characteristics or volumes,
the report may provide an index based on that primary
variable for each toxic chemical. The Administrator is
encouraged to develop production indexes to accommodate
individual industries for use on a voluntary basis.

(6)	The techniques which were used to identify source
reduction opportunities. Techniques listed should
include, but are not limited to, employee
recommendations, external and internal audits,
participative team management, and material balance
audits. Each type of source reduction listed under
paragraph (3) should be associated with the techniques or



1	multiples of techniques used to identify the source

2	reduction technique.

3	(7) The amount of any toxic chemical released into

4	the environment which resulted from a catastrophic event,

5	remedial action, or other one-time ever.t and is not

6	associated with production processes during the reporting

7	year.

8	(8) The amount of the chemical from the facility

9	which is treated (at the facility or elsewhere) during

10	such calendar year and the percentage change from the

11	previous year.

12	For the first year of reporting under this subsection,

13	comparison with the previous year is required only to the

14	extent such information is available.

15	{c} SARA PROVlSIONSi—The provisions of sections 322,

16	325(c), and 326 of the Superfund Amendments and

17	Reauthorization Act of 1986 shall apply to the reporting

18	requirements of this section in the same manner as to the

19	reports required under section 313 of that Act. The

20	Administrator may modify the form required for purposes of

21	reporting information under section 313 of that Act to the

22	extent he deems necessary to include the additional

23	information required under this section.

24	(dj Additional Optional Information,—Any person filing a

25	report under this section for any year may include with the



1	report additional information regarding source redction,

2	recycling, and other pollution control techniques in earlier

3	years.

4	(e) Availability of Data.—subject to section 322 of the

5	Superfund Amendments and Reauthorization Act of 1986, the

6	Administrator shall make data collected under this section

7	publicly available in the same manner as the data collected

8	under section 313 of the Superfund Amendments and

9	Reauthorization Act of 1986.


17	(a) BlENKIAL REPORTS.—The Administrator shall provide

18	Congress with a report within eighteen months after enactment

19	of this Act and biennially thereafter, containing a detailed

20	description*of the actions taken to implement the strategy to

21	promote source reduction developed under section 4(b} and of

22	the results of such actions. The report shall include an

23	assessment of the effectiveness of the clearinghouse and

24	grant program established under this Act in promoting the

25	goals of the strategy/ and shall evaluate data gaps and data



1	duplication with respect to data collected under Federal

2	environmental statutes.

3	(b) Subsequent Reports.—Each biennial report submitted

4	under subsection (a) after the first report shall contain

5	each of the following:

5	(1) An analysis of the data collected under section 7

7	on an industry-by-industry basis for not less than five

8	SIC codes or other categories as the Administrator deems

9	appropriate. The analysis shall begin with those SIC

10	codes or other categories of facilities which generate

11	the largest quantities of toxic chemical waste. The

12	analysis shall include an evaluation of trends in source

13	reduction by industry, firm size, production, or other

14	useful means. Each such subsequent report shall cover

15	five SIC codes or other categories which were not covered

16	in a prior report until all SIC codes or other categories

17	have been covered.

18	(2) An analysis of the usefulness and validity of the

19	data collected under section 7 for measuring trends in

20	source ^reduction and the adoption of source reduction by

21	business.

22	(3) Identification of regulatory and nonregulatory

23	barriers to source reduction, and of opportunities for

24	using existing regulatory programs, and incentives and

25	disincentives to promote and assist source reduction.



1	l<) Identification of industries and pollutants that

2	require-priority assistance in multi-media source

3	reduction.

4	(5) Recommendations as to incentives needed to

5	encourage investment and research and development in

6	source reduction.

7	(6) Identification of opportunities and development

8	of priorities for research and development in source

9	reduction methods and techniques.

10	(7) An evaluation of the cost and technical

11	feasibility, by industry and processes, of source

12	reduction opportunities and current activities and an

13	identification of any industries for which there are

14	significant barriers to source reduction with an analysis

15	of the basis of this identification.

16	(8) An evaluation of methods of coordinating,

17	streamlining, and improving public access to data

18	collected under Federal environmental statutes.

19	(9) An evaluation of data gaps and data duplication

20	with respect to data collected under Federal

21	environmental statutes.

22	In the report following the first biennial report provided

23	for under this subsection, paragraphs (3) through (9) may be

24	included at the discretion of the Administrator.


JMW58 5


1	(a) Nothing in this Act shall be construed to modify or

2	interfere with the implementation of title III of tr.e

3	Superfund Amendments and Reauthorization Act of 1985.

4	(b) Nothing contained in this Act shall be construed,

5	interpreted or applied to supplant, displace* preecpt or

6	otherwise diminish the responsibilities and liabilities under

7	other State or Federal law, whether statutory or common.


9	There is authorized to be appropriated to the

10	.Administrator $8,000,000 for each of the fiscal years 1991,

11	1992, and 1993 for functions carried out under this Act

12	(other than State grants), and $8,000,000 for each of the

13	fiscal years 1991, 1992, and 1993, for grant programs to

14	States issued pursuant to section 5.

Pollution Prevention Information Clearinghouse


Federal Agencies Pollution Prevention Programs and Projects

The Pollution Prevention Information Gearinghouse (PPIC) is establishing a Federal Agencies Mini-
Exchange (FAME) database on its Pollution Prevention Information Exchange System (PIES). The U.S.
Environmental Protection Agency (EPA) is collecting information concerning any Federal agencies' pollution
prevention efforts. EPA is requesting a variety of information from Federal agencies' environmental managers
on their pollution prevention/waste minimization programs and projects. EPA is soliciting Federal agencies
and facilities to provide the following types of information:

•	Policy Statements - cunrent Agency and facility
pollution prevention goals, objectives, and policy

•	Program Descriptions - formal and informal
facility and Agency pollution prevention pro-
grams that encourage or enhance the implemen-
tation of waste minimization opportunities.

•	Manuals and Guidance Documents - facility-
specific or Agency pollution prevention reports,
articles, directives, guidance documents, and
document ordering information.

•	Conferences, Seminars, and Training Courses
- any upcoming pollution prevention confer-
ences, 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 gathered
from waste minimization assessments, procurement activities, audits, process changes, National Environ-
mental Policy Act (NEPA) reviews, and other "lessons learned." Contact PPIC for a copy of the case study

This information will be collected, placed on PIES, and shared by Federal agencies and industries that are
facing similar waste management/waste minimization problems. If your Federal agency or facility has
developed a pollution prevention program or initiated waste minimization projects and would like to
participate in exchanging information on PIES, please send copies to PPIC, Federal Agencies Mini-Exchange,
7600-A Leesburg Pike, Falls Church, VA 22043. If you have any questions concerning the requested
information or accessing the Clearinghouse, call PPIC Technical Assistance at (703) 821-4800.

> JPPIC Is a cteari|ngho^	to ieducisg

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United States
Environmental Protection

Office of Pollution Prevention
Washington, DC 20460

Marcn ' 99'

<&EPA Pollution Prevention

Fact Sheet

EPA's Pollution
Prevention Strategy

Overview	EPA's Pollution Prevention Strategy, released in February 1991, was

developed by the Agency in consultation with all program and
regional offices. The strategy provides guidance on incorporating
pollution prevention into EPA's ongoing environmental protection
efforts and includes a plan for achieving substantial voluntary
reductions of targeted high risk industrial chemicals. The strategy is
aimed at maximizing private sector initiative while challenging
industry to achieve ambitious prevention goals.

Industrial	A major component of the strategy is the Industrial Toxics

Toxics Project	Project. EPA has identified 17 high risk industrial chemicals that

offer significant opportunities for prevention (see box on back of this
page). The Agency has set a goal of reducing environmental releases
of these chemicals by 33 percent by the end of 1992 and by at least 50
percent by the end of 1995.

The 17 pollutants identified as targets of the industrial toxics project
present both significant risks to human health and the environment
and opportunities to reduce such risks through prevention. The list
was drawn from recommendations submitted by program offices,
taking into account such criteria as health and ecological risk,
potential for multiple exposures or cross-media contamination,
technical or economic opportunities for prevention, and limitations
of treatment.

All of the targeted chemicals are included on EPA's Toxic Release
Inventory (TRI); thus, reductions in their releases can be measured
in each year's TRI reports. Several hundred companies who have
reported releases of the target chemicals have already been
contacted by EPA. EPA is seeking their cooperation in making
voluntary commitments to reduce releases and in developing
pollution prevention plans to cany out these commitments.

Printed on Recycled Paper

Guidance for
EPA Activities

The strategy also provides guidance on incorporating pollution
prevention into the Agency's existing programs, emphasizing the
need for continued strong regulatory and enforcement programs.

At the same time, the
strategy favors
flexible, cost-effective
approaches that
involve market-based
incentives where
practical. For
example, the strategy
calls for the use of
"regulatory clusters,"
through which EPA
will categorize the
rules it intends to
propose over the next
several years for
certain chemicals and
their sources. The
clusters are intended
to foster improved
cross-media evaluation of the cumulative impact of standards, more
certainty for industry, and early investment in prevention activities.

Institutional	The strategy outlines several short-term measures that will address

Barriers	various institutional barriers within the Agency's own organization

that limit its ability to develop effective prevention strategies. Such
measures include designating special assistants for pollution
prevention in each Assistant Administrator's office, developing
incentives and awards to encourage Agency staff to engage in
pollution prevention efforts, incorporating prevention into the
comprehensive 4-year strategic plans by each program office, and
providing pollution prevention training to Agency staff.

Other Sectors	The industrial toxics project for the manufacturing sector represents

the first focus of a comprehensive Agency strategy. EPA will be
seeking to work with the Departments of Agriculture, Energy, and
Transportation to develop strategies for preventing pollution from
agricultural practices and energy and transportation use. EPA has
already begun several joint initiatives, including a cooperative grants
program for sustainable agriculture research with the Department of
Agriculture and a joint program with the Department of Energy to
demonstrate energy efficiency and waste reduction in key sectors.

Target Chemicals

(million pounds released in 1988)





Carbon Tetrachloride














Methyl Ethyl Ketone


Methyl Isobutyl Ketone




T etrachloroethylenc




1,1,1-T richloroe thane


T richlorocthylene




For More

Copies of the strategy document are available from Julie Shannon
in the Office of Pollution Prevention, 202-382-2736.

Office of Poflubon Picvcstxn
Wehingtott, DC 20460

United Sots
Environmental Protection

•	Source reduction practices used with respect to the toxic
chemical at the facility.

•	Techniques used to identify source reduction opportunities,
including employee recommendations, external and internal
audits, participatory team management, and material balance

•	A ratio of production in the reporting year to production in the
previous year.

Publication	The proposed rule will be published in the Federal Register in the

Fall 1991, with a final rule scheduled for the end of the year. EPA
is also preparing guidance to help facilities develop estimates for
these new data elements and identify sources of data.


For more information, contact the EPCRA Information Hotline at



fi New Approach to
Environmental Protection

•	Pollution Prevention Act

•	Federal Facility Procurement

•	Resource Conservation and Recovery Act

•	Clean Air Act

•	Clean Water Act

•	Montreal Protocol

•	Future Legislative Activity


/Pollution Prevention #3ct of 1990

"The Congress hereby declares it to be the national policy
of the United States that pollution should be prevented or
reduced at the source, whenever feasible; pollution that
cannot be prevented should be recycled in an
environmentally safe manner, whenever feasible; pollution
that cannot be prevented or recycled should be treated in
an environmentally safe manner, whenever feasible; and
disposal or other releases into the environment should be
employed only as a last resort and should be conducted in
an environmentally safe manner."


Pollution Prevention fkt of 1990

Major Components

•	Information Clearinghouse

•	State Grants

•	EPA Reporting

Pollution Prevention fkt of 1990

New TRI (SARA Title III) Reporting

•	Mandatory pollution prevention questions in FORM R (SARA
Title III)

•	Statistics on Recycling (on and off-site)

•	More detailed statistics on waste transfers

•	Changes in some reporting requirements for 1991. All
changes implemented for 1992 reporting year.



Pollution Prevention Strategy

In February 1991, EPA issued its Pollution Prevention
Strategy. The strategy outlines EPA pollution prevention
policy and objectives, and is designed to:

-	Set forth a program that will achieve specific
objectives in pollution prevention within a
reasonable time frame, and

-	Provide guidance and direction for efforts to
incorporate pollution prevention within EPA's existing
regulatory and non-regulatory programs.

Federal Facility Procurement

EPA has issued "procurement guidelines" requiring
government agencies to buy products made with
recovered materials. The guidelines provide
recommendations for implementing certain
requirements of Section 6002 of RCRA, which requires
procuring agencies to:

- Revise specifications to allow procurement of
products containing recovered material

- Eliminate requirements that specifically exclude the
use of recovered materials

Federal Facility Procurement

• Materials included under the Procurement Act include:



-	Insulation

-	Tires and Retreaded Tires

-	Rerefined Oils

-	Paper

-	Concrete w/fly ash


-	Compost

-	Particle Board



Resource Conservation and
Recovery fict (RCRfi), 1976

Targeting pollution control, Congress passed RCRA to
regulate the land disposal of waste, and mandated that
hazardous wastes be treated, stored, and disposed of
properly. The goals are:

-	Protect human health and the environment

-	Reduce waste and conserve energy and natural

-	Reduce or eliminate the generation of hazardous
waste as expeditiously as possible

/RCRfi Amendments, 1984

The 1984 Hazardous arid Solid Waste Amendments (HSWA)
significantly expanded the scope and requirements of
RCRA. HSWA Incorporated Pollution Prevention into National

• "The Congress hereby declares it to be the national
policy of the United States that, wherever feasible, the
generation of hazardous waste is to be reduced or
eliminated as expeditiously as possible. Waste that is
nevertheless generated should be treated, stored, or
disposed of so as to minimize the present and future
V	threat to human health and the environment."

Clean flir fict,

The Clean Air Act designated specific substances to
be regulated by establishing maximum emission
levels. The act promotes prevention and control of air
pollution through:

-	National Ambient Air Quality Standards (NAAQS)

-	National Emission Standards for Hazardous Air
Pollutants (NESHAPS)

-	New Source Performance Standards

/The flir Pollution Prevention and
/ Control fict of 1990

"...air pollution prevention and air pollution control at its
source is the primary responsibility of States and local

"...Federal financial assistance and leadership is essential
for the development of cooperative Federal, state and
local programs to prevent and control air pollution..."


The fiir Pollution Prevention
and Control fict of 1990

Several provisions of the Clean Air Act Amendments
promote prevention, including:

-	Federal, state, and local government actions

-	Research and technology programs

-	Reduced emissions of hazardous air pollutants

-	Reduced emissions of sulfur dioxide

-	Improved fuel quality

-	Phase-out of substances with detrimental
environmental effects

Clean Water fict, 1970

Congress passed the Clean Water Act to provide
comprehensive Federal regulation on all sources of
water pollution. The long-term goal of the Act is "zero
discharge" of pollutants to the nation's waters.

Clean Water fkt, 1987

As part of the 1987 Amendments, Congress recognized
that end-of-pipe methods often result in media shifts of

Congress amended the Clean Water Act to encourage
cities and industries to implement best management
practices to reduce releases to surface waters.

The Montreal Protocol

In 1987, several countries worldwide adopted the
Montreal Protocol on Substances that Deplete the
Ozone layer. The Protocol has since been ratified by
over 60 countries and took effect in January of 1989.
The goal is to protect the ozone layer from man-made
ozone depleting chemicals by phasing out by 1995:

-	CFCs

-	Carbon tetrachloride

-	Halons

-	Methyl Chloroform

Future Legislative Activity

Federal Facilities Toxic Release Act (H.R. 4986)
RCRA Reauthorization
CWA Reauthorization

Federal Facilities Toxic Release
Act (H.R. 4986)

•	No SIC code limitations

•	Effective Immediately

•	EPA study of additional chemicals

•	Full TRI reporting


Robert B. Pojasek, Ph.D.

GEI Consultants. Inc.





A company wishing to undertake
pollution prevention must not
only understand the elements of
a good prevention program, as dis-
cussed in the articles beginning on pp.
120 and 130. The procedure whereby
such a program is implemented can
also make a big difference.

Unfortunately, much of the imple-
mentation today follows a "prescrip-
tive" approach [7], This employs a
standardized procedure built around
questionnaires and checklists, and it
relies heavily on past solutions to pollu-
tion problems that are presumed simi-
lar to the one at hand.

A more-creative and imaginative al-
ternative is offered here. It can be
called the "descriptive" approach
[2,3,b\ In it. people close to the process-
ing operation under examination are
challenged to define and study the pol-
lution problems and derive their own
ways of solving them.

Functionality is important

The starting point for the descriptive
approach is is the concept of functional-
ity. For every process or operation in
the chemical process industries there is
a functional sequence of events or ac-
tions. One action initiates others, which
in turn initiate still others, until the
process has completed its overall func-
tion with some kind of product

Functionality is captured in a process
flow diagram, similar to the flowsheets

used by process engineers. It uses box-
es to depict the series of steps through
which the input materials must pass in
the course of transformation into prod-
uct. Lines may represent either move-
ment of material from one process step
to another (as in a conventional flow
diagram) or instead the time sequence
of functions. To ensure a complete ac-
counting of materials, all inputs and
losses from each unit or operation must
be depicted.

This diagram becomes the basis for
defining, refining, documenting and
understanding the process. One must
gain that understanding in order to
most effectively alter the system so as
to have fewer losses (i.e., so as to imple-
ment pollution prevention).

It takes a variety of skills to operate
an industrial facility. Most if not all
those same talents should be drawn
upon to integrate pollution prevention

into the facility's operations. The infor-
mation-gathering that pins down the
functionality can — indeed, should —
be done by group effort Table 1 shows
some of the skills that might be repre-
sented. The optimal group size ^
around eight to twelve people.

The "first draft" of the process flow
diagram and the materials accounting
can be constructed as an interacts .•
effort without ever going inside
facility. Each participant in the
will have a different perspecc-.- -
what happens in the process or >•ซ-ป
tion. These differences can ..
cussed, perhaps while someone — .
connected with the process is i i * . -
as a resource person. Refers.
general nature can be provno*-:
group members before the r
provide some background in/or— ฑ - -

The next step is to verify ir.r ,r
mation in the first draft The taarr.



Environmental engineering
Safety and health
Design engineering
Production engineering
Information systems
Human resources
Materials management
Marketing and sales
Accounting and finance

TABLE 1. The pollution-prevention team

Part 3


This approach
capitalizes on
and creativity


Waate MMmitanon Aaaaaament

Proe, UrW/Oper.

Prepared By




Pmf No

Sheet l_ <# _l_ Page j_ <# J_








OpOona Rating (R)

•i Option

n option

S3 Option

M Option

*3 option











Reduction in waste's hamd

Reduction ol treatment/dlipoaaI com

Reduction of safety hazard*

Reduction ot input RMtanai com

Extern ot current use in induany

Effect on product quatfy (no onset ฆ 10)

Low capital cost

Low 0 ft U cost

Short mptementaOon period

Eeeeol ImpMinemaUon


Sua ot Wtigniad Wattage ฃ (W*R)

lyiMi Rartdag

FeaattMy AiMMia actioduM tar (DaM)

Fta 1. Wortcsi from US. Environmental Protection Agency (EPA) iupiesiif one wy to rank poMutton-pwntlon i



this by checking with the people who
actually run the process or operation.

This approach to assembling the au-
thoritative diagram is of course more
roundabout than simply going in the
first place to the people directly in-
volved. Its advantage is that it forces
everybody on the team to think deeply
about the process or operation. This can
vastly broadens the range of sugges-
tions for pollution prevention, as dis-
cussed in the next section.

Seeking opportunities

Once the group clearly understands the
functionality of the process, it can turn
to any of various idea-generating tech-
niques to derive a list of opportunities
for minimizing or eliminating process
losses. Examples of such techniques
are brainstorming (see top of next
page), force-field analysis, and the use
of cause-and-effect diagrams. If it
seems desirable, the group can be
trained beforehand to utilize creativity
properly in this crucial step [J].

This search for opportunities is the
soul of the descriptive approach. It can-
not be relegated to a computer search
for case histories, nor to an engineer
trying to adapt a "standard" pollution-
prevention approach utilized else-
where. Instead the team responds to
the singular characteristics of the pro-
cess and the culture of the company.

It is important to keep this step inde-
pendent of the feasibility study that
follows. People should feel free to sug-
gest or to discuss proposed solutions
for virtually any reason — for instance,
good return on investment a project of
special interest to the facility manager,
a project easy to start with.

Various criteria and techniques for
informally ranking the suggested op-
portunities are available. Figure 1
shows a worksheet used for this pur-
pose by the U.S. Environmental Protec-
tion Agency (EPA). Many firms prefer
a simpler approach utilizing a (+) for
favorable, a (-) for unfavorable and a
(0) for neutral or undetermined.

By means of such criteria or tech-
niques. the group will progress from
many opportunities to one or more pri-
mary ones that seem (subject to the
subsequent feasibility study) particu-
larly realistic and doable. For example,
a group seeking opportunities within a


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Part 3


Brainstorming is a useful technique for generating many ideas or options for a

given topic or problem. It encourages spontaneous, free-flowing thought — the

evaluation can come later. To brainstorm:

1.	Establish a time limit (10-15 minutes) and explain the issue or problem

2.	Each person thinks up as many solution ideas as possible and shares them
with the group. To maximize creativity, don't worry about whether the ideas
are practical or not

3.	All ideas are recorded on paper, without discussion or evaluation or their
merit or usefulness

4.	The speaker may clarify any quick questions about an idea as long as there is
no further discussion

5.	When it seems that all ideas have been proposed (i.e.. when there is a long
silence), check with the group to make sure it is ume to stop. However, don't
be too hastv about this




Hot the new material been


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or other andBary equipment
"-ฆ'y.i be required? , :
wnov uopuiiiiMiHi ana oraoi . j	v.-^l <

wU be affected?	/Describe any training or procedure-

.v changes that are requbed

ป/ WW1 production be affected?

/Describe any material-testing
Will product quality be affected? program that wW be required


Is the equipment commercially
f available?

. Is performance information
'' available?

Win modifications to work flow or
production procedures be required?




yWhat operator and maintenance
training will be required?

y Describe catalyst, chemical,
replacement parts, or other supplies

/ What facility and product constraints / Does the option meet government

* o


>/ How Is service handled?

Is scaleup information available?

Is testing required?

Will utility requirements change?

What are the estimated deUvery and .
x' Installation times?	y'

What warranties are offered?

v/ Will production be affected?

/ What will be the estimated
production downtime?

Will product quality be affected?

/Describe any additional storage or


materials-handling requirements

y Describe any additional laboratory or
analytical requirements

earlier presence or" accounting and fi-
nancial people on the pollution-preven-
tion team (Table 1) becomes particular-
ly beneficial.

Every company has its own economic
criteria against which a proposal is
judged. For this purpose, capital-cost
information along the lines shown in
the upper part of Figure 2 is collected,
as well as data on incremental operat-
ing costs and revenues as shown in the
lower part of the figure.

If the project does not have a signifi-
cant capital cost, the decision as to
whether to implement can be made on
the basis of whether an operating cost
savings occurs or not. If significant
capital costs are involved, a more de-
tailed financial analysis may be re-
quired. The American Institute for Pol-
lution Prevention (headquartered at
the University of Cincinnati. Cincinnati,
Ohio) is currently preparing a "Practi-
cal Guide on Pollution Prevention Eco-
nomics" that discusses the use of eco-
nomic-evaluation tools.

This overall approach, involving peo-
ple from a broad range of activities, not
only generates creative solutions to pol-
lution problems. It also smoothes the
way for adopting the chosen solutions.!

Edited by Nicholas P. Chopey

The Author

Robert B. Pojasek is a Vicer
President of CEI Consultants,

Inc., 1021 Main Street.

Winchester, MA 01890, (617)

721-4000, Fax. (617) 721-4073,
where he directs the firm's
corporate environmental
programs. Currently Chair
of the Amencan Institute for
Pollution Prevention, he is
associated with numerous
advisory boards related to 1
environmental technology. He teaches a course
in pollution prevention at Tufts U. His own
education includes a B.A. in Chemistry from
Rutgers U. and a Ph.D. in the same sub|ect
from the U. of Massachusetts.


L. U.S. Environmental Protection Agency.
"Waste Opportunities Assessment Manual/'
Publication No. 625/7-88/003. Cincinnati. 1988.

2.	Pojasek. R.B.. Pollution Prevention Progres-
sion. in Rothenberg. Eric B. andTelego. Dean J.
(eda.). "Environmental Risk Management - A
Desk Reference.' RTM Communicauons. 1991

3.	Pojasek, R.B., Waste Reduction Audits, in
Rothenberg and Telego. op. ciL

4 Pojasek. R.B. and Cali. LJ.. Contrasting Ap-
proaches to Pollution Prevention Auditing. Pol-
lution Prevention Review, Vol. 1. No. 3 (In

5. von Oech. Roger, " A Whack on the Side of the
Head," Warner Books, New York. 1990.



Toxiwastellution Reducimization

"The proactive prevention of wastes otherwise not
eliminated by comprehensive reduction strategies
which are targeted for chemical releases affecting
multi-media pollution nonetheless recycled for recovery
thereby resulting in the minimization of toxic uses
applied at any time and/or any place."

Roger Schecter

North Carolina Pollution Prevention Pays Program

Saving Money

Would you like to reduce your company's operating
budget, with little or no capital investment?

If you said yes, this brochure is for you It is
designed for the businessman — large or small —
who thinks waste reduction makes sense in general,
but wants more specific information The basic steps
of setting up a waste reduction program are
outlined Such a program can help you save money,
enhance your image, and reduce your liability

What Is Waste Reduction?

Waste reduction is nothing more than a common
sense approach to managing your resources There
are many synonyms for waste reduction including
source reduction, recycling, and waste minimization
|The definitions in the box inside this brochure
should help you put these terms in perspective) No
matter what the term is, the philosophy is the same
—reduce the quantity of waste at its source

A Serious Problem

The problem is B-l-G Officials estimate that 275
million metric tons (MMTs) of hazardous waste—
that is, waste which can catch fire, explode, corrode,
or is toxic—are regulated under the Resource
Recovery and Conservation Act (RCRA) Wastes of all
kinas may amount to nearly one billion MMTs a

Equally staggering is the breadth of the problem
Nearly every commercial establishment, industry and
household produces waste which can be reduced

Why Worry About
Waste Reduction?

There are a number of obvious incentives for waste
reduction, including

reducing cost of raw materials

i*" reducing costly treatment schemes

reducing disposal costs

reducing liability claims for improper

enhancing your public image

What's In A Name?

Waste reduction is defined as in-plant
practices that reduce, avoid, or eliminate the
generation of hazardous or other wastes so as
to reduce risks to health and environment
Actions taken away from the waste generating
activity |e g„ recycling) are not considered
waste reduction

Source reduction is defined as the reduction
or elimination of waste at the source, usually
within a process Source reduction measures
include some types of treatment processes,
process modifications, input material
substitutions, and various good-housekeeping

Waste minimization is defined as the
reduction of hazardous waste that is generated
or subsequently treated, stored, or disposed It
includes any source reduction or recycling
activity intended to reduce the volume or
toxicity of hazardous waste.

Set Up The Program

ป Obtain management support.

ซ• Set goals and objectives for the assessment-

Staff The Program

ปฆ Identify someone familar with waste reduction,
and your facility, to coordinate the program.

Staff the project with knowledgeable people from
affected departments.

Spread The Word

Incorporate waste reduction goals into all
company programs.

" Get employees involved by developing incentives
for participation.

A Waste Reduction Flow Chart

Establish a commitment tolreduce wastes at the source

One Step At A Time

Once you decide waste reduction is worthwhile, you
need to follow a series of logical steps in
implementing a program First, make sure there is a
genuine commitment to waste reduction Next,
gather all background data Finally, develop a waste
reduction plan that makes sense for your
organization. (Details on how to set up an effective
program are presented in this flowchart)

Do Your Homework

Lay The Groundwork


.ฆi —.


Implement Your Plan


Identify The Problem

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'liU^jtoalilIiti)ix4iEXiU' •

Re-evaluate previous options

•ป Assemble design information on process flow

diagrams, piping and instrumentation diagrams,

equipment lists, specifications, and operating


ป Acquire environmental information

such as multimedia waste inventories, hazardous

waste manifests, compliance reports, and permits.

b Collect raw material and product information.

ฐ Obtain economic information such as product,

utility, and raw material costs; waste treatment

and disposal costs; etc.

ฆ Gather any other necessary information.

Some Success Stories

Stories of successful waste reduction programs abound

~	A leading chemical company established a program in 1987 that reduced waste generated at the company's
facilities by more than 100,000 tons — saving an estimated S250 million

~	A Texas chemical manufacturer of a nylon intermediate (adiponitrile) developed a new process that improves
product yield, cuts the amount of wastewater generated in half, and saves S10 million a year

~	A company that makes furnaces recovered calcium fluoride from its sludge — saving over $170,000 per year

~	A Pennsylvania die manufacturer used a solvent recovery unit to reclaim 1,1,1-trichloroethane, which was then
used as a degreasing agent, producing a savings of nearly $5,000 per year

The range of savings in these programs highlights the fact that waste reduction can work in businesses of all sizes
and shapes

3M Corporation
Saint Paul, MN

Stanley Furniture
Stanleytown, VA

The Cooper Tool Group
Lufkin Division
Apex, NC



2 —3 years



(over past 1 2 years)

The company uses a life cycle
approach to reducing the
amount of hazardous wasle
generated Over the last 12
years the program has involved
over 2,200 individual protects
— including product reform-
ulation, process modification,
equipment redesign, house-
keeping, and recycling


0 51%

5 weeks



This modification of the
company's tray booth spraying
system allows them to mix the
sludge with wood chips, put
them in hazardous waste bags,
and burn them. They use the
fuel, or sell it



5 weeks



The company modified their
manufacturing process to re-
cover nickel from their process

Working For Common Goals

Waste reduction is one area where national
environmental goals and industry's economic
interests clearly coincide For generators, the benefits
include saving money, lessening liabilities, and
easing hazardous waste management regulatory
burdens For the general public, waste minimization
pays off in the most important way of all — an
improved environment

For More Information

For more details on waste reduction contact your
local wastewater treatment facility. Department of
Public Works, Sanitation District or State Waste
Minimization program

Or, contact

Water Pollution Control Federation
601 \X/ythe Street
Alexandria. VA 22314-1994

(703) 684-2400

Direct inquiries to the Public Education department

M)ฉ (rm lr<ง]ฉ$ฉzy

An Interactive Exercise for Waste Reduction Training

Delivered Spring 1991 by
The University of Tennessee, Center for Industrial Services
Waste Reduction Assistance Program
226 Capitol Boulevard Bldg, Suite 401
Nashville, Tennessee 37219
phone 615-242-4816

Developed by WRITAR (Waste Reduction Institute for Training and Application Research. Inc.)

completed February, 1991 by Thad Schifsky


Public policy staff in regulatory and/or policy-making positions are in an importr
position. They can influence waste generators in industry to adopt methods of
environmental protection. This outlines an exercise which can heighten public policy staffs'
awareness of how waste is produced and how it can be reduced. At the same time, this
exercise will provide participants with a sense of what it's like to work in an industrial setting
and to use group problem solving techniques.

The instructions here show the exercise facilitator, in a step-by-step, fashion how to
take a group through the Play-Doh Fun Factory exercise. Also included is a "Principles of
Operation" section explaining how we developed this exercise, what our basic ideas are
behind the exercise, and how we expect participants will benefit from the exercise. We
have also included a section defining participant roles, as well as a list of equipment and
materials needed.

Principles of Operation

Nearly all training to date in waste minimization has been based on lectures and
case studies, all of which are more properly termed education. Training to date has been
given a lessor priority because the information to conduct training has not been available.

Our early training attempts at verbal role play and small group discussions while
useful, did not prove as powerful, successful, and flexible as the Fun Factory training
exercise. It's a fun exercise and we believe that people who have fun while learning
more likely to retain what they've learned. We are employing the principle that hands-on
training allows trainees to become participants rather than observers. People would rather
have the actual tools to work with rather than reflecting on concepts.

We determined that the regulatory audience who will participate in this exercise may
not be familiar with what it is like to function in an industrial setting. Because of this, we
wanted to construct an exercise to give these participants a good sense of how a
business operates day-to-day. By participating in this exercise, they will also acquire a
sense of how waste is generated and subsequently learn to recognize processes that
create waste. Finally, with their enhanced sense of an industrial setting and knowledge of
how waste is generated, we believe these participants will be more effective in promoting
waste minimization in their respective positions.


To motivate audiences to promote, persuade and encourage waste minimization
by taking them through a mock industrial process. This mock process is intended to
heighten the participants' awareness of the importance of communication in waste
minimization efforts. In addition, it is intended to help participants become more awe
sources of waste, options for waste minimization/and resistance to change.


We have several objectives in mind for this exercise. One is to help participants not
familiar with industrial processes to understand these processes. Another is to help
participants understand the challenges and frustrations of reducing waste in all industrial
settings. A related objective is to show the participants that by taking part in this exercise,
they may find their previous understanding of waste reduction and its implementation has
little in common with the reality of waste reduction in an industrial setting. Our final objective is
to help participants become aware of the importance of communication in waste
reduction efforts and to become aware of some of the many factors that make it difficult to
actually implement waste minimization, such as labor relations, customer demands, and

Pnrticipant roles —An ideal size for the group of participant is 20 people.

Facilitator Role—The Facilitator would be ideally filled by a person who is
comfortable with taking charge and leading a group of people through'an exercise.

Since the successful completion of this exercise depends on a high level of interaction
among the participants, the Facilitator should also be adept at promoting this interaction
by his/her own example.

Customer—The facilitator takes on the role of the Customer after the Play-Doh
machines are handed out. The Customer's role is to place orders, create pressure,
demand quality, and generally harass the teams with the goal of creating an atmosphere
of good natured chaos. The Customer's job begins with circulating to each team and
placing the first order with each "Big Boss." After the teams have begun working, the
Customer begins requesting sample parts from each team and inspects their quality. While
inspecting each team's product, the Customer mentions how well their competition is
performing. The Customer continues to inspect each team's product, mentions the
competition's performance, and how important the job is to their company throughout the
exercise. Write the following titles and role descriptions on index cards.

Boss—Keep your back to the process at all times. Everything is always late. You only
care about the bottom line. Your links to your team are trough Quality Control and the
Production Manager, communicate to your team through them.

Production Manager—The Techs are lazy, QC is crazy, and the Boss is on your case.
You can look at the process once every five minutes. Get those parts out now!

Quality Control (QC)—Everyone wants to slip something by you. Watch those Techs
carefully. You're the only guardian of the company's good name. If it's no good by you, it's
no good.

Technician (Tech.) (Two Techs per team)—You are underpaid and overworked.

Only you understand the process. If only management could get organized! Don't let
them push you around.

RCRA Inspector (Optional')— You know that every facility has something to hide anr*
your job is to find it. The paper work is never filled out right, their records are never whe
they're supposed to . e, and all the labels are upside down.


1.	Assemble attendees into teams of five and seat them around the "production floor" (see
Materials Needed, pg. 5)

2.	Assign a city or county name to each team for identification, and write the team names
on a flip chart or chalk board

3.	Explain to the teams that they are in competition with each other to produce a critical
"part" for the military, and they will produce this part from Play-Doh using the Fun Factory
machine. Tell them that since this is work for a defense contract, the parts have to be made
to exacting standards.

4.	Explain that red Play-Doh is a toxic metal*, yellow Play-Doh is toxic because of volatile or
organic air (emissions', and blue and white Play-Doh is non-toxic. Explain that if toxic Play-
Doh is mixed with non-toxic, the part is contaminated and considered waste. Write these
specifications on the flip chart for the players' reference.

5.	Explain that anything that is contaminated or isn't a finished product is considered waste,
therefore it can't be recycled and should be placed in a waste pile.

6.	Assign roles by handing out the index cards (see Materials Needed, pg. 5, and
Participant Roles, pg. 3). Roles can be assigned arbitrarily. Any extra people can be

7.	Hand out Fun Factory machines and Play-Doh. Caution teams not to start until you tell
them. Tell teams they will have 90 minutes to complete the exercise, after which there will
be a 30-minute assessment and then a second 90 minute exercise. A half-hour break can
be inserted in the exercise.

8.	Tell the teams that you are the Customer, and that you will order only through the Big

9.	Tell the teams to open up the machines. This may distract them them a short time, so
pause with your instructions.

10.	Give the teams the first order to make 10 blue stars with a thickness comparable to the
lid of the Play-Doh can. Explain that the parts are to be extruded with the machine, not
molded by hand. Tell teams that the finished parts should be smooth on both sides, and
contain no mixed colors. Write the order and specifications on the flip chart.

11.	Check on each team's progress. Begin quality control at this time, checking for parts tha
are not smooth or are shaped badly.

12.	When any team is near completion of the first order begin placing the second or
10 white stars with the same thickness of the blue stars. Be careful not to tip-off nearby ,
about the content of this and future orders.

13.	Place the third (10 blue rectangles) and fourth (10 red ropes) orders with all teams when
any one team is close to completion of the second order. Tell them the rectangles should
be made the smallest possible, with the same thinness as the stars. The ropes should be
made as long as an index card is wide.

14.	Continue checking for parts that are not smooth or are shaped badly, and begin
inspecting parts for streaks of color resulting from sloppy color changes.

15.	Remind the teams that they are in competition with each other. Since teams will work at
different speeds, tell them you might have to pull the job from one team and give it to

16.	At 90 minutes, tell the teams to stop, collect and segregate the parts and waste, and
clean their machines. Determine who finished first. Inspect each team's finished parts for
conformity to the standards of smoothness and shape and inspect each teams' waste
piles and note the amount of waste generated. You may wish to weigh each teams with
with a small scale to determine which team generated the most waste.

17.	Ask the teams to appoint a group spokesperson among themselves, and begin the
discussion. Write responses on flip chart. Ask them what they think is wrong with the exercise
as an industrial process (process analysis). Next ask what they would change and why
(options generation). Then ask each team what is the first thing they would modify and why
(implementation). Lastly point out the insights they have gained from the exercise,
examples of insights include;

1.	How this exercise can help participants not familiar with the process understand the
complexities of waste reduction in an industrial setting.

2.	All waste reduction ideas derived from this exercise came from the participants,
which is often the case, or should be, in real industrial facilities.

3.	A sense of how waste is actually generated, which will help participants to at least
promote waste reduction ideas.

18.	Begin the exercise again and have everybody implement what they've learned.

19.	Clean up.

List of Equipment and Materials Needed

1. Play-Doh Fun Factories

2	. Supplemental supply of Piay-Doh

3	. Flip chart or black board

4	. 24" x 36" sheets of white paper (often removed from a flip chart) for "production floor"

5	. Packet of 3" x 5" index cards

6	. Felt-tip markers for flip chart

7	. Chalk and erasers for blackboard

*Disclaimer: Although some colors are described as being hazardous materials and wastes, the props are
shape, or form hazardous. This is a mock industrial process demonstration for training purposes.

Play-Doh Fun Factory Assessment Worksheet






V Management

V Management

V Management

Management	y Management

Waste Management

E = Emit to the Environment
A/D = Accumulate and Dispose
R = Recycle

D = Discharge to Surface Water/Sewer

What is Pollution Prevention?
Waste Management Options

Method	Example Activities	Example Applications

• Stabilization

• Neutralization

• Precipitation


• Evaporation

• Incineration

• Scrubbing

Thermal Destruction
of Organic Solvent
ฆ Precipitation of Heavy
Metal From a Spent
Plating Bath

•	Reuse

•	Reclamation

Solvent Recycling
Metal Recovery From
a Spent Plating Bath
Volatile Organic

Friendly Design
of New Products
Product Changes
Source Elimination

Modify Product to
Avoid Solvent Use
Modify Product to
Extend Coating Life




26 West Martin Luther King Drive
Cincinnati, Ohio 45268
VOICE: (513) 569-7562
FAX: (513) 569-7566













E PA/625/7-90/004
E PA/625/7-90/005



Please send the above guides to me at the following address:





Moving to Pollution Prevention Audits in the 1990'$

"We must learn not just to control
pollution but to prevent it, not just to
dispose of waste more safely but to
eliminate it altogether."

William K. Reilly
Administrator, U.S. EPA

Federal Government's
Role in Pollution

Eiiviiunmcntal Auditing
Policy Statement

Federal Register

July 9,1986

Part IV

Protection Agency

40 CFH Rait 373

Reporting Hazardous Substance Activity
Whan Sailing or Transferring Federal
Real Property; Final Rule

What is the Purpose of the

Encourage environmental auditing for all regulated

Ensure consistent EPA responses

Clarify EPA's policy on requests for audit reports, etc.

What is the Environmental
Auditing Policy Statement s

•	Definition

•	Encouragement

•	Requests for reports

•	Inspections and enforcement

•	Federal facilities

•	State and local roles

•	Elements of auditing


What is EPfl s Definition of
Environmental Auditing?

A Review




+ Ot





—To Assure—








Audits Can Accomplish Any
or All of the Following:

Verify environmental compliance

Evaluate the effectiveness of environmental
management system

Assess risks from regulated and unregulated practices
Identify pollution prevention opportunities

Levels of Environmental

Pollution Prevention Audits: The "Fourth Dimension"

What is EPA's Policy on
Requests for Audit Reports?

.EPA will not routinely request audit reports."

.exercised on a case-by-case basis..."

.and where the information needed cannot be
obtained from...data otherwise available..."

What is EPfi's fludit Policy
for Federal Agencies

Encourages all Federal agencies to institute
environmental auditing programs

Same policy as toward private firms

EPA will provide technical assistance to design programs

Possible Interagency agreements

I . 'ZWhat is EPfi's fiadit Policy
, / for Federal Agencies


•	EPA encourages Federal agencies to submit findings with
action plans to EPA

•	Report needed projects through the A-106 process

•	EPA may coordinate with agencies on public release of

•	FOIA policies govern requests for audit information



Summary of Federal Agency
Environmental Auditing

Partial Program

No Program


Program Under


V * Current as of end of FY 1987

35 Agencies

"7Summary off Federal figency
/ Environmental ficiditing

19 agencies have no auditing program

Agriculture Dept.
U.S. Navy
U.S. Coast Guard


Food & Drug Admin.
Bureau of the Mint
Bureau of Printing
& Engraving

U.S. Army
U.S. Air Force
Defense Logistics

[7 I I Partial Program	I I Comprehensive

[71 1 Under Development I I No Auditing Program

EPA Assistance to Federal

1984: Environmental Auditing Conference for Federal

1985: Workshop for U.S. Army

1987: Report on Federal Agency Auditing Activities

1988: Second Environmental Auditing Conference for
Federal Agencies

1989: Audit Program Design Guidelines and Generic
Audit Protocols

1990- Pollution Prevention Audit Wrokshops for Federal
1992: Facilities

Elements of Effective
Environmental Auditing

•	Management support

•	Auditor independence

•	Staffing and training

•	Written procedures

•	Gathering audit evidence

•	Written reports

•	Quality assurance

Types of Foliation
Prevention Audits

Waste minimization audits
Waste reduction audits
Waste minimization opportunity assessments
Pollution prevention opportunity assessments
Energy audits



Waste Redaction flkidit


Waste Redactions

•	Good operating practices

•	Material substitutions

•	Product reformulations

•	Equipment changes

•	Process changes

Waste Redactions

•	Good operating practices

•	Material substitutions

•	Product reformulations

•	Equipment changes

•	Process changes

EPfi'S Chemical Safety
Audit Program

Primary Goals of Onsite Audits:

•	To understand the problems and successful
practices/technologies for preventing and
mitigating chemical accidents

•	Heighten awareness of the need for chemical
safety among facilities and their neighbors in
the community




Waste Minimization
Opportunity Assessment Manual

Hazardous Waste Engineering Research Laboratory
Office of Research and Development
U.S Environmental Protection Agency
Cincinnati. Ohio 45268


This report has been reviewed by the Hazardous Waste Engineering Research
Laboratory, U.S. Environmental Protection Agency, and approved for publication.
Approval does not signify that the contents necessarily reflect the views and policies of
the U.S. Environmental Protection Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.

Users are encouraged to duplicate those portions of the manual as needed to implement
a waste minimization program. Organizations interested in publishing and distributing the
entire manual should contact the Alternative Technologies Division, Hazardous Waste
Engineering Research Laboratory. U.S. Environmental Protection Agency. Cincinnati.
Ohio 45268, to obtain a reproducible master.



The term, 'waste minimization" is heard increasingly at meetings and conferences of
individuals working in the field of hazardous waste management. Waste minimization is an
umbrella term that includes the first two categories of the EPA's preferred hazardous
waste management strategy which is shown below:

1.	Source Reduction: Reduce the amount of waste at the source, through changes in
industrial processes.

2.	Recycling: Reuse and recycle wastes for the original or some other purpose, such
as materials recovery or energy production.

3.	Incineration/Treatment: Destroy, detoxify, and neutralize wastes into less harmful

4.	Secure Land Disposal: Deposit wastes on land using volume reduction,
encapsulation, leachate containment, monitoring, and controlled air and
surface/subsurface waste releases.

In carrying out its program to encourage the adoption of waste minimization, the
Hazardous Waste Engineering Research Laboratory has supported the development of a
recommended procedure for identifying waste minimization applications. This manual
describes that procedure and will be of interest to those responsible for reducing waste
streams, and to those interested in learning about waste minimization in general.












Planning and Organization



Assessment Phase



Feasibility Analysis



Implementing Waste Minimization Options



A.	Waste Minimization Assessment Worksheets	A-1

B.	Simplified Waste Minimization Assessment Worksheets	B-1

C.	Example Waste Minimization Assessment	C-1

D.	Causes and Sources of Waste	D-1

E.	Waste Minimization Techniques	E-1

F.	Government Technical/Financial Assistance Programs	F-1

G.	Option Rating: Weighted Sum Method	G-1

H.	Economic Evaluation Example	H-1


List of Worksheets


Appendix A

1.	Assessment Overview	A-3

2.	Program Organization	A-4

3.	Assessment Team Make-up	A-5

4.	Site Description	A-6

5.	Personnel	A-7

6.	Process Information	A-8

7.	Input Materials Summary	A-9

8.	Products Summary	A-10

9.	Individual Waste Stream Characterization	A-11

10.	Waste Stream Summary	A-15

11.	Option Generation	A-16

12.	Option Description	A-17

13.	Options Evaluation by Weighted Sum Method	A-18

14.	Technical Feasibility	A-19

15.	Cost Information	A-25

16.	Profitability Worksheet #1: Payback Period	A-31

17.	Profitability Worksheet #2: Cash Flow for NPV and IRR	A-32

18.	Project Summary	A-33

19.	Option Performance	A-34
Appendix B

Si. Assessment Overview	B-2

S2 Site Description	8-3

53.	Process Information	B-4

54.	Input Materials Summary	B-5

55.	Products Summary	B-6

56.	Waste Stream Summary	B-7

57.	Option Generation	B-8

58.	Option Description	B-9

59.	Profitability	B-10



The following people are members of the ad
comments and insights to the preparation of fr

Denny J. Beroiz

General Dynamics Pomona Division
Elaine Eby

Office of Solid Waste
US Environmental Protection Agency

John Frick, PhD

Directorate of Supply Operations
Defense Logistics Agency

Kevin Gashlin

Hazardous Waste Assistance Program

New Jersey Department of Environmental Protection

Gregory J. Hollod, PhD
Petrochemicals Department
E.I. DuPont de Nemours & Co.

Gary Hunt

Pollution Prevention Pays Program

North Carolina Department of Environmental


John S. Hunter, III, PhD
3M Corporation

sory committee that contributed valuable

Michael Overcash, PhD
Department of Chemical Engineering
North Carolina State University

Robert Pojasek, PhD
ChemCycle Corporation

Dennis Redington
Monsanto Co

Michael E. Resch

Waste Disposal Engineering Division
US Army Environmental Hygiene Agency

Jack Towers

Waste Reduction Services
Chemical Waste Management

David Wigglesworth

Waste Reduction Assistance Program

Alaska Health Project

Kathleen Wolf, PhD

Source Reduction Research Partnership

Harry M. Freeman of the U.S. Environmental Protection Agency, Office of Research and
Development, Hazardous Waste Engineering Research Laboratory, was the project
officer responsible for the preparation of this manual. Special acknowledgment is given to
Myles Morse of the U.S. Environmental Protection Agency, Office of Solid Waste, for his
assistance and comments. James Lounsbury and Roger Schecter of the EPA Office of
Solid Waste are also acknowledged for their assistance in the preparation of this manual.

This manual was developed by the Hazardous and Toxic Materials Division of Jacobs
Engineering Group as a subcontractor to Versar, Inc. Marvin Drabkin was the project
manager for Versar. Participating in the preparation of this manual for Jacobs were
Gregory A. Lorton. Carl H. Fromm. Michael P. Meltzer, Deborah A. Hanlon, Sally
Lawrence, Michael S. Callahan, and Srinivas Budaraju.


Section 1

Waste minimization (WM) has been successful for
many organizations. By following the procedures
outlined in this manual, a waste generator can:

•	Save money by reducing waste treatment and
disposal costs, raw material purchases, and other
operating costs.

•	Meet state and national waste minimization policy

•	Reduce potential environmental liabilities.

•	Protect public health and worker health and safety.

•	Protect the environment.

Waste minimization is a policy specifically mandated by
the U. S. Congress in the 1964 Hazardous and Solid
Wastes Amendments to the Resource Conservation
and Recovery Act (RCRA). This mandate, coupled
with other RCRA provisions that have led to
unprecedented increases in the costs of waste
management, have heightened general interest in
waste minimization. A strong contributing factor has
been a desire on the part of generators to reduce their
environmental impairment liabilities under the
provisions of the Comprehensive Environmental
Response, Compensation, and Liabilities Act
(CERCLA, or "Superfund"). Because of these
increasing costs and liability exposure, waste
minimization has become more and more attractive

The following terms, used throughout this manual, are
defined below:

Waste Minimization fWM) In the working definition
currently used by EPA, waste minimization consists of
source reduction and recycling. This concept of waste
minimization is presented In Figure 1-1. Of the two
approaches, source reduction is usually preferable to
recycling from an environmental perspective. Source
reduction and recycling each are comprised of a
number of practices and approaches which are
illustrated in Figure 1-2.

The present focus of WM activities is on hazardous
wastes, as defined in RCRA. However, it is important
that all pollutant emissions into air, water and land be
considered as part of a waste minimization program.
The transfer of pollutants from one medium to another

is not waste minimization. For example, the removal of
organics from wastewater using activated carbon, in
and of itself, is not waste minimization, since the
pollutants are merely transferred from one medium
(wastewater) to another (carbon, as solid waste).

Waste minimization ornnram fWMP). The RCRA
regulations require that generators of hazardous waste
"have a program in place to reduce the volume and
toxicity of waste generated to the extent that is
economically practical." A waste minimization program
is an organized, comprehensive, and continual effort
to systematically reduce waste generation. Generally,
a program is established for the organization as a
whole. Its components may include specific waste
minimization projects and may use waste minimization
assessments as a tool for determining where and how
waste can be reduced. A waste minimization program
should reflect the goals and policies for waste
minimization set by the organization's management.
Also, the program should be an ongoing effort and
should strive to make waste minimization part of the
company's operating philosophy. While the main goal
of a waste minimization program is to reduce or
eliminate waste, it may also bring about an
improvement in a company's production efficiency.

EPA will publish separate guidance on the elements
of effective waste minimization programs. This
guidance will discuss the following elements likely to
be found in an effective WM program:

•	Top management support

•	Explicit program scope and objectives

•	Accurate waste accounting

•	Accurate cost accounting

•	Pervasive waste minimization philosophy

•	Technology transfer

Waste minimization assessment fWMA). A waste
minimization assessment is a systematic planned
procedure with the objective of identifying ways to
reduce or eliminate waste. The steps involved in
conducting a waste minimization assessment are
outlined in Figure 1-3. The assessment consists of a
careful review of a plant's operations and waste
streams, and the selection of specific areas to assess.
After a specific waste stream or area is established as
the WMA focus, a number of options with the potential
to minimize waste are developed and screened. Third,
the technical and economic feasibility of the selected
options are evaluated. Finally, the most promising
options are selected for implementation.











The reduction, to the extant feasible, of hazardous wast* that la generated or subsequently treated, stored or
disposed of. It includes any source reduction or recycling activity undertaken by a generator that results in
either (1) the reduction of total volume or quantity of hazardous waste or (2) the reduction of toxicity of the
hazardous waste, or both, so long as such reduction is consistent with the goal of minimizing present and
future threats to human heafth and the environment (EPA*s Report to Congress, 1986, EPA/530-SW-86-C33).


Any aetMty that reduces or eliminates the generation of hazardous waste at the source, usually within a
process (op. dt).


A material is "recycled" V tt is used, reused, or reclaimed (40 CFR 261.1 (c) (7)). A materia) is "used or reused"
tf it is either (1) employed as an ingredient (inducting its use as an intermediate) to make a product; however a
material wfll not satisfy this condition H distinct components of the material are recovered as separate end
products (as when metals are recovered from metal containing secondary materials) or (2) employed in a
particular function as an effective substitute for a commercial product (40 CFR 261.1 (c) (5)). A material is
"reclaimed" I It is processed to recover a useful product or if It is regenerated. Examples indude the recovery
of lead values from spent batteries and the regeneration of spent solvents (40 CFR 261.1 (c) (4)).

Figure 1-1. Waste Minimization Definitions






• Product substitution

-	Product conservation

-	Changs In product

com position



• Return to original process
ฆ Raw material substitute
for another process


• Processed for

resource recovery
- Processed as a


-	Material purification

-	Material substitution


Process changes
Equipment, piping, or

layout changes
Additional automation
Changes in operational


' Procedural measures
- Loss prevention
' Management practices
• Waste stream segregation
Material handling
Production scheduling

Figure 1-2. Waste Minimization Techniques

Figure 1-3. The Wast* Mlnlmlzatlen AiMunwnt Procedure

The recognized need to minimize wast*



•	Gat management commitment

•	Sat ovaraD aasaaamant program goals

•	Organize asaassmant program taak fore*

Aaaaaamant organization
and commitmant to i

mizatkin I
• proceed*


•	Collect prooaas and factty *****

•	Prioritize and aalact aaaaaamant targata

•	Salad paopla lor aaaaaamant taama

•	Raviaw data and impact aita

•	Ganarata options

•	Screen and aalact optiona for furthar atudy

Aaaaaamant raport of
selected options


Saltrt naw
imant targata
and reevaluate
previous optiona


•	Technical evaluation

•	Economic evaluation

•	Select optiona for implementation

Final report, including
recommended optiona



•	JuatHy projects and obtain funding

•	Installation (equipment)

•	Implementation (procedure)

•	Evaluate performanoe

Repeat the prooees ^


Successfully implemented
waata minimization projects


Incentives for Waste Minimization

There are a number of compelling incentives for
minimizing waste. Table 1-1 summarizes some of
these incentives.

Table 1-1. Wast* Minimization Inoantlvaa



•	Landfill disposal cost increases.

•	Costfy alternative treatment technologies.

•	Savings in raw material and manufacturing costs.

•	Certification of a WM program on the hazardous waste

•	Biennial WM program reporting.

•	Land disposal restrictions and bans.

•	Increasing permitting requirements for wast* handling
and treatment.


•	Potential reduction in generator liability for environmental
problems at both onsite and oft site treatment, storage,
and disposal facilities.

•	Potential reduction m BabiDty for worker safety.

PubBc Image and Environmental Concern

•	Improved 'mage in the community and from employees.

•	Concern for improving the environment

EPA intends to publish a manual entitled "Waste
Minimization Benefits Handbook" which will discuss in
detail the cost/benefit analyses of WM options.

About this manual

This manual has been prepared for those responsible
for planning, managing, and implementing waste
minimization activities at the plant and corporate levels.
The manual concentrates on procedures that motivate
people to search, screen, and put into practice
measures involving administrative, material, or
technology changes that result in decreased waste
generation. It is also a source of concepts and ideas
for developing and implementing a waste minimization

The manual Is organized as follows:

•	Section 2 outfines the planning and organizational
aspects that provide a necessary foundation for a
waste minimization assessment

•	Section 3 describes the assessment phase,
including collecting information, selecting
assessment targets, selecting assessment teams,
and identifying potential WM options.

•	Section 4 discusses the methods for evaluating
options for technical and economic feasibility.

• Section 5 descrfoes the implementation of attractive
options: obtaining funding, installation and
implementation, and measuring the effectiveness
of implemented options.

A set of worksheets useful in carrying out assessments
is included in Appendix A. Because individual
generators' circumstances and needs vary widely,
users of this manual are encouraged to modify the
procedures and worksheets to fit their unique
requirements. The manual is intended to serve as a
point of departure, rather than as a set of rigid
requirements. Accordingly, Appendix B presents a
simplified set of worksheets that are designed to assist
generators who are interested in performing only
preliminary assessments. These worksheets also
provide a useful framework for conducting
assessments for smalt businesses and small quantity

A sample assessment Is presented in Appendix C.
Appendix D describes waste streams from common
industrial operations. Appendix E is a catalog and brief
description of waste minimization techniques
applicable in a number of common waste-intensive
operations. Appendix F is a list of addresses and
telephone numbers of state programs for technical
assistance in waste minimization. Appendix G
presents describes a method for screening and rating
potential waste minimization options for further study.
Finally, an example of an economic feasibility analysis
of a large waste minimization project is presented in
Appendix H.


Section 2
Planning and Organization

The recognized need to minimize waste

Successfully implemented
waste minimization projects

This section discusses factors that are important to the
success of a waste minimization program. Because a
comprehensive WM program affects many functional
groups within a company, the program needs to bring
these different groups together to reduce wastes.
The formality of the program depends upon the size
and complexity of the organization and its waste
problems. The program structure must be flexible
enough to accommodate unforeseen changes. The
developmental activities of a WM program include:

•	getting management commitment

•	setting WM goals

•	staffing the program task force

Getting Management Commitment

The management of a company will support a waste
minimization program if It is convinced that the benefits
of such a program will outweigh the costs. The
potential benefits include economic advantages,
compliance with regulations, reduction in liabilities
associated with the generation of wastes, improved
public image, and reduced environmental impact

The objectives of a WM program are best conveyed to
a company's employees through a formal policy

statement or management directive. A compare'
upper management is responsible for establishing
formal commitment throughout all divisions of i
organization. The person in charge of the company ป
environmental affairs is responsible to advise
management of the importance of waste minimization
and the need for this formal commitment. An example
of a formal policy statement follows:


[A major chemical company]..."is committed to continue
excellence, leadership, and stewardship in protecting the
environment. Environmental protection is a primary
management rasponsibiBty, as well as the responsibility of
•very employee. .

In keeping with this poficy, our objective as a oompany is to
reduce waste and achieve minimal adverse impact on the air,
water, and land through excellenoe in environmental oontroL

The Environmental GuideRnes include the following points:

•	Environmental protection is a line responsibility and an
important measure of employee performance. In addi-
tion, every employee is responsible for environmental
protection in the same manner he or she is for safety.

•	Minimizing or eliminating the generation of waste hr~
been and continues to be a prime consideration
research, process design, and plant operations; ad
viewed by management like safety, yield, and h

•	Reuse and recycling of materials has been and will
continue to be given first consideration prior to
classification and disposal of waste."

Involve Employees

Although management commitment and direction are
fundamental to the success of a waste minimization
program, commitment throughout an organization is
necessary in order to resolve conflicts and to remove
barriers to the WM program. Employees often cause
the generation of waste, and they can contribute to the
overall success of the program. Bonuses, awards,
plaques, and other forms of recognition are often used
to provide motivation, and to boost employee
cooperation and participation. In some companies,
meeting the waste minimization goals is used as a
measure for evaluating the job performance of
managers and employees.


Cause Champions

Any WM program needs one or more people to
champion the cause. These "cause champions" help
overcome the inertia present when changes to an
existing operation are proposed. They also lead the
WM program, either formally or informally. An
environmental engineer, production manager, or plant
process engineer may be a good candidate for this
role. Regardless of who takes the lead, this cause
champion must be given enough authority to
effectively cany out the program.

Organizing a WM Program:
The Program Task Force

The WM program will affect a number of groups within a
company. For this reason, a program task force should
be assembled. This group should include members of
any group or department in the conpany that has a
significant interest in the outcome of the program.
Table 2-4 at the end of this section and Worksheet 3 in
Appendix A lists departments or groups of a typical
manufacturing company that should be involved in the

The formality or informality of the WM program will
depend on the nature of the company. The program in
a large highly structured company will probably
develop to be quite formal, in contrast to a small
company, or a company in a dynamic industry, where
the organizational structure changes frequently.

Table 2-1 lists the typical responsibilities of a WM
program task force. It will draw on expertise within the
company as required. The scope of the program wOl
determine whether full-time participation is required by
any of the team members.

Table 2-1. Responsibilities of the WM Program
Taak Force

•	Get commitment and a statement of policy from

•	Establish overall WM program goals.

•	Establish a waste tracking system.

•	Prioritize the waste streams or facility areas for

•	Select assessment teams.

•	Conduct (or supervise) assessments.

•	Conduct (or monitor) technical/economic feasibility
analyses erf favorable options.

•	Select and justify feasble options for implementation.

•	Obtain funding and establish schedule for

•	Monitor (and/or direct) implementation progress.

•	Monitor performance of the option, once it is operating.

In a small company, several people at most will be all
that are required to implement a WM program. Include
the people with responsibility for production, facilities,

maintenance, quality control, and waste treatment and
disposal on the team. It may be that a single person,
such as the plant manager, has all of these
responsibilities at a small facility. However, even at a
small facility, at least two people should be involved to
get a variety of viewpoints and perspectives.

Some larger companies have developed a system in
which assessment teams periodically visit different
facilities within the company. The benefits result
through sharing the ideas and experiences with other
divisions. Similar results can be achieved with periodic
in-house seminars, workshops, or meetings. A large
chemical manufacturer held a corporate-wide
symposium in 1986 dealing specifically with waste
minimization. The company has also developed other
programs to increase company-wide awareness of
waste minimization, including an internally published
newsletter and videotape.

Setting Goals

The first priority of the WM program task force is to
establish goals that are consistent with the policy
adopted by management. Waste minimization goals
can be qualitative, for example, "a significant reduction
of toxic substance emissions into the environment."
However, it is better to establish measurable,
quantifiable goals, since qualitative goals can be
interpreted ambiguously. Quantifiable goals establish
a clear guide as to the degree of sucess expected of
the program. A major chemical company has adopted a
corporate-wide goal of 5% waste reduction per year, in
addition, each facility within the company has set its
own waste minimization goals.

As part of its general poBcy on hazardous waste, a large
defense contractor has established an ambitious
corporate-wide goal of zero discharge of hazardous
wastes from its facilities by the end of 1988. Each
division within the corporation is given the
responsibility and freedom to develop its own program
(with intermediate goals) to meet this overall goal. This
has resulted in an extensive investigation of
procedures and technologies to accomplish source
reduction, recycling and resource recovery, and onsite

Table 2-2 lists the qualities that goals should possess.
It is important that the company's overall waste
minimization goals be incorporated into the appropriate
individual departmental goals.

The goals of the program should be reviewed
periodically. As the focus of the WM program becomes
more defined, the goals should be changed to reflect
any changes. Waste minimization assessments are not
intended to be a one-time project. Periodic
reevaluation of goals is recommended due to
changes, for example, in available technology, raw


Table 2-2. Attrlbu of Effsctlvs Goals

•	ACCEPTABLE to those who wffl work to achieve them.

•	FLEXIBLE and adaptable to changing requirements.

•	MEASURABLE over time.


•	SUITABLE to the overall corporate goals and mission.


•	ACHIEVABLE wfth a practical level of effort

Source: Pearee ind Robinson, Strafnic Management

material supplies, environmental regulations, and
economic climate.

Overcoming Barriers

As It sets goals for waste minimization and then defines
specific objectives that can be achieved, the program
task force should recognize potential barriers.
Although waste minimization projects can reduce
operating costs and improve environmental
compliance, they can lead to conflicts between
different groups within the company. Table 2-3 lists
examples of Jurisdictional conflicts that can arise during
the implementation of a waste minimization prpjecL

In addition to jurisdictional conflicts related to these
objective barriers, there are attitude-related barriers
that can disrupt a WM program. A commonly held
attitude is "If it alnl broke, donl fix it!" This attitude
stems from the desire to maintain the status quo and
avoid the unknown. It is also based on the fear that a
new WM option may not woik as advertised. Without
the commitment to carefully conceive and implement
the option, this attitude can become a self-fulfilling
prophecy. Management must declare that "It is broker

Another attitude-related barrier is the feeling that "It
just wont work!* This response is often given when a
person does not fully understand the nature of the
proposed option and its impact on operations. The
danger here is that promising options may be dropped
before they can be evaluated. One way to avoid this is
to use idea-generating sessions (e.g., brainstorming).
This encourages participants to propose a large
number of options, which are individually evaluated on
their merits.

An often-encountered barrier is the fear that the WM
option will diminish product quality. This is particularly
common in situations where unused feed materials are
recovered from the waste and then recycled back to
the process. The deterioration of product quality can
be a vaBd concern if unacceptable concentrations of
waste materials build up in the system. The best way to
allay this concern is to set up a small-scale
demonstration in the facility, or to observe the
particular option in operation at another facility.

Table 2-3. Examples of Barriers to Waate


•	A new operating procedure wOl reduce waate but may also
be a bottleneck that decreases this overall production

•	Production will be stopped while the new proฉ
equipment is installed.

•	A new piece of equipment has not been demonstrated in a
similar servioe. It may not woik here.


•	Adequate space it not available for the installation of new

•	Adequate utilities ere not available for the new

•	Engineering or construction manpower will not be
avaBabie in time to meet the project achedule.

•	Extensive maintenance may be required

QutBty Control

•	More intensive QC may be needed.

•	More rework may be required

Cttant Ralatiom/Maikating

•	Changes in product characteristics may affect customer


•	A program to reduce inventory (to avoid material
deterioration and reprocessing) may lead to stockouts
during high product demand


•	There is not enough money to fund the project


•	Existing atocka (or binding contracts) will delay
replacement of a hazardous material with a non-
hazardous substitute.


•	Accepting another plant's waate as a feedstock may
require a lengthy resolution of regulatory issues.

Waatป Tmatmnt

•	Use of a new nonhazardous raw material wBI adversely
impact the existing wastewater treatment facility.

Planning and Organization Summary

Table 2-4 provides a summary of the steps involved in
planning and organizing a waste minimization program.

Assessment Worksheets

Appendix A includes a set of worksheets for use in
planning and carrying out a waste minimization
assessment, and implementing the selected options.
Worksheet 1 summarizes the entire assessment
procedure. Worksheets 2 and 3 are used to record the
organization of the WM program task force and the


individual assessment teams, respectively. Worksheet
3 includes a list of functions and departments that
should be considered when organizing the
assessment teams.

Table 2-4. Planning and Organization Activities

Gat management commitment to:

•	Establish waste minimization as a company goal.

•	Establish a waste minimization program to meet this

•	goal

•	Give authority to the program task force to
implement this program.

Set overall goals for the program. These goals should be:

•	ACCEPTABLE to those who will work to achieve

•	FLEXIBLE to adapt to changing requirements.

•	MEASURABLE over time.


•	SUITABLE to the overall corporate goals.


•	ACHIEVABLE with a practical level of effort.


Find a 'cause champion", with the following attributes:

•	Familiar with the facility, its production processes,
and its waste management operations.

•	Familiar with the people.

•	Familiar with quality control requirements.

•	Good rapport with management

•	Familiar with new production and waste
management technology.

•	Familiar with WM principles and techniques, and
environmental regulations.

•	Aggressive managerial style.

Get people who know the facility, processes, and

Get people from the affected departments or groups.

•	Production.

•	Facilities/Maintenance.

•	Process Engineering.

•	Quality Control.

•	Environmental

•	Research and Development

•	Safety/Health.

•	Marketing/Client Relations.

•	Purchasing.

•	Material Control/Inventory.

•	Legal.

•	Finance/Accounting.

•	Information Systems.


Incorporate the company's WM goals into departmental

Solicit employee cooperation and participation.

Develop incentives and/or awards tor managers and


Section 3
Assessment Phase

The recognized need to minimize waste

* Planning and

What are the input materials used that generate t>
waste streams of a particular process or plant area

How much of a particular input material enters each
waste stream?

How much of a raw material can be accounted for
through fugitive losses?

Successfully implemented
waste minimization projects

The purpose of the assessment phase is to develop a
comprehensive set of waste minimization options, and
to identify the attractive options that deserve
additional, more detailed analysis. In order to develop
these WM options, a detailed understanding of the
plant's wastes and operations is required. The
assessment should begin by examining information
about the processes, operations, and waste
management practices at the facility.

Collecting and Compiling Data

The questions that this information gathering effort will
attempt to answer include the following:

•	What are the waste streams generated from the
plant? And how much?

•	Which processes or operations do these waste
streams come from?

•	Which wastes are classified as hazardous and which
are not? What makes them hazardous?

•	How efficient is the process?

•	Are unnecessary wastes generated by mixing
otherwise recyclable hazardous wastes with other
process wastes?

•	What types of housekeeping practices are used to
limit the quantity of wastes generated?

•	What types of process controls are used to improve
process efficiency?

Table 3-1 lists information that can be useful in
conducting the assessment. Reviewing this
information will provide important background for
understanding the plant's production and
maintenance processes and wBI allow priorities to be
determined. Worksheets 4 through 10 in Appendix A
can be used to record the information about sif-
characteristics, personnel, processes, input mated
products, and waste streams. Worksheets S2 throi
S6 in Appendix B are designed to record the sa...„
information, but in a more simplified approach.

Waste Stream Recordป

One of the first tasks of a waste minimization
assessment is to identify and characterize the facility
waste streams. Information about waste streams can
come from a variety of sources. Some information on
waste quantities is readily available from the completed
hazardous waste manifests, which include the
description and quantity of hazardous waste shipped
to a TSDF. The total amount of hazardous waste
shipped during a one-year period, for example, is a
convenient means of measuring waste generation and
waste reduction efforts. However, manifests often lack
such information as chemical analysis of the waste,
specific source of the waste, and the time period
during which the waste was generated. Also,
manifests do not cover wastewater effluents, air
emissions, or nonhazardous solid wastes.

Other sources of information on waste str earns include
biennial reports and NPDES (National Pollutant


Table 3-1. Facility Information for WM

Design Information

•	Process flow diagrams

•	Material and heat balances (both design balances and
actual balances) for

production processes
pollution pontrol processes

•	Operating manuals and process descriptions

•	Equipment lists

•	Equipment specifications and data sheets

•	Piping and instrument diagrams

•	Plot and elevation plans

•	Equipment layouts and work flow diagrams

Environmental Information

•	Hazardous waste manifests

•	Emission inventories

•	Biennial hazardous waste reports

•	Waste analyses

•	Environmental audit reports

•	Permits and/or permit applications

Raw Material/Production Information

•	Product composition and batch sheets

•	Material application diagrams

•	Material safety data sheets

•	Product and raw material inventory records

•	Operator data logs

•	Operating procedures

•	Production schedules

Economic Information

•	Waste treatment and disposal costs

•	Product, utility, and raw material costs

•	Operating and maintenance costs

•	Departmental cost accounting reports

Other Information

•	Company environmental policy statements

•	Standard procedures

•	Organization charts

Discharge Elimination System) monitoring reports.
These NPOES monitoring reports will include the
volume and constituents of wastewaters that are
discharged. Additionally, toxic substance release
inventories prepared under the "right to know"
provisions of SARA Title III, Section 313 (Supertund
Amendment and Reauthorization Act) may
providevaluable information on emissions into all
environmental media (land, water, and air).

Analytical test data available from previous waste
evaluations and routine sampling programs can be
helpful if the focus of the assessment is a particular
chemical within a waste stream.

Flow Diagrams and Material Balances

Row diagrams provide the basic means for identifying
and organizing information that is useful for the
assessment. Flow diagrams should be prepared to
identify important process steps and to identify
sources where wastes are generated. Flow diagrams
are also the foundation upon which material balances
are built.

Material balances are important for many WM projects,
since they allow for quantifying losses or emissions
that were previously unaccounted for Also, material
balances assist in developing the following

•	baseline for tracking progress of the WM efforts

•	data to estimate the size and cost of additional
equipment and other modifications

•	data to evaluate economic performance

In its simplest form, the material balance is represented
by the mass conservation principle:

Mass in - Mass out + Mass accumulated

The material balance should be made individually for all
components that enter and leave the process. When
chemical reactions take place in a system, there is an
advantage to doing "elemental balances" for specific
chemical elements in a system.

Material balances can assist in determining
concentrations of waste constituents where analytical
test data is limited. They are particularly useful where
there are points in the production process where it is
difficult (due to inaccessibility) or uneconomical to
collect analytical data. A material balance can help
determine if fugitive losses are occurring. For
example, the evaporation of solvent from a parts
cleaning tank can be estimated as the difference
between solvent put into the tank and solvent
removed from the tank.

To characterize waste streams by material balance can
require considerable effort. However, by doing so. a
more complete picture of the waste situation results.
This helps to establish the focus of the WM activities
and provides a baseline lor measuring performance.
Appendix 0 lists potential sources of waste from
specific processes and operations.

Sources of Material Balance Information

By definition, the material balance includes both
materials entering and leaving a process. Table 3-2
lists potential sources of material balance information.


Table 3-2. Soureea of Material Balanee

•	Samples, analyses, and flow measurements of feed
stocks, products, and waste streams

•	Raw material purchase records

•	Material inventories

•	Emission inventories

•	Equipment cleaning and validation procedures

•	Batch make-up records

•	Product specifications

•	Design material balances

•	Production records

•	Operating logs

•	Standard operating procedures and operating manuals

•	Waste manifests

Material balances are easier, more meaningful, and
more accurate when they are done for individual units,
operations, or processes. For this reason, it is
important to define the material balance envelope
properly. The envelope should be drawn around the
specifc area of concern, rather than a larger group of
areas or the entire facility. An overall material balance
for a facility can be constructed from individual unit
material balances. This effort will highlight
interrelationships between units and will help to point
out areas for waste minimization by way of cooperation
between different operating units or departments.

Pitfalls in Preparing Material Balances

There are several factors that must be considered
when preparing material balances in order to avoid
errors that could significantly overstate or understate
waste streams. The precision of analytical data and
flow measurements may not allow an accurate measure
of the stream. In particular, in processes with very large
inlet and outlet streams, the absolute error in
measurement of these quantities may be greater in
magnitude than the actual waste stream itself. In this
case, a reliable estimate of the waste stream cannot be
obtained by subtracting the quantity of hazardous
material in the product from that in the feed.

The time span is important when constructing a
material balance. Material balances constructed over a
shorter time span require more accurate and more
frequent stream monitoring in order to close the
balance. Material balances performed over the
duration of a complete production run are typically the
easiest to construct and are reasonably accurate. Time
duration also affects the use of raw material purchasing
records and onsKe inventories for calculating input
material quantities. The quantities of materials
purchased during a specific time period may not
necessarily equal the quantity of materials used in
production during the same time period, since
purchased materials can accumulate in warehouses or

Developing material balances around complex
processes can be a complicated undertaking,
especially if recycle streams are present. Such tasks
are usually performed by chemical engineers, often
with the assistance of computerized process

Material balances will often be needed to comply with
Section 313 of SARA (Superfund Amendment and
Reauthorization Act of 1986) in establishing emission
inventories for specific toxic chemicals. EPA's Office
of Toxic Substances (OTS) has prepared a guidance
manual entitled Estimating Releases and Waste
Treatment Efficiencies for the Toxic Chemicals
Inventory Form (EPA 560/4-88-021. The OTS manual
contains additional information for developing material
balances for the listed toxic chemicals. The information
presented in this manual applies to a WM assessment
when the material balances are for individual
operations being assessed rather than an overall
facility, when the variations in flow over time is
accounted for, and when the data is used from
separate streams rather than from aggregate streams.

Tracking Wastes

Measuring waste mass flows and compositions is
something that should be done periodically. By
tracking wastes, seasonal variations in waste flows or
single large waste streams can be distinguished from
continual, constant flows. Indeed, changes in waste
generation cannot be meaningfully measured unless
the information is collected both before and after r
waste minimization option is implementec
Fortunately, it is easier to do material balances the
second time, and gets even easier as more are done
because of the "learning curve" effect In some larger
companies, computerized database systems have
been used to track wastes. Worksheets 9 and 10 in
Appendix A (and Worksheet S6 in Appendix B)
provide a means of recording pertinent waste stream

Prioritizing Waste Streams and/or
Operations to Assess

ideally, all waste streams and plant operations should
be assessed. However, prioritizing the waste streams
and/or operations to assess is necessary when
available funds and/or personnel are limited. The WM
assessments should concentrate on the most
important waste problems first, and then move on to
the lower priority problems as the time, personnel, and
budget permit.

Setting the priorities of waste streams or facility areas to
assess requires a great deal of care and attention,
since this step focuses the remainder of the


assessment activity. Table 3-3 lists important criteria to
consider when setting these priorities.

Tabla 3-3. Typical Conaldaratlona for
Prioritizing Wast* Straama to Aaaaaa

•	Compliance with currant and future regulations.

•	Costs of waste management (treatment and disposal).

•	Potential environmental and safety liability.

•	Quantity of waste.

•	Hazardous properties of the waste (including toxicity,
flammability, corrosivity, and reactivity).

•	Other safety hazards to employees.

•	Potential for (or ease of) minimization.

•	Potential for removing bottlenecks in production or waste

•	Potential recovery of valuable by-products.

•	Available budget for the waste minimization assessment
program and projects.

Worksheet 10 in Appendix A (Worksheet S6 in
Appendix B) provides a means for evaluating waste
stream priorities for the remainder of the assessment.

Small businesses, or large businesses with only a few
waste generating operations should assess their entire
facility. It is also beneficial to look at an entire facility
when there are a large number of similar operations.
Similarly, the implementation of good operating
practices that involve procedural or organizational
measures, such as soliciting employee suggestions,
awareness-building programs, better inventory and
maintenance procedures, and internal cost accounting
changes, should be implemented on a facility-wide
basis. Since many of these options do not require
large capital expenditures, they should be
implemented as soon as practical.

Selecting the Assessment Teams

The WM program task force is concerned with the
whole plant. However, the focus of each of the
assessment teams is more specific, concentrating on a
particular waste stream or a particular area of the plant.
Each team should include people with direct
responsibility and knowledge ol the particular waste
stream or area of the plant. Table 3-4 presents four
examples of teams for plants of various sizes in
different industries.

In addition to the internal staff, consider using outside
people, especially in the assessment and
implementation phases. They may be trade
association representatives, consultants, or experts
from a different facility of the same company. In large
multi-division companies, a centralized staff of experts
at the corporate headquarters may be available. One
or more "outsiders* can bring in new ideas and provide
an objective viewpoint. An outsider also is more likely
to counteract bias brought about by "inbreeding", or

Table 3-4. Examples of WM Asaeaament Teams

1.	Metal finishing department in a large defense contractor.

•	Metal finishing department manager

•	Process engineer responsible for metal finishing

•	Facilities engineer responsible for metal finishing

•	Wastewater treatment department supervisor

•	Staff environmental engineer

2.	Small pesticide formulator.

•	Production manager*

•	Environmental manager

•	Maintenance supervisor

•	Pesticide industry consultant

3.	Cyanide plating operation at a military facility.

•	Internal assessment team

-	Environmental coordinator*

-	Environmental engineer

•	Electroplating facility engineering supervisor

•	Metallurgist

Materials science group chemist

•	Outside assessment team

Chemical engineers (2)

-	Environmental engineering consultant
Plating chemistry consultant

4.	Large offset printing facility.

•	Internal assessment team

Plant vice president

•	Film processing supervisor

•	Pressroom supervisor

•	Outside assessment team

Chemical engineers (2)'

•	Environmental scientist

•	Printing industry technical consultant

" - Team leader

the "sacred cow" syndrome, such as when an old
process area, rich in history, undergoes an

Outside consultants can bring a wide variety of
experience and expertise to a waste minimization
assessment. Consultants may be especially useful to
smaller companies who may not have in-house
expertise in the relevant waste minimization
techniques and technologies.

Production operators and line employees must not be
overlooked as a source of WM suggestions, since they
possess firsthand knowledge and experience with the
process. Their assistance is especially useful in
assessing operational or procedural changes, or in
equipment modifications that affect the way they do
their work.

"Quality circles" have been instituted by many
companies, particularly in manufacturing industries, to


improve product quality and production efficiency.
These quality circles consist of meetings of workers
and supervisors, where improvements are proposed
and evaluated. Quality circles are beneficial in that they
involve the production people who are closely
associated with the operations, and foster participation
and commitment to-improvement. Several large
companies that have quality circles have used them as
a means of soliciting successful suggestions for waste

Site Inspection

With a specific area or waste stream selected, and with
the assessment team in place, the assessment
continues with a visit to the site. In the case where the
entire assessment team is employed at the plant being
assessed, the team should have become very familiar
with the specific area in the process of collecting the
operating and design data. The members of the
assessment team should familiarize themselves with
the site as much as possble. Although the collected
information is critical to gaining an understanding of the
processes involved, seeing the site is important in
order to witness the actual operation. For example, in
many instances, a process unit is operated differently
from the method originally described in the operating
manual. Modifications may have been made to the
equipment that were not recorded in the flow diagrams
or equipment lists.

When people from outside of the plant participate in
the assessment, It is recommended that a formal site
inspection take place. Even when the team is made up
entirely of plant employees, a site inspection by all
team members is helpful after the site information has
been collected and reviewed. The inspection helps to
resolve questions or conflicting data uncovered during
the review. The site inspection also provides
additional information to supplement that obtained

When the assessment team includes members
employed outside of the plant, the team should
prepare a list of needed information and an inspection
agenda. The list can be presented in the form of a
checklist detailing objectives, questions and issues to
be resolved, and/or further information requirements.
The agenda and information list are given to the
appropriate plant personnel in the areas to be
assessed early enough before the visit to allow them to
assemble the information in advance. Of course, it may
be that the assessment team members themselves are
in the best position to collect and compile much of the
data. By carefully thinking out the agenda and needs
list, important points are less likely to be overlooked
during the inspection. Table 3*5 presents useful
guidelines for the site inspection.

Table 3-5. Guidelines for the Site Inspection

•	Prepare an agenda in advance that covers all points that
still require clarification. Provide staff contacts in the
area being assessed with the agenda several day*
before the inspection.

•	Schedule the inspection to coincide with the partial
operation that is of interest (e.g., make-up chemical
addition, bath aampling, bath dumping, start-up.
shutdown, etc.).

•	Monitor the operation at different times during the shift,
and if needed, during all three ehifts. especially when
waste generation is highly dependent on human
involvement (e.g.. in painting or parts cleaning

•	Interview the operators, shift supervisors, and foremen in
the assessed area. Do not hesitate to question more
than one person I an answer is not forthcoming. Assess
the operators4 and their supervisors' awareness of the
waete generation aspects of the operation. Note their
familiarity (or lack thereof) with the impacts their
operation may have on other operations.

•	Photograph the area of interest, if warranted.
Photographs are valuable in the absence of plant layout
drawings. Many details can be captured in photographs
that otherwise could be forgotten or inaccurately recalled
at a later date.

ฆ Observe the "housekeeping" aspects of the operation.
Check for signs of spills or leaks. Visit the maintenance
ahop and ask about any problems in keeping the
equipment leak-free. Assess the overall cleanliness
the site. Pay attention to odors and fumes.

•	Assess the organizational structure and level of
coordination of environmental activities between various

•	Assess administrative controls, such as cost accounting
procedures, material purchasing procedures, and waste
collection procedures.

In performing the site inspection the assessment team
should follow the process from the point where raw
materials enter the area to the point where the
products and the wastes leave the area. The team
should identify the suspected sources of waste. This
may include the production process; maintenance
operations; storage areas for raw materials, finished
product, and work-in-process. Recognize that the
plant's waste treatment area itself may also offer
opportunities to minimize waste. This inspection often
results in forming preliminary conclusions about the
causes of waste generation. Full confirmation of these
conclusions may require additional data collection,
analysis, and/or site visits.


Generating WM Options

Once the origins and causes of waste generation are
understood, the assessment process enters the
creative phase. The objective of this step is to
generate a comprehensive set of WM options for
further consideration. Following the collection of data
and site inspections, the members of the team will
have begun to identify possible ways to minimize
waste in the assessed area. Identifying potential
options relies both on the expertise and creativity of
the team members. Much of the requisite knowledge
may come from their education and on-the-job
experience, however, the use of technical literature,
contacts, and other sources is always helpful. Some
sources of background information for waste
minimization techniques are listed in Table 3-6.

Table 3-6. Sourest of Background Information
on WM Optlona

Trade associations

As part of their overall function to assiat companies
within their industry, trade associations generally
provide assistance and information about environmental
regulations and various available techniques for
complying with these regulations. The information
provided is especially valuable since it is industry-

Plant engineers and operators

The employees that are intimately familiar with a facility's
operations are often the best source of suggestions for
potential WM options.

Pubfished literature

Technical magazines, trade journals, government
reports, and research briefs often contain information
that can be used as waste minimization options.

State and local environmental agencies

A number of states and local agendas have, or are
developing, programs that indude technical assistance,
information on industry-specific waste minimization
techniques, and compiled bibliographies. Appendix E
provides a list of addresses for state and federal
programs for WM assistance.

Equipment vendors

Meetings with equipment vendors, as well as vendor
literature, are particularly useful in identifying potential
equipment-oriented options. Vendors are eager to assist
companies in implementing projects. Remember, though,
that the vendor's job is to sell equipment.


Consultants can provide information about WM
techniques. "Section 2 discusses the use of consultants
in WM programs. A consultant with waste minimization
experience in your particular industry is most desirable.

Waste Minimization Options

The process for identifying options should follow a
hierarchy in which source reduction options are
explored first, followed by recycling options. This
hierarchy of effort stems from the environmental
desirability of source reduction as the preferred means
of minimizing waste. Treatment options should be
considered only after acceptable waste minimization
techniques have been identified.

Recycling techniques allow hazardous materials to be
put to a beneficial use. Source reduction techniques
avoid the generation of hazardous wastes, thereby
eliminating the problems associated with handling
these wastes. Recycling techniques may be
performed onsite or at an offsite facility designed to
recycle the waste.

Source reduction techniques are characterized as
good operating practices, technology changes,
material changes, or product changes. Recycling
techniques are characterized as use/reuse techniques
and resource recovery techniques. These techniques
are described below:

Source Reduction: Good Operating

Good operating practices are procedural,
administrative, or institutional measures that a company
can use to minimize waste. Good operating practices
apply to the human aspect of manufacturing
operations. Many of these measures are used in
industry largely as efficiency improvements and good
management practices. Good operating practices can
often be implemented with little cost and, therefore,
have a high return on investment. These practices can
be implemented in all areas of a plant, including
production, maintenance operations, and in raw
material and product storage. Good operating
practices include the following:

•	Waste minimization programs

•	Management and personnel practices

•	Material handling and inventory practices

•	Loss prevention

•	Waste segregation

•	Cost accounting practices

•	Production scheduling

Management and personnel practices include
employee training, incentives and bonuses, and other
programs that encourage employees to
conscientiously strive to reduce waste. Material
handling and inventory practices include programs to
reduce loss of input materials due to mishandling,
expired shelf life of time-sensitive materials, and
proper storage conditions. Loss prevention minimizes


wastes by avoiding leaks from equipment and spills.
Waste segregation practices reduce the volume of
hazardous wastes by preventing the mixing of
hazardous and nonhazardous wastes. Cost
accounting practices include programs to allocate
waste treatment and disposal costs directly to the
departments or groups that generate waste, rather
than charging these costs to general company
overhead accounts. In doing so, the departments or
groups that generate the waste become more aware of
the effects of their treatment and disposal practices,
and have a financial incentive to minimize their waste.
By judicious scheduling of batch production runs, the
frequency of equipment cleaning and the resulting
waste can be reduced.

Example: Goari Operating Practices

A large consumer product company In California
adopted a corporate policy to minimize the
generation of hazardous waste. In order to
implement the policy, the company mobilized
quality circles made up of emtftoyees representing
areas within the plant that generated hazardous
wastes. The company experienced a 75%
reduction in the amount of wastes generated by
instituting proper maintenance procedures
suggested by the quality circle teams. Since the
team members were also line supervisors and
operators, they made sure the procedures were

Source Reduction: Technology Changes

Technology changes are oriented toward process and
equipment modifications to reduce waste, primarily in a
production setting. Technology changes can range
from minor changes that can be implemented in a
matter of days at low cost, to the replacement of
processes involving large capital costs. These
changes include the following:

•	Changes in the production process

•	Equipment, layout, or piping changes

•	Use of automation

•	Changes in process operating conditions, such as
• Flow rates

-	Temperatures

-	Pressures

-	Residence times

Example: Technology Changes

A manufacturer of fabricated metal products
cleaned nickel and titanium wire in an alkaline
chemical bath prior to using the wire in their product

In 1986. the company began to experiment with a
mechanical abrasive system. The wire was passed
through the system which uses silk and carbide
pads and pressure to brighten the metal. The
system worked, but required passing the wir
through the unit twice for complete cleaning.
1987. The company bought a second abrasive t
and installed it in series with the first unit. This
system allowed the company to completely
eliminate the need for the chemical cleaning bath.

Source Reduction: Input Material Changes

Input material changes accomplish waste minimization
by reducing or eliminating the hazardous materials that
enter the production process. Also, changes in input
materials can be made to avoid the generation of
hazardous wastes within the production processes.
Input material changes include :

•	Material purification

•	Material substitution

Example: Inout Material Changes

An electronic manufacturing facility of a large
diversified corporation originally cleaned printed
dn/H boards with solvents. The company found that
by switching from a solvent-based cleaning system
to an aqueous-based system that the saw
operating conditions and workloads could
maintained. The aqueous-based system was fa
to dean six times more effectively. This resulted ...
lower product reject rate, and eliminated a
hazardous waste.

Source Reduction: Product Changes

Product changes are performed by the manufacturer
of a product with the intent of reducing waste resulting
from a product's use. Product changes include:

•	Product substitution

•	Product conservation

•	Changes in product composition

Example: Product changes

In the paint manufacturing industry, water-based
coatings are finding increasing applications where
solvent-based paints were used before. These
products do not contain toxic or flammable solvents
that make solvent-based paints hazardous when
they are disposed of. Also, cleaning the applicators
with solvent is not necessary. The use of water-

based paints instead of solvent-based paints also
greatly reduces volatile organic compound
emissions to the atmosphere.

Recycling: Use and Reuse

Recycling via use and/or reuse involves the return of a
waste material either to the originating process as a
substitute for an input material, or to another process
as an input material.

Example- Reuse

A printer of newpaper advertising in California
purchased an ink recycling unit to produce black
newspaper ink from Its various waste inks. The unit
blends the different colors of waste ink together
with fresh black ink and black toner to create the
black ink. This ink is then filtered to remove flakes of -
dried ink. This ink is used in place of fresh black ink,
and eliminates the need for the company to ship
waste ink off site for disposal. The price of the
recycling unit was paid off in 18 months based only
on the savings in fresh black ink purchases. The
payback improved to 9 months when the costs for
disposing of ink as a hazardous waste are included

Recycling: Reclamation

Reclamation is the recovery of a valuable material from
a hazardous waste. Reclamation techniques differ
from use and reuse techniques in that the recovered
material is not used in the facility, rather it is sold to
another company.

Example: Reclamation

A photoprocessing company uses an electrolytic
deposition cell to recover silver out of the rinsewater
from film processing equipment. The stiver is then
sold to a small recyder. By removing the silver from
this wastewater, the wastewater can be discharged
to the sewer without additional pretreatment by the
company. This unit pays for itself in less than two
years with the value of silver recovered.

The company also collects used film and sells it to
the same recycler. The recyder bums the film and
collects the silver from the the residual ash. By
removing the silver from the ash, the ash becomes

Appendix E lists many WM techniques and concepts
applicable to common waste-generating operations

(coating, equipment cleaning, parts cleaning, and
materials handling). Additionally, a list of good
operating practices is provided.

Methods of Generating Options

The process by which waste minimization options are
identified should occur in an environment that
encourages creativity and independent thinking by the
members of the assessment team. While the individual
team members will suggest many potential options on
their own, the process can be enhanced by using
some of the common group decision techniques.
These techniques allow the assessment team to
identify options that the individual members might not
have come up with on their own. Brainstorming
sessions with the team members are an effective way
of developing WM options. Most management or
organizational behavior textbooks describe group
decision techniques, such as brainstorming or the
nominal group technique.

Worksheet 11 in Appendix A is a form for listing
options that are proposed during an option generation
session. Worksheet 12 in Appendix A is used to
briefly describe and document the options that are
proposed. Worksheets S7 and S8 in Appendix B
perform the same function in the simplified set of

Screening and Selecting Options for Further

Many waste minimization options will be identified in a
successful assessment. At this point, it is necessary to
identify those options that offer real potential to
minimize waste and reduce costs. Since detailed
evaluation of technical and economic feasibility is
usually costly, the proposed options should be
screened to identify those that deserve further
evaluation. The screening procedure serves to
eliminate suggested options that appear marginal,
impractical, or inferior without a detailed and more
costly feasibflhy study.

The screening procedures can range from an informal
review and a decision made by the program manager or
a vote of the team members, to quantitative decision-
making tools. The informal evaluation is an
unstructured procedure by which the assessment
team or WM program task force selects the options that
appear to be the best. This method is especially useful
in small facilities, with small management groups, or in
situations where only a few options have been
generated. This method consists of a discussion and
examination of each option.

The weighted sum method is a means of quantifying
the important factors that affect waste management at a


particular faculty, and how each option will perform with
respect to these factors. This method is
recommended when there are a large number of
options to consider. Appendix G presents the
weighted sum method In greater detail, along with an
example. Worksheet 13 in Appendix A is designed to
screen and rank options using this method.

The assessment procedure is flexible enough to allow
common group decision-making techniques to be
used here. For example, many large corporations
currently use decision-making systems that can be
used to screen and rank WM options.

No matter what method is used, the screening
procedure should consider the following questions.

•	What is the main benefit gained by implementing
this option? (e.g., economics, compliance, fiabillty,
workplace safety, etc.)

•	Does the necessary technology exist to develop
the option?

•	How much does it cost? Is it cost effective?

•	Can the option be implemented within a reasonable
amount of time without disrupting production?

•	Does the option have a good "track record"? If not,
is there convincing evidence that the option will
work as required?

•	Does the option have a good chance of success?
(A successfully initiated WM program wfll gain wider
acceptance as the program progresses.)

•	What other benefits will occur?

The results of the screening activity are used to
promote the successful options for technical and
economic feasibility analyses. The number of options
chosen for the feasibility analyses depends on the
time, budget, and resources available for such a study.

Some options (such as procedural changes) may
involve no capital costs and can be Implemented
quickly with little or no further evaluation. The
screening procedure should account for ease of
implementation of an option. If such an option is dearty
desirable and indicates a potential cost savings, It
should be promoted for further study or outright


Section 4
Feasibility Analysis

The recognized need to minimize waste


•	Technical evaluation

•	Economic evaluation

•	Select options for implementation



Successfully implemented
waste minimization projects

The final product of the assessment phase is a list of
WM options for the assessed area. The assessment
will have screened out the impractical or unattractive
options. The next step is to determine if the remaining
options are technically and economically feasble.

Technical Evaluation

The technical evaluation determines whether a
proposed WM option will work in a specific application.
The assessment team should use a "fast-track"
approach in evaluating procedural changes that do not
involve a significant capital expenditure. Process
testing of materials can be done relatively quickly, tf the
options do not involve major equipment installation or

For equipment-related options or process changes,
visits to see existing installations can be arranged
through equipment vendors and industry contacts.
The operator's comments are especially important and
should be compared with the vendor's dainc. Bench-
scale or pilot-scale demonstration is often necessary.
Often it is possible to obtain scale-up data using a
rental test unit for bench-scale or pilot-scale
experiments. Some vendors will install equipment on a
trial basis, with acceptance and payment after a
prescribed time, if the user is satisfied.

The technical evaluation of an option also must
consider facility constraints and product requirements,
such as those described in Table 4-1. Although an
inability to meet these constraints may not present
insurmountable problems, correcting them will likely
add to the capital and/or operating costs.

Table 4-1. Typical Technical Evaluation Criteria

•	Is the system safe for workers?

•	• Will product quality be maintained?

•	Is space available?

•	Is the new equipment, materials, or procedures
compatible with production operating procedures, work
flow, and production rates?

•	Is additional labor required?

•	Are utilities available? Or must they be installed,
thereby raising capital costs?

•	How long will production bo stopped in order to install ths

•	Is special expertise required to operate or maintain the
new system?

•	Does the vendor provide acceptable service?

•	Does the system create other environmental problems?

All affected groups in the facility should contribute to
and review the results of the technical evaluation. Prior
consultation and review with the affected groups (e.g.,
production, maintenance, purchasing) is needed to
ensure the viability and acceptance of an option. If the
option calls for a change in production methods or
input materials, the project's effects on the quality of
the final product must be determined, if after the
technical evaluation, the project appears irrfeasible or
impractical, it should be dropped. Worksheet 14 in
Appendix A Is a checklist of important items to consider
when evaluating the technical feasibility of a WM

Economic Evaluation

The economic evaluation is carried out using standard
measures of profitability, such as payback period,
return on investment, and net present value. Each
organization has its own economic criteria for selecting
projects for implementation. In performing the
economic evaluation, various costs and savings must
be considered. As in any projects, the cost elements
of a WM project can be broken down into capital costs
and operating costs. The economic analysis described
in this section and in the associated worksheets
represents a preliminary, rather than detailed, analysis.

For smaller facilities with only a few processes, the
entire WM assessment procedure will tend to be much


Table 4-2. Capital Invaatmant for a Typical
Larga WM Prejaet

Direct Capital Costs
Site Development

Demolition and alteration work
Site : waring and grading
WaKways, roads, and fencing
Process Equipment

All equipment listed on (low sheets
Spare parts

Taxes, freight, insurance, and duties

Piping and ducting
Insulation and painting

Instrumentation and controls
Buildings and structures
Connections to Existing Utilities and Services (water,
HVAC, power, steam, refrigeration, fuels, plant air
and ineit gas, lighting, and fire control)

New Utility and Service Facilities (same Hems as above)
Other Non-Process Equipment

Construction/Installation labor salaries and burden
Supervision, accounting, timekeeping, purchasing,
safety, and expediting
Temporary facilities
Construction tools and equipment
Taxes and insurance
Building permits, field tests, licenses
Indirect Capital Costs

In-house engineering, procurement, and other home
office costs

Outside engineering, design, and consulting Services

Permitting costs

Contractors' fees

Start-up costs

Training costs


Interest accrued during construction

Woiking Capital

Raw materials inventory
Finished product inventory
Materials and supplies



Source: Adapted from Perry. Chemical Engineer's
Handbook (1985); and Peters and Timmerhaus. Plant Design
and Economics for Chemical Engineers (1980).

less formal. In this situation, several obvious WM
options, such as installation of flow controls and good
operating practices may be implemented with little or
no economic evaluation. In these instances, no
complicated analyses are necessary to demonstrate
the advantages of adopting the selected WM options.

A proper perspective must be maintained between the
magnitude of savings that a potential option may offer,
and the amount of manpower required to do the
technical and economic feasbility analyses.

' Capital Cost*

Table 4-2 is a comprehensive Bst of capital cost itenw
associated with a large plant upgrading project. These
costs include not only the fixed capital costs for
designing, purchasing, and installing equipment, but
also costs tor woiking capital, permitting, training, start-
up, and financing charges.

With the increasing level of environmental regulations,
initial permitting costs are becoming a significant
portion of capital costs for many recycling options (as
well as treatment, storage, and disposal options).
Many source reduction techniques have the
advantage of not requiring environmental permitting in
order to be implemented.

Operating Costa and Savlnga

The basic economic goal of any waste minimization
project is to reduce (or eliminate) waste disposal costs
and to reduce input material costs. However, a variety
of other operating costs (and savings) should also be
considered. In making the economic evaluation, it is
convenient to use incremental operating costs in
comparing the existing system with the new system
that incorporates the waste minimization option.
("Incremental operating costs' represent tl*
difference between the estimated operating cc
associated with the WM option, and the act,
operating costs of the existing system, without tht>
option.) Table 4-3 describes incremental operating
costs and savings and incremental revenues typically
associated with waste minimization projects.

Reducing or avoiding present and future operating
costs associated with waste treatment, storage, and
disposal are major elements of the WM project
economic evaluation. Companies have tended to
ignore these costs in the past because land disposal
was relatively inexpensive. However, recent regulatory
requirements imposed on generators and waste
management facilities have caused the costs of waste
management to increase to the point where it is
becoming a significant factor in a company's overall
cost structure. Table 4-4 presents typical external
costs tor offsite waste treatment and disposal. In
addition to these external costs, there are significant
internal costs, including the labor to store and ship out
wastes, liability insurance costs, and onsite treatment


TabU 4>3. Operating Costa and Savlnga
Associated with WM Projacts

Reduced waste management costs.

This includes reductions in costs for

Offsite treatment, storage, and disposal fees
State fees and taxes on hazardous waste generators
Transportation costs

Onsite treatment, storage, and handling costs
Permitting, reporting, and recordkeeping costs

Input materia) cost savings.

An option that reduces waste usually decreases the
demand for input materials.

Insurance and liability savings.

A WM option may be significant enough to reduce a
company's insurance payments. It may also lower a
company's potential liability associated with remedial
ciean-up of TSDFs and workplace safety. (The
magnitude of liability savings is difficult to determine).

Changes in costs associated with quality.

A WM option may have a positive or negative effect on
product quality. This could resuS in higher (or lower)
costs for rework, scrap, or quality control functions.

Changes In utBlties costs.

Utilities costs may increase or decrease. This includes
steam, electricity, process and cooling water, plant air,
refrigeration, or inert gas.

Changes in operating and maintenance labor, burden, and

An option may either increase or decrease labor
requirements. This may be reflected in changes in
overtime hours or in changes in the number of
employees. When direct labor costs change, then the
burden and benefit costs will also change. In large
projects, supervision costs will also change.

Changes in operating and maintenance supplies.

An option may result increase or decrease the use of
O&M supplies.

Changes in overhead costs.

Large WM projects may affect a facility's overhead

Changes in revenues from increased (or decreased)

An option may result in an increase in the productivity of
a unit. This will result in a change in revenues. (Note that
operating costs may also change accordingly.)

Increased revenues from by-products.

A WM option may produce a by-product that can be sold
to a recyder or sold to another company as a raw
material. This will increase the company's revenues.

Table 4-4. Typical Costs of Offsite Industrisl
Waste Management*


Drummed hazardous waste"

Solids	$75 to $110 per drum

Liquids	$65 to $120 per drum
Buk waste

Solids	$120 per cubic yard

Liquids	$0.60 to $2.30 per gallon

Lab packs	$110 per drum

Analysis (at disposal site) $200 to $300
Transportation	$65 to $85 per hour @ 45 mies

per hour (round trip)

* • Does not tndude internal costs, such as taxes and fees,
and labor for manifest preparation, storage, handling, and

Based on 55 gallon drums. These prices are for larger
quantities of drummed wastes. Disposal of a small
number of drums can be up to four times higher per

For the purpose of evaluating a project to reduce
waste quantities, some types of costs are larger and
more easily quantified. These include:

•	disposal fees

•	transportation costs

•	predisposal treatment costs

•	raw materials costs

•	operating and maintenance costs.

It is suggested that savings in these costs be taken
into consideration first, because they have a greater
effect on project economics and involve less effort to
estimate reliably. The remaining elements are usually
secondary in their direct impact and should be
included on an as-needed basis in fine-tuning the

Profitability Analysis

A project's profitability is measured using the estimated
net cash flows (cash incomes minus cash outlays) for
each year of the project's life. A profitability analysis
example in Appendix H includes two cash flow tables
(Figure H-3 and H-4).

If the project has no significant capital costs, the
project's profitability can be judged by whether an
operating cost savings occurs or not. If such a project
reduces overall operating costs, it should be
implemented as soon as practical.


For projects with significant capital costs, a more
detailed profitability analysis is necessary. The three
standard profitability measures are:

•	Payback period

•	Internal rate of return (IRR)

•	Net present value

The payback period for a project is the amount of time It
takes to recover the initial cash outlay on the project.
The formula for calculating the payback period on a
pretax basis is the following:

Paybfirt ptrbd ฆ Capital investment
(in years) Annual operating cost savings

For example, suppose a waste generator installs a
piece of equipment at a total cost of $120,000. H the
piece of equipment is expected to save $48,000 per
year, then the payback period is ZS years.

Payback periods are typically measured in years.
However, a particularly attractive project may have a
payback period measured in months. Payback periods
in the range of three to four years are usually
considered acceptable for low-risk investments. This
method is recommended for quick assessments of
profitability. If large capital expenditures are involved. It
is usually followed by more detailed analysis.

The internal rate of return (IRR) and the net present
value (NPV) are both cfiscounted cash flow techniques
for determining profitability. Many companies use
these methods for ranking capital projects that are
competing for funds. Capital funding for a project may
well hinge on the ability of the project to generate
positive cash flows beyond the payback period to
realize acceptable return on investment. Both the
NPV and IRR recognize the time value of money by
discounting the projected future net cash flows t~ the
present. For investments with a low level of risk, an
aftertax IRR of 12 to 15 percent is typically acceptable.

Most of the popular spreadsheet programs for
personal computers wfll automatically calculate IRR and
NPV for a series of cash flows. Refer to any financial
management, cost accounting, or engineering
economics text for more information on determining
the IRR or NPV. Appendix H presents a profitability
analysis example for a WM project using IRR and NPV.

Adjustment* tor Rltka and Liability

As mentioned earlier, waste minimization projects may
reduce the magnitude of environmental and safety
risks for a company. Although these risks can be
identified, It is difficult to predict if problems occur, the
nature of the problems, and their resulting magnitude.
One way of accounting for the reduction of these risks


is to ease the financial performance requirements of
the project. For example, the acceptable payback may
be lengthened from four to five years, or the required
internal rate of return may be lowered from 15 percent
to 12 percent. Such adjustments reflect recognition of
elements that affect the risk exposure of the compar
but cannot be included directly in the analyses. The
adjustments are judgmental and necessarily reflect t
individual viewpoints of the people evaluating the
project for capital funding. Therefore, It Is important
that the financial analysts and the decision makers in
the company be aware of the risk reduction and other
benefits of the WM options. As a policy to encourage
waste minimization, some companies have set tower
hurtfle rates for WM projects.

While the profitability is important in deciding whether
or not to implement an option, environmental
regulations may be even more important. A company
operating in violation of environmental regulations can
face fines, lawsuits, and criminal penalties for the
company's managers. Ultimately, the facility may even
be forced to shut down. In this case the total cash flow
of a company can hinge upon Implementing the
environmental project

Workahaata tor Economic Evaluation

Worksheets 15 through 17 in Appendix A are used to
determine the economic evaluation of a WM option.
Worksheet 15 is a checklist of capital and operating
cost items. Worksheet 16 is used to find a simple
payback period for an option that requires cap it?1
investment. Worksheet 17 is used to find the r
present value and internal rate of return for an opti
that requires capital investment. Worksheet S9 ...
Appendix B is used to record estimated capital and
operating costs, and to determine the payback period
in the simplified assessment procedure.

Final Report

The product of a waste minimization assessment is a
report that presents the results of the assessment and
the technical and economic feasibility analyses. The
report also containes recommendations to implement
the feasble options.

A good final report can be an Important tool for getting
a project Implemented. It is particulariy valuable in
obtaining funding for the project. In presenting the
feasfoMty analyses. It Is often useful to evaluate the
project under different scenarios. For example,
comparing a projects's profHabfllty under optimistic and
pessimistic assumptions (such as increasing waste
disposal costs) can be beneficial. Sensitivity analyses
that indicate the effect of key variables on profitability
are also useful.

The report should include not only how much the
project will cost and Its expected performance, but also
how It wOl be done. It Is important to discuss:

•	whether the technology is established, with
mention of succeslul applications;

•	the required resources and how they will be

•	estimated construction period;

•	estimated production downtime;

•	how the performance of the project can be
evakjated after it is implemented.

Before the report is finaBzed, It is Important to review
the results with the affected departments and to so Beit
their support. By having department representatives
assist in preparing and reviewing the report, the
chances are increased that the projects will be
implemented. In summarizing the results, a qualitative
evaluation of intangible costs and benefits to the
company should be included. Reduced liabilities and
improved image in the eyes of the employees and the
community should be discussed.


Section 5

Implementing Waste Minimization Options

The recognized need to minimize waste


Planning and




Analysis Phaaa



•	Justify projects and obtain funding

•	Installation (equipment)

•	implementation (procedure)

•	Evmhiate performance


Successfully implemented
waste minimization projects

The WM assessment report provides the basis for
obtaining company funding of WM projects. Because
projects are not always sold on their technical merits
alone, a clear description of both tangible and
intangble benefits can help edge a proposed project
past competing projects for funding.

The champions of the WM assessment program
should be flexible enough to develop alternatives or
modifications. They should also be committed to the
point of doing background and support work, and
should anticipated potential problems in implementing
the options. Above all, they should keep in mind that
an idea will not sell If the sponsors are not sold on it

Obtaining Funding

Waste reduction projects generally involve
improvements in process efficiency and/or reductions
in operating costs of waste management. However, an
organization's capital resources may be prioritized
toward enhancing future revenues (for example,
moving into new fines of business, expanding plant

capacity, or acquiring other companies), rather th?'
toward cutting current costs. If this is the case. ther(
sound waste reduction project could be postpone
unto the next capital budgeting period. It Is then up to
the project sponsor to ensure that the project is
reconsidered at that time.

Knowing the level within the organization that has
approval authority for capital projects will help in
enlisting the appropriate support. In large
corporations, smaller projects are typically approved at
the plant manager level, medium-size projects at the
divisional vice president level, and larger projects at the
executive committee level.

An evaluation team made up of financial and technical
personnel can ensure that a sponsor's enthusiasm Is
balanced with objectivity. It can also serve to quell
opposing "canl be done" or If It aint broke, dont fix IT
attitudes that might be encountered within the
organization. The team should review the project in
the context of:

•	past experience in this area of operation

•	what the market and the competition are doing

•	how the implementation program fits into th*
company's overall business strategy

•	advantages of the proposal in relation to compu.. v
requests for capital funding

Even when a project promises a high interal rate of
return, some companies will have difficulty raising
funds internally tor capital investment. In this case, the
company should look to outside financing. The
company generally has two major sources to consider
private sector financing and government-assisted

Private sector financing includes bank loans and other
conventional sources of financing. Government
financing is available in some cases. It may be
worthwhile to contact your state's Department of
Commerce or the federal Small Business
Administration for information regarding loans for
pollution control or hazardous waste disposal projects.
Some states can provide technical and financial
assistance. Appendix F includes a list of states
providing this assistance and addresses to get



Waste minimization options that involve operational,
procedural, or materials changes (without additions or
modifications to equipment) should be implemented
as soon as the potential cost savings have been
determined. For projects involving equipment
modifications or new equipment, the installation of a
waste minimization project is essentially no different
from any other capital improvement project. The
phases of the project include planning, design,
procurement, and construction.

Worksheet 18 is a form for documenting the progress
of a WM project through the implementation phase.

Demonstration and Follow-up

After the waste minimization option has been
implemented, it remains to be seen how effective the
option actually turns out to be. Options that don't
measure up to their original performance expectations
may requre rework or modifications. It is important to
get warranties from vendors prior to installation of the

The documentation provided through a follow-up
evaluation represents an important source of
information for future uses of the option in other
facilities. Worksheet 19 Is a form for evaluating the
performance of an implemented WM option. The
experience gained in implementing an option at one
facility can be used to reduce the problems and costs
of implementing options at subsequent facilities.

Measuring Waste Reduction

One measure of effectiveness for a WM project is the
projects effect on the organization's cash flow. The
project should pay for itself through reduced waste
management costs and reduced raw materials costs.
However, it is also important to measure the actual
reduction of waste accomplished by the WM project.

The easiest way to measure waste reduction is by
recording the quantities of waste generated before
and after a WM project has been implemented. The
difference, drvidied by the original waste generation
rate, represents the percentage reduction in waste
quantity. However, this simple measurement ignores
other factors that also affect the quantity of waste

In general, waste generation is directly dependent on
the production rate. Therefore, the ratio of waste
generation rate to production rate is a convenient way
of measuring waste reduction.

Expressing waste reduction in terms of the ratio of
waste to production rates is not free of problems,
however. One of these problems is the danger of
using the ratio of infrequent large quantities to the
production rate. This problem is illustrated by a
situation where a plant undergoes a major overhaul
involving equipment cleaning, paint stripping, and
repainting. Such overhauls are fairly infrequent and
are typically performed every three to five years. The
decision to include this intermittent stream in the
calculation of the waste reduction index, based on the
ratio of waste rate to product rate, would lead to an
increase in this index. This decision cannot be
justified, however, since the infrequent generation of
painting wastes is not a function of production rate. In
a situation like this, the waste reduction progress
should be measured in terms of the ratio of waste
quantity or materials use to the square footage of the
area painted. In general, a distinction should be made
between production- related wastes and maintenance-
related wastes and clean-up wastes.

Also, a few waste streams may be inversely
proportional to production rate. For example, a waste
resulting from outdated input materials is likely to
increase if the production rate decreases. This is
because the age-dated materials in inventory are more
likely to expire when their use in production

For these reasons, care must be taken when
expressing the extent of waste reduction. This
requires that the means by which wastes are
generated be well understood.

In measuring waste reduction, the total quantity of an
individual waste stream should be measured, as well as
the individual waste components or characteristics.
Many companies have reported substantial reduction
in the quanitites of waste disposed. Often, much of
the reduction can be traced to good housekeeping
and steps taken to concentrate a dilute aqueous
waste. Although concentration, as such, does not fall
within the definition of waste minimization, there are
practical benefits that result from concentrating
wastewater streams, including decreased disposal
costs. Concentration may render a waste stream easier
to recycle, and is also desirable if a facility's current
wastewater treatment system is overloaded.

Obtaining good quality data for waste stream quanities,
flows, and composition can be costly and time
consuming. For this reason, it may be practical, in
some instances, to express waste reduction indirectly
in terms of the ratio of input materials consumption to
production rate. These data are easier to obtain,
although the measure is not direct.


Mc iring w 9 minimization by using a ratio of waste
quantity to material throughput or product output is
generally more meaningful for specific units or
operations, rather than for an entire facflity. Therefore,
it is important to preserve the focus of the WM project
when measuring and reporting progress. For those
operations not involving chemical reactions, it may be
helpful to measure WM progress by using the ratio of
input material .quantity to material throughput or
production rate.

Waste Minimization Assessments for
New Production Processes

This manual concentrates on waste minimization
assessments conducted in existing facilities.
However, it is important that waste minimization
principles be applied to new projects. In general, K is
easier to avoid waste generation during the research
and development or design phase than to go back and
modify the process after & has already been installed.

The planning and design team for a new product,
production process, or operation should address
waste generation aspects early on. The assessment
procedure in this manual can be modified to provide a
WM review of a product or process in the planning or
design phase. The earlier the assessment is
performed, the less likely it is that the project will
require expensive changes. All new projects should
be reviewed by the waste minimization program task

A better approach than a pre-project assessment is to
include one or more members of the WM program task
force on any new project that wfll generate waste. In
this way, the new project wiD benefit from the "built-in"
presence of a WM champion and Ms or her influence to
design the process to minimize waste At a Callfomla
facility of a major defense contractor, all new projects
and modifications to existing facBRies and equipment
are reviewed by the WM program team. All projects
that have no environmental Impact are quickly
screened and approved. Those projects that do have
an environmental impact are assigned to a team
member who participates In the project kick-off and
review meetings from inception to implementation.

Ongoing Waste Minimization Program

The WM program Is a continuing, rather than a one-
time effort. Once the highest priority waste streams
and facility areas have been assessed and those
projects have been implemented, the assessment
program should look to areas and waste streams with
lower priorities. The ultimate goal of the WM program
should be to reduce the generation of waste to the
maximum extent achievable. Companies that have
eliminated the generation of hazardous waste should


continue to look 1 reducing industrial wastewater
dtecharges, air emissions, and solid wastes.

The frequency wfth which assessments are done wiO
depend on the program's budget, the company's
budgeting cycle (annual cycle in most companies]
special circumstances. These special drcumstt
might be:

•	a change in raw material or product requirements

•	higher waste management costs

•	new regulations

•	new technology

•	a major event wfth undesirable environmental

oonsequenoes (such as a major spill)

Aside from the special circumstances, a new series of
assessments should be conducted each fiscal year.

To be truly effective, a philosophy of waste
minimization must be developed in the organization.
This means that waste minimization must be an integral
part of the company's operations. The most
successful waste minimization programs to date have
all developed this philosophy within their companies.

Appendix A
Waste Minimization Assessment Worksheets

The worksheets that follow are designed to facilitate the WM assessment procedure. Table A-1 lists the worksheets,
seoording to the particular phase of the program, and a brief description of the purpose of the worksheets.

Appendix B presents a series of simplified worksheets for small businesses or tor preliminary assessments.

Table A-1. List of Waste Minimization Assessment Worksheets
Phase Number and Title	Purposs/Remsrks

1. Assessment Overview

Summarizes the overall assessment procedure.

Planning and Organization
(Section 2)

2.	Program Organization

3.	Assessment Team Make-up

Asssssment Phase

(Section 3)

4.	Site Description

5.	Personnel

6.	Process Information

7.	Input Materials Summary

8. Products Summary

9. Individual Waste Stream

10. Waste Stream Summary

Records key members in the WMA program task force and the WM
assessment teams. Also records the relevant organization.

Lists names of assessment team members as well as duties. Includes
a list of potential departments to consider when selecting the teams.

Lists background information about the facility, including location,
products, and operations.

Records information about the personnel who work In the area to be

This is a checklist of useful process information to look for before
starting the assessment.

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

identifies hazardous components, production rate, revenues, and
other information about products.

Reaords source, hazard, gene ration rate, doposal coet, and method
of treatment or disposal for each waste stream.

Summarizes all of the information collected for each waste stream.
This sheet is also used to prioritize waste streams to assess.



Table Aป1. Ust of Waste Minimization Assessment Worksheets (eontlnued)

Phase Number and Title


Asssssmsnt Phase (continued)
(Section 3)

11.	Option Generation

12.	Option Description

13.	Optiom Evaluation by

Weighted Sum Method

Feasibility Analyala Phaae
(Section 4)

14.	Technical FsasbBty

15. Coet Information

16.	Prafitabiflty Woiksheet #1

Payback Period

17.	ProfitabiBty Worksheet #2

Caah Ftow tor NPV and IRR

Record* option* proposed during brainstorming or nominal group
technique sessions. Includes the rationale tor proposing each option.

Describee and summarizes information about a prepoeed option. Also
notes spprovsl ot promising options.

Used (or screening options using the weighted sum method.

Detailed checkfist for performing a technical evaluation ol a WM option.
This worksheet is divided into sections for equipment-related options,
personnel/procedural-related options, and materials-related options.

Detailed Bst of capita] and operating cost information for use in the
economic evaluation ol an option.

Based on the capital and operating coet information developed from
Worksheet 15, this worksheet is used to calculate the payback period.

This worksheet is used to develop caah flows for calculating NPV or RR.

(Section 8)

If. Project Summery

19. Option Performance

Summarizes important tasks to be performed during the
implementation ol an option. This includes deferable, responabte
person, budget, and schedule.

Reoords material balanoe information for evaluating the
performance of an implemented option.



Waste Minimization Assessment

Pra|. No.

Prepared Bv


Cheeked By


Sheet 1 of 1 Page	of	



Begin tha Wast* Minimization
Aaaaaamant Program


Workaheata used


*	Gat management commitment

*	Set overall assessment program goals

*	Organize assessment program task force

Assessment organization
I and commitment to proceed

Select new
assessment targets
and reevaluate
previous options


•	Compile process and facility data

•	Prioritize and select assessment targets

•	Select people for assessment teams

•	Review data and inspect site

•	Generate options

•	Screen and select options for further study




Assessment report of
selected options


•	Technical evaluation

•	Economic evaluation

•	Select options for implementation



Final report, including
recommended options


Repeat the process

•	Justify projects and obtain funding

•	Installation (equipment)

•	Implementation (procedure)

•	Evaluate performance




Successfully operating
waate minimization projecta


Site .

Proj. No.

Checked By	

Sheet 1 of 1 Page	of 	









Program Manager

Site Coordinator

Assessment Team Leader

Organization Chart




Waste Minimization Assessment

Pmj No

Prepared By

Checked By


Sheet 1 of 1 Pagฎ	of 	







Telephone #






Assessment Team


Site Coordinator





Materials Control




Quality Control














Wast* Minimization Assessment

Proj. No.

Prepared By	.

Checked By	

Sheet 1 of 1 Page	of 	-









Street Addreaa:


State/ZIP Code:
Telephone: ( )

Major Products:

SIC Codes:	

EPA Generator Number :

Ma lor Unit or.
Product or

Facilities/Equipment Age:





Waste Minimization Assessment

Pro). No.

Prepared by
Checked By

Sheet 1 of _1_ Page	of 	








Total Staff

Direct Supv. Staff

Average Age, yrs.	

Annual Turnover Rate %

Seniority, yrs.	

Yrs. of Formal Education
Training, hrsTyr.	

Additional Remarks



Site .

Waste Minimization Assessment

Pro]. No.

Prepared By
Checked By
Sheet J_ of

1 Page	of 	-





Process Unit/Operation:	

Operation Type: ~ Continuous

D Discrete
D Batch or Semi-Batch Q Other—







Used In this
Report (Y/N)



Process Flow Diagram

Materlal/Enerpy Balance



now/Amount Measurements


Process Description

Operating Manuals

Equipment List

Equipment Specifications

Piping & Instrument Diagrams

Plot and Elevation Plan(s)

Work Flow Diagrams

Hazardous Waste ManHests

Emission Inventories

Annual/Blennlal Reports

Environmental Audit Reports

Permit/Permit Applications

Batch Sheet(s)

Materials Application Diagrams

Product Composition Sheets

Material Safety Data Sheets

Inventory Records

Operator Logs

Production Schedules


Site .

Waste Minimization Assessment

Proj. No.

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7 .




Stream No.


Stream No.

Stream No.



Component/Attribute of Concern

Annual Consumption Rate


Component(s) of Concern

Purchase Price, $ per
Overall Annual Cost

Delivery Mode*	

Shipping Container Size & Type1	

Storage Mode*	

Transfer Mode*	

Empty Container Disposal/Management*

Shelf Life	

Supplier Would	

•	accept expired material (V/N)	

•	accept shipping containers (Y/N)	

- revise expiration date (V/N)	

Acceptable Substltute(s), If any	

Alternate Suppliers)	

stream numbers, If applicable, should correspond to those used on process flow diagrams.

e.g., pipeline, tank car, 100 bbl. tank truck, truck, etc.

e.g., 55 gal. drum, 100 lb. paper bag, tank, etc.

e.g., outdoor, warehouse, underground, aboveground, etc.

e.gn pump, forkllft, pneumatic transport, conveyor, etc.

e.g., crush and landfill, clean and recycle, return to supplier, etc.



Waste Minimization Assessment

Pmj Nn

Preoared Bv

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Sheet 1 of 1 Page	of _





Stream No.	

Stream No.	

Stream No.	


Component/Attribute of Concern

Annual Production Rate


Component^) of Concern

Annual Revenues, S

Shipping Mode

Shipping Container Size & Type

Onslte Storage Mode

Containers Returnable (Y/N)

Shelf Life

Rework Possible (Y/N)

Customer Would

• relax specification (Y/N)

• accept larger containers (Y/N)

stream numbers, If applicable, should correspond to those used on process flow diagrams.





Waste Minimization Assessment

Proj. No.

Prepared By	

Checked By	

Sheet 2 of 4 Page	of 	






1. Waste Stream Name/ID:.
Process Unit/Operation

Stream Number.

Waste Characteristics (attach additional sheets with composition data, as necessary.)





O solid O mixed phase

Density, b/cuft


pH	.Flash Point.

High Heating Value, Btu/b.
	; % Water —

3. Waste Leaves Process as:

~ air emission ~ wastewater EH solid waste O hazardous waste

4. Occurrence

~	continuous

~	discrete


discharge triggered by Q chemical analysis	

~ other (describe) 	

Type: ~ periodic	length of period:

~	sporadic (irregular occurrence)

~	non-recurrent

Generation Rate

Maximum .
Average -
Frequency -
Batch Size-

bs per year

bs per	

lbs per	

batches per






I Site



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6. Waste Origins/Sources

Fill out this worksheet to Identify the origin of the waste. If the waste Is a mixture of waste
streams, fill out a sheet for each of the Individual waste streams.

Is the waste mixed with other wastes? O Yes Q No

Describe how the waste Is generated.

Example:	Formation and removal of an undesirable compound, removal of an uncon-

verted Input material, depletion of a key component (e.g., drag-out), equlr
ment cleaning waste, obsolete Input material, spoiled batch and product
run, spill or leak cleanup, evaporative loss, breathing or venting bsses, t





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Waste Stream




Management Method

Leaves site In

O	bulk	

EH	roll off bins	

CD	55 gal drums

EH	other (describe)

Disposal Frequency

Applicable Regulations1

Regulatory Classification2



| |	onsite

I I	commercial TSDF

~	own TSDF
EH	other (describe)

EH	direct use/re-use

EH	energy recovery

EH	redistilled 	

~	other (describe) -

I | offsite

reclaimed material returned to site?

EH Yes EH No EH used by others
residue yield 	

residue disposal/repository


list federal, state & local regulations, (e.g., RCRA, TSCA, etc.)
list pertinent regulatory classification (e.g., RCRA • Listed K011 waste, etc.)


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Waste Stream

7. Management Method (continued)


I I biological	

EH	oxidation/reduction-

~	incineration 	

CI	pH adjustment	

ED	precipitation	

~	solidification	

I I	other (descrbe) —

residue disposal/repository

Final Disposition EH landfill

~ pond

~	lagoon 	

~	deep well	

m	ocean 	

J	other (describe).

Costs as of 	(quarter and year)

Cost Element:

Unit Price


OnsKe Storaoe & Handlina



Transportation Fee

DiSDOsal Fee

Local Taxes

State Tax

Federal Tax

Total Disposal Cost





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Stream No. _	

Stream No.		

Stream No. 		

Waste ID/Name:


Component/or Property of Concern

Annual Generation Rata (units )


Component(s) of Concern

Cost of Disposal

Unit Cost (S per: )

Overall (per year)

Method of Management1

Priority Rating Criteria*

Re latlva

Rating (R)


Rating (R)


Rating (R)


Regulatory Compliance

Treatment/Disposal Cost

Potential Liability

Waste Quantity Generated

Waste Hazard

Safety Hazard

Minimization Potential

Potential to Remove Bottleneck

Potential By-product Recovery

Sum of Priority Rating Scores




Priority Rank

Notes: 1. Stream numbers, If applicable, should correspond to those used on process flow diagrams.

2. For example, sanitary landfill, hazardous waste landfill, onslte recycle, Incineration, combustion
with heat recovery, distillation, dewaterlng, etc.

1 3. Rate each stream In each category on a scale from 0 (none) to 10 (high).





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11 •



Meeting format (e.g., brainstorming, nominal group technique)

Meeting Coordinator		

Meeting Participants			

List Suggested Options

Rationale/Remarks on Option








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Option Name:


or EPA

Briefly describe the option

Waste Stream(s) Affected:

Input Materlal(s) Affected:

Product(s) Affected: 	

Indicate Type:	~ Source Reduction

	 EqulpmentซRelated Change

	 Personnel/Procedure-Related Change

	 Materials-Related Change

~ Recycling/Reuse

	 Onslte 		Material reused for original purpose

	 Offslte 		Material used for a lower-quality purpose

		Material sold

		Material burned for heat recovery

Originally proposed by: 	Date:

Reviewed by: 	Date:

Approved for study?	yes	 no, by:	

Reason for Acceptance or Rejection	





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WM Option Description

1.	Nature of WM Option O Equipment-Related

EH Personnel/Procedure-Related
EH Materials-Related

2.	If the option appears technically feasible, state your rationale for this.

Is further analysis required? EH Yes EH No. If yes, continue wtth this
worksheet If not, skip to worksheet 15.

3. Equipment • Related Option

Equipment available commercially?
Demonstrated commercially?
In similar application?

Describe closest industrial analog











Describe status of development

Prospective Vendor

Working Installatlon(s)

Contact Person(s)

Date Contacted 1.

1. Also attach filled out phone conversation notes, Installation visit report, etc.





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WM Option Description

3. Equipment-Related Option (continued)

Performance Information required (describe parameters):

Scale up Information required (describe):

Testing Required: O yes O no

Scale: ED bench CI] pilot O 	

Test unit available? O yes ~ no
Test Parameters (list)	

Number of test runs:	

Amount of materlal(s) required:	

Testing to be conducted:	Q tn-plant


Facility/Product Constraints:

Space Requirements	

Possible locations within facility 	





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WM Option Description

2. Equipment-Related Option (continued)

Utility Requirements:

Electric Power Volts (AC or DC)
Process Water Flow	



Cooling Water

Quality (tap, demln, etc.)	

Row	 Pressure.

Temp. In

Coolant/Heat Transfer Fluid —

Temp. Out

Temp. In
Duty —

Temp. Out



_ Row


Plant Air.
Inert Gas-




Estimated delivery time (after award of contract-

Estimated Installation time	

Installation dates	

Estimated production downtime.

Will production be otherwise affected? Explain the effect and Impact on production.

Will product quality be affected? Explain the effect on quality.


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WM Option Description	

3. Equipment-Related Option (continued)

Will modifications to work (lowor production procedures be required? Explain..

Operator and maintenance training requirements

Number of people to be trained	 D Onslte

	 ~ Offslte

Duration of training
Describe catalyst, chemicals, replacement parts, or other supplies required.


Rate or Frequency
of Replacement

Supplier, Address |

Does the option meet government and company safety and health requirements?
D Yes D No Explain	

How Is service handled (maintenance and technical assistance)? Explain

What warranties are offered?





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WM Option Description

3. Equipment-Related Option (continued)

Describe any additional storage or material handling requirements.

Describe any additional laboratory or analytical requirements.

4. Personnel/Procedure-Related Changes
Affected Departments/Areas	

Training Requirements

Operating Instruction Changes. Describe responsible departments.

5. Materials-Related Changes (Note: If substantial changes In equipment are required, then handle the
option as an equipment-related one.)	Yes ilfi

Has the new material been demonstrated commercially?	EH EH

In a similar application?	ED 1 I

Successfully?	El I I

Describe closest application.





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WM Option Description

Materials-Related Changes (continued)

Affected Departments/Areas

Will production be affected? Explain the effect and Impact on production.

Will product quality be affected? Explain the effect and the Impact on product quality.

Will additional storage, handling or other ancillary equipment be required? Explain.

Describe any training or procedure changes that are required.

Decrlbe any material testing program that will be required.





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WM Option Description		

CAPITAL COSTS - Include all costs as appropriate.	totals

dH Purchased Process Equipment

Price (fob factory)		

Taxes, freight, Insurance		

Delivered equipment cost		

Price for initial Spare Parts Inventory	 	

~	Estimated Materials Cost






EH Estimated Costs for Utility Connections and New Utility Systems



Cooling Water		

Process Water		


Fuel (Gas or Oil)		

Plant Air		

Inert Gas		 	

CH Estimated Costs for Additional Equipment

Storage & Material Handling		



~	Site Preparation		

(Demolition, site clearing, etc.)		

| [ Estimated Installation Costs



ln>house Staff				


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EH Engineering and Procurement Costs (In-house & outside)





O Start-up Costs

~	Training Costs		

EH Permitting Costs


In-house Staff Costs		

~	Initial Charge of Catalysts and Chemicals

Hem #1	

Item <2	

ED Working Capital [Raw Materials, Product, inventory, Materials and Supplies (not elsewhere specified)].

Item #1.
Item #2.
Item #3
Item #4.

ED Estimated Salvage Value (If any) 	





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Cost Item


Purchased Process Equipment


Utility Connections

Additional Equipment

Site Preparation


Engineering and Procurement

Start-up Cost

Training Costs

Permitting Costs

initial Charge of Catalysts and Chemicals

Fixed Capital Investment

Working Capital

Total Capital Investment

Salvage Value





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Q Estimated Decrease (or Increase) In Utilities


Unit Cost
$ per unit

Decrease (or Increaee) In Quantity
Unit per time

Total Decrease (or Increaee)
$ per time



Cooling Process

Process Water


Fuel (Qee or OU)

Plant Air

Inert Air

INCREMENTAL OPERATING COSTS • Include all relevant operating savings. Estimate these costs on an inc

mental basis (i.e., as decreases or increases over existing costs).

O BASIS FOR COSTS Annual	Quarterly	 Monthly	Dally	 Other—

~	Estimated Disposal Cost Saving

Decrease In TSDF Fees		

Decrease In State Fees and Taxes		

Decrease In Transportation Costs		

Decrease In Onstte Treatment and Handling		

Decrease In Permitting, Reporting and Recordkeeping		

Total Decrease In Disposal Costs		

~	Estimated Decrease In Raw Materials Consumption


Unit Cost
$per unit

Reduction In Quantity
Units per time

Decrease In Cost
$ per time







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Estimated Decrease (or Increase) In Ancillary Catalysts and Chemicals


Unit Cost
$ per unit

Dacraaaa (or bicraaaa) In Quantity
Unit par time

Total Dacraasa (or Incraaaa)
$ par tima

EH Estimated Decrease (or Increase) In Operating Costs and Maintenance Labor Costs
(Include cost of supervision, benefits and burden).


Estimated Decrease (or Increase) In Operating and Maintenance Supplies and Costs.


Estimated Decrease (or Increase) In Insurance and Liability Costs (explain).


Estimated Decrease (or Increase) In Other Operating Costs (explain).


I I Estimated Incremental Revenues from an Increase (or Decrease) In Production or Marketable
By-products (explain).



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15 f





Decreases In Operating Cost or Increases In Revenue are Positive.
Increases In Operating Cost or Decrease In Revenue are Negative.

Operating Cost/Revenue Item

$ per year

Decrease In Disposal Cost

Decrease In Raw Materials Cost

Decrease (or Increase) In Utilities Cost

Decrease (or Increase) In Catalysts and Chemicals

Decrease (or Increase) In 0 & M Labor Costs

Decrease (or Increase) In 0 & M Supplies Costs

Decrease (or Increase) In Insurance/Liabilities Costs

Decrease (or Increase) In Other Operating Costs


Incremental Revenues from Increased (Decreased) Production

Incremental Revenues from Marketable By-products

Net Operating Cost Savings





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Total Capital Investment ($) (from Worksheet 15c)

Annual Net Operating Cost Savings ($ per year) (from Worksheet I5f).

Payback Period (In years) i

Total Capital Investment
Annual Net Operating Cost Savings


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Cash Incomes (such as net operating cost savings and salvage value) are shown as positive.
Cash outlays (such as capital Investments and Increased operating costs) are shown as negative.


Operating1 Year

A Fixed Capital Investment

B 4 Working Capital

C Total Capital Investment


Salvage Value*


Net Operating Costs Savings


- Interest on Loana


• Depreciation


Taxable Income

I • Income Tax*


Aftertax Profit*


~ Depredation


- Repayment of Loan Principal


- Capital Investment (line C)


* Salvage Value (line D)

0 Caah Flow

P Present Value of Caah Flow

0 Net Present Value (NPV)*

Present Worth* (5% discount)










(10% discount)










(15% discount)










(20% discount)










(25% discount)










1	Adjust table as necessary If the anticipated project life la leaa than or more than 8 years.

2	Salvage value Include* scrap value of equipment plus sale of working capital minus demo-
lition costs.

3. The worksheet Is used lor calculating an aftertax cash flow. For pretax cash flow, use sn Income tax rata of 0%.

4	The present value of the cash flow Is equal to the cash flow multiplied by the present worth factor.

5	The net present value la the sum of the present value of the caah flow for that year and all of the proceeding years.

6	The formula for the present worth factor Is	*	where n Is years and t la the dlacount rate.


7	The Internal rate of return (IRR) Is the discount rate (r) that resutta In a net present value of zero over the life of t>
p™jซt	A.32

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Task Leader
































Approval By	 Date

Authorization By	 Date.

reject Started (Date)	




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WM Option Description
~ Baseline

(without option)

EH Projected




Period Duration.


Production per Period

Units (.

Input Materials Consumption per Period






(d) Waste Generation per Period

Waste Stream


(e) Substance(s) of Concern • Generation Rate per Period

Pounds/Unit Product

Pounds/Unit Product

Waste Stream



Pounds/Unit Product


Appendix B

Simplified Waste Minimization Assessment Worksheets

The worksheets that follow are designed to facilitate a simplified WM assessment procedure. Table B-1 lists the
worksheets, according to the particular phase of the program, and a brief description of the purpose of the
worksheets. The worksheets hers are presented as supporting only a preliminary effort at minimizing waste,
or in a situation where a more formal rigorous assessment is not warranted.

Table B-1. List of Simplified WM AaMMmtnt Worksheets

Phase Number and Title


51.	Assessment Overview

Assessment Phaae

(Section 3)

52.	Site Description

S3. Process Information

S4. Input Materials Summary

S5. Products Summary

S6. Waste Stream Summary

S7. Option Generation

S8. Option Description

Feasibility Analyals Phaaa
(Section 4)

Summarizes the overall assessment procedure.

Lists background information about the facility, including location,
products, and operations.

This is a checklist of useful process information to look for before
starting the assessment.

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

Identifies hazardous components, production rate, revenues, and
other information about products.

Summarizes all of the information collected for each waste stream.
This sheet is also 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 option. Also
notes approval of promising options.

S9. Profitability

This worksheet is used to identify capital and operating costs and to
calculate the payback period.



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Begin the Waste Minimization
Aaaaasmant Program



*	Get management commitment

ฆ Set overall assessment program goals

•	Organize assessment program task force

Workeheeta uewd


Assessment organization
and commitment to proceed

Select new
assessment targets
and reevaluate
previous options


•	Compile process and facility data

•	Prioritize and select assessment targets

•	Select people for assessment teams

•	Review data and inspect site

•	Generate options

•	Screen and select options for further study





Assessment report of
selected options


•	Technical evaluation

•	Economic evaluation

•	Select options for implementation



Final report including
recommended options


Repeat the process

• Justify projects and obtain funding
1 Installation (equipment)
' Implementation (procedure)
' Evaluate performance


Successfully operating
waste minimization projects



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Street Address:


State/ZiP Code:
Telephone: ( )

Major Products:

SIC Codes:	

EPA Generator Number :

Major Unit or:
Product or:

Facilities/Equipment Ape:



Site .

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Process Unit/Operation:	

Operation Type: D Continuous

~ Discrete
O Batch or Semi-Batch D Other—





I Ml


Used In this
Report (Y/N)



Process Flow Diagram

Material/Energy Balance



Row/Amount Measurements


Process Description	

Operating Manuals	

Equipment List	

Equipment Specifications

•alng & Instrument Diagrams
Plot and Elevation Pian(s)

Work Flow Diagrams	

Hazardous Waste Manifests

Emission Inventories	

Annual/Blennlal Reports	

Environmental Audit Reports
Permit/Permit Applications

Batch Sheet(s)	

Materials Application Diagrams
Product Composition Sheets
Material Safety Data Sheets

Inventory Records	

Operator Logs	

Production Schedules





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Stream No.


Stream No.

Stream No.



Component/Attribute of Concern

Annual Consumption Rate


Component(s) of Concern

Purchase Price, $ per
Overall Annual Cost

Delivery Mode1

Shlpplno Container Site & Type*

Storage Mode*

Transfer Mode4

Empty Container Disposal/Management1

Shelf Life

Supplier Would

accept expired material (Y/N)

accept shlpplno containers (Y/N)

revise expiration date (Y/N)

Acceptable Substitute^), If any

Alternate Suppliers)

e.g., pipeline, tank car, 100 bbl. tank truck, truck, etc.

e.g., 55 gaL drum, 100 lb. paper bag, tank, etc.

e.g., outdoor, warehouse, underground, aboveg round, etc.

e.g., pump, forkllft, pneumatic transport, conveyor, etc.

e.g., crush and landfill, clean and recycle, return to supplier, etc.







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Stream No.


Stream No.	

Stream No.

Component/Attribute of Concern

Annual Production Rate


Component(s) of Concern

Annual Revenues, $

Shlpplnfl Mode	

Shipping Container Slse & Type

Onslte Storage Mode	

Containers Returnable (Y/N)

Shelf Life	

Rework Possible (Y/N)	

Customer Would	

• relax specification (Y/N)
- accept larger containers (Y/N)





nana Nuiiuiituutuii m*mmhhiii

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Stream No.	

Stream No.

Stream No.	

Waste ID/Name:


Component/or Property of Concern

Annual Generation Rate (units )


Component^) of Concern

Cost of Disposal

Unit Cost (S par )

Overall (per year)

athod of Management*

Priority Ratlna Criteria1


Rating (R)


Rating (R)


Rating (R)


Regulatory Compliance

Treatment/Disposal Cost

Potential Liability

Waste Quantity Generated

Waste Hazard

Safety Hazard

Minimization Potential

Potential to Remove Bottleneck

-Potential By-product Recovery

Sum of Priority Rating Scores




Priority Rank

Notes: 1. For example, sanitary landfill, hazardous waste landfill, onslte recycle, Incineration, combustion
with heat recovery, distillation, dewaterlng, etc.

2. Rate each stream In each category on a scale from 0 (none) to 10 (high).


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Meeting format (e.gM bralnstonnlng, nominal group technique)

Meeting Coordinator			

Meeting Participants		

List Suggested Options

Ratlonale/Remarks on Option





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Option Name:



Briefly describe the option

Waste Stream(s) Affected:

Input Mateiial(s) Affected:

Product(s) Affected: 	—		

Indicate Type:	ED Source Reduction

	 Equipment-Related Change

	 Personnel/Procedure-Related Change

	 Materials-Related Change

~ Recycling/Reuse

	 Onslte 		Material reused for original purpose

	 Offslte 		Material used for a lower-quality purpose

		Material sold

		Material burned for heat recovery

Originally proposed by: 	Date:

Reviewed by: 	Date:

Approved for study?	yes	 no, by:	

Reason for Acceptance or Rejection	


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Capital Costs

Purchased Equipment


Utility Connections-

Start-up and Training.
Other Capital Costs -

Total Capital Costs ฆ

Incremental Annual Operating Costs
Change In Disposal Costs —

Change In Raw Material Costs -
Change In Other Costs	

Annual Net Operating Cost Savings

Payback Period On years)i

Total Capital Costs

Annual Net Operating Cost Savings


Appendix C
Waste Minimization Assessment Example
Amalgamated Metal Reflnlshlng Corporation

The following case study is an example of a waste
minimization assessment of a metal plating operation.
This example is reconstructed from an actual
assessment, but uses fictitious names. The example
presents the background process and facility data, and
then describes the waste minimization options that are
identified and recommended for this facility.

Amalgamated Metal Refinishing Corporation is in the
business of refinishing decorative items. The
corporation owns and operates a small facility in
Beverly Hills, California. The principal metals plated at
this facility are nickel, brass, silver, and gold.

Preparing for the Assessment

Since the facility is a small one with a rather small
number of employees, an assessment team was
assembled that included both oompany personnel and
outside consultants. The team was made up of the
following people:

•	Plant manager (assessment team leader)

•	First shift plating supervisor

•	Corporate process engineer

•	Plating chemistry consultant

•	Environmental engineering consultant

The assessment team chose to look at all of the plating
operations, rather than focusing on one or two specific
plating processes.

The assessment began by collecting recent
production records, input material information,
equipment layout drawings and flow diagrams, waste
records, and plant operator instructions. After each of
the team members had reviewed the information, a
comprehensive inspection of the plating room was
carried out. The following process, layout, and waste
descriptions summarize the information that was
collected for the assessment.

Process Description

Items brought in for refinishing are cleaned,
electroplated and polished The basic operations
include paint stripping, cleaning, electroplating, drying,
and polishing.

In silver plating, the original plated metal is stripped off
the item by dipping it into a sodium cyanide solution
with the system run in reverse current. This is followed
by an acid wash in a 50% muriatic acid solution. The
item is then polished to a bright finish. The polished
item is then cleaned with caustic solution to remove
dirt, rinsed with a 5% sulfuric acid solution to neutralize
any remaining caustic solution on the item, and rinsed
with water. The item is now ready for electroplating.

After the item is immersed in the plating tank for the
required amount of time, it is rinsed in a still rinse tank,
followed by a continuous water rinse. Tap water is
used for both the still and continuous rinsing steps.
Solution from the still rinse tank is used as make-up for
the plating baths.ln places where two still rinse tanks
are used, water from the second tank is used to-
repienish the first still rinse tank. Overflow from the
continuous rinse tank is discharged as wastewater.
The item is polished following the plating step.

Gold plating generally does not require stripping. After
the initial cleaning operation, the item is electroplated.
Nickel and brass plating are also done in a similar
manner. Vapor degreasing using 1,1,1-
trichloroethane is often perfomed on brass- and nickel-
plated items to remove oil and grease, in some cases,
items are first nickel-plated and then plated with gold,
silver, or brass.

For electroplating operations, the constituents of the
cyanide solutions must be kept at an optimum
concentration. The solutions are analyzed twice a
month by an outside laboratory. A representative
sample from a tank is obtained by dipping a tube to the
bottom of the plating tank. The sample is analyzed and
recommendations for make-up are made based on the
test results. Table C-1 shows a typical analysis for
brass and nickel electroplating solutions, respectively.
This table also shows the optimum concentrations for
each constituent in the baths, as well as the
recommended make-up and/or dilution requirements.

All plating operations at the facility are performed
manually. Tire facility operates one shift per day and
employs eight operators.

Equipment Layout Description

All plating, cleaning, and rinse tanks are located in one
room at the plating shop, while an adjacent room
houses all equipment used for buffing and polishing.


Table C-1. Electroplating Solution Analyses

Table C-2. Waatawatar charaetarlatloa


Brass Plating

Copper metal
Zinc metal
Sodium cyanide
Sodium hydroxide
Copper cyanide
Zinc cyanide
Rochelle salts

Nickel Plating
Nickel metal
Nickel chloride
Boric acid
Nickel sulfate


0.3 oz/gsl

8.0 oz/gal



7.52 oz/gal

16.65	OZ/gal



4 ฃ

Sampling date
Sampling location
Type of sample
Reporting period

Total flow in
Total flow out
Peak flow

Suspended aofids

Total cyanide
Total chromium

OS and grease

August 8,1987
Clarifwr Sample Box
Tme Composite
July "87 to August "8*

290 gallons
1JS gallons per minute


1.0 mg/L
0.42 mg/L
1.30 mg/L
0.93 mg/L
<0.05 mg/L

02 mg/L

Figure C-1 is a plan of the facility. The area north of the
buffing room is used for drying and storage purposes.
Finished goods, as well as raw materials, are stored in
the front of the buDding.

Thirty tanks are used in cleaning and electroplating
operations. Figure C-1 includes the names and normal
working volumes of these tanks. The configuration of
a typical plating unit includes a plating bath, followed by
one ore two still tanks and a continuous rinse tank.
Except for nickel plating, all plating and stripping
solutions used at the facility are cyanide-based.

Waste Stream Description

Cyanide waste is generated from silver stripping; from
silver, gold, brass, and copper electroplating; and from
the associated rinsing operations. The principal waste
streams are wastewater from the continuous rinse
tanks and from floor washings, and plating tank filter

Aqueous streams generated from paint stripping, from
metal stripping and electroplating, and from floor
washings are routed to a common sump. This sump
discharges to the sanitary sewer. Table C-2 presents
the results of a typical analysis on the wastewater.

Metal sludges accumulate in the plating tanks. This
sludge is filtered out of the plating solution once a
month using a portable dual cartridge filter. Two filter
cartridges are used for each plating tank. Cartridges
are typically replaced every two to three months.

The sump is pumped out and disposed of as
hazardous waste once every six months. When
pumped out the sump usually contains 300 to 400

gallons of sludge comprised of dirt, stripped paint, and
a solution containing cyanide and heavy metals.

Proposed Waste Minimization Options

After the site inspection was completed and additional
information was reviewed, the team held a
brainstorming session to identify potential waste
minimization options for the facility. The following
options were proposed during the meeting;

•	Reduce solution drag-out from the plating tanks by

-	Proper positioning of workpiece on the plating

-	Increasing plating solution temperatures.

-	Lowering the concentration of plating solution

-	Increase the recovery of drag-out wfth drain

•	Extend plating solution bath Hfe by;

-	Reducing drag-in by better rinsing.

-	Using deiontzed make-up water.

-	Using purer anodes.

-	Returning spent solutions to the suppliers.

•	Reduce the use of rinse water by:

•	Using multiple countercurrent rinse tanks.

-	Using still rinsing.

•	Using spray or fog rinsing.

ฆ Prevent dust from the adjacent buffing and
polishing room from entering the plating room and
contaminating the plating baths.

•	Segregate cyanide wastes from the rinse tanks from
other wastewater streams, such as floor washings
and paint stripping wastes.



Amalgamated Metal Refinishlng Corporation
Worldwide Headquarters and Production Facilities
Beverly Hills, California


The team members each independently reviewed the
options and then met to decide which options to study
further. The team chose the following options for the
feasibility analysis:

•	Re d uce drag-out by using drain boards.

•	Extend bath Hfe>using detanked water for make-up.

•	Use spray rinsing to reduce rinsewater usage.

•	Segregate hazardous waste from nonhazardous

Feasibility Analysis

The assessment team conducted technical and
economic feasibility analyses on each of the four

Segregate Hazardous Wastes

The assessment team recognized that segregating
hazardous wastes from nonhazardous wastes could be
implemented at virtually no cost and would save money
immediately. There were no identified technical

Use Drain Boards to Reduce Drag-out

Drain boards are used to collect plating solution that
drips off the rack and the workpiece after they are
pulled out of the plating tank. The plating solution
drains back into the plating tank. This option reduces
the amount of dilute rinse water waste, but impurities
build up faster in the plating solution. Shoe drag-out is
reduced, make-up chemical consumption is reduced.

The purchase price of drain boards is estimated at
$115, with installation costs of $200, for a total capital
cost of $315. This option is expected to reduce rinse
water disposal costs by $500 per year, and reduce
make-up chemicals costs by $400 per year. The
resulting payback period is 0.35 years, or about 4

Use Deionized Water tor Make-up Solutions
and ftlnse Water

Using Dl water will reduce the build-up of impurities in
the plating solutions. In particular, the build-
uphardness minerals from tap water will be avoided.
This, in turn, will avoid the precipitation of carbonates in
the plating tanks.

the drain boards, the total capital cost of this option i6
$582. The deionizer is rented and serviced by an
outside water treating service company for $450 per
year. The savings in disposal costs and make-up
chemical costs is $900 per year. Therefore, the annt'
net operating cost savings is $450 per year. Tl
payback period is 1.3 years.

Inatall Spray Rinses

Installing spray rinses wDI reduce the amount of rinse
water required to dean the items. With spray rinse
nozzles and controls, rinsing can be done on demand
Rinse water usage was estimated to be reduced by
50%. The resulting rinse wastewater is more
concentrated and some can be returned to the plating
tanks as a water make-up.

The assessment team determined that four spray rinse
units would cost $2,120, plus an additional $705 for
piping, valves, and installation labor. The total capital
cost was $2825. The reduction in disposal costs were
estimated at $350 per year, based on a 50% reduction
in rinse wastewater. This resulted in a payback of over
8 years.


The procedures for segregating hazardous wastes
from nonhazardous wastes was implemented before
the feasibility analysis was completed for the other
three options. The installation of drain boards and fr
purchase of a water deionizer were made shortly af
the feasibility analysis was completed. The Dl waL
system was online two months later. The assessment
team decided not to implement the spray rinse option
because of the long payback period.

Future WM Assessments

During the next cycle of waste minimization
assessments, the assessment team will review
previously suggested options in the plating area and
wiD look at ways to reduce the generation of metallic
dust in the buffing and polishing area. In the
meantime, the assessment team will continue to look
for additional opportunities to reduce waste
throughout the facility.

The assessment team decided to combine the
evaluation of this option with the previous option of
using drain boards. The initial purchase and installation
of the deionizer was $267. When adding the cost of

Appendix D
Typical Causes and Sources of Waste

In order to develop a comprehensive list of waste minimization options tor a facility, it is necessary to
understand the sources, causes, and controlling factors that influence waste generation. The tables
in this Appendix list this information for common industrial operations.

Table D-1. Typical Wastes from Plant Operations

Table D-2. Causes and Controlling Factois of Waste Generation

Table D-1. Typical Waataa from Plant Operations

Plant Function Location/Operation	Potential Waste Material

Material Receiving

Loading docks, incoming
pipelines, receiving areas

Packaging materials, off-spec materials, damaged containers,
inadvertent spills, transfer hose emptying

Raw Material and
Product Storage

Tanks, warehouses, drum
storage yards, bins,

Tank bottoms; off-spec and excess materials; spill residues;
leaking pumps, valves, tanks, and pipes; damaged containers,
empty containers


Melting, curing, baking,
distilling, washing, coating,
formulating, reaction

Washwater; rinse water; solvents; still bottoms; off-spec
products; catalysts;empty containers; sweepings; ductwork
clean-out; additives; oil; filters; spill residue; excess materials;
process solution dumpe; leaking pipes, valves, hoses, tanks,
and process equipment

Support Services


Reagents, off-spec chemicals, samples, empty sample and
chemical containers

Maintenance shops

Solvents, cleaning agents, degreasing sludges, sand-blasting
waste, caustic, scrap metal, oils, greases


Oils, filters, solvents, acids, caustics, cleaning bath sludges,


Fly ash, slag, tube dean-out material, chemical additives, oil
empty containers, boiler blowdown. water-treating chemical

Cooling towers

Chemical additives, empty containers, cooling tower bottom
sediment cooling tower blowdown, fan lube oils

Source: adapted from Gary Hunt and Roger Schecter, "Minimization of Hazardous Waste Generation*,

Standard Handbook of Hazardous Waste Management. Harry Freeman, editor, McGraw-Hill, New York (currently in press).


Table D-2. Can

Chemical Reaction

Contact between
aqueous and
organic phases

Process equipment

Heat exchanger

Metal parts

Metal surface

Disposal of
unusable raw
materials or
off-spec products

Clean-up of spills
and leaks

i and Controlling Factora In

Typical Causes

Incomplete conversion
By-product formation
Catalyst deactivation
(by poisoning or sintering)

Condensate from steam
Jet ejectors

Presenoe of water as a
reaction by-product
Use of water for product

Equipment cleaning
SpU clean-up

Presenoe of ding
Deposit formation
Use of filter aids
Use of chemical cleaners

Presence of cfing (process
side) or scale (cooRng
water eide)

Deposit formation
Use of chemical deanere

Disposal of spent solvents,
spent cleaning solution, or
cleaning sludge


•	Disposal of spent treating

•	Obeolete raw materials

•	Off-spec products caused
by contamination, improper
reactant controls, inadequate
pre-cleaning of equipment or
workpiece, temperature or
pressure excursions

•	Manual material transfer and

hand ting operations

•	Leaking pump seals

•	Leaking flange gaskets

Waate Generation

Operational Factors

•	Inadequate temperature control

•	Inadequate mixing

•	Poor feed flow control

•	Poor feed purity control

•	Indiscriminate use of water for
cleaning or washing

Design Factors

•	Drainage prior to cleaning

•	Production scheduling to

reduce cleaning frequency

1 Inadequate cooling water

' Excessive cooling water

Indiscriminate use of solvent
or water

' Poor rack maintenance

•	Excessive rinsing with water
> Fast removal of workpiece

•	Poor operator training or


•	Inadequate quality control

•	Inadequate production planning
and inventory control of

1 Inadequate maintenance
1 Poor operator training

•	Lack of attention by operator

•	Excessive use of water in

1 Proper reactor design
' Proper catalyst aelection
1 Choioe of prooees
> Choice of reaction condittonB

' Vacuum pumps instead of

steam jet ejectors
1 Choioe of process
1 Use of retailers instead of
steam stripping

1 Design reactors or tanks

wper blades
1 Reduce ding
' Equipment dedication

1 Design for lower film temperature

and high turbulenos
' Controls to prevent coding
water from overheating

1 Choioe between cold dip tank or

vapor degreasing
1 Choioe between solvent or
aqueous cleaning solution

' Countercurrent rinsing
'Fog rinsing

' Dragout collection tanks or trays

> Use of automation
• Maximize dedication of
equipment to a single function

Choice of gasketing materials
1 Choice of seals
' Use of welded or seal-welded

Source: Jacobs Engineering Group


Appendix E
Waste Minimization Techniques

The tables in this appendix lists techniques and practices for waste reduction in operations that are
applied in a wide range of industries. Most of the techniques listed here are source reduction techniques.

Table E-1. Waste Minimization Options for Coating Operations
Table E-2. Waste Minimization Options for Equipment Cleaning Operations
Table E-3. Waste Minimization through Good Operating Practices
Table E-4. Waste Minimization Options in Materials Handling, Storage, and Transfer
Table E-5. Waste Minimization Options for Parts Cleaning Operations
Source: Jacobs Engineering Group


Table E-1. Waste Minimization Options for Coating Operations



Waste Reduction Measures



Coaling overspray

Coating material that fails


Maintain 50% overlap between spray pattern

The coated object does not look


to reach the object being


Maintain 6" • 8" distance between spray gun

streaked, and wastage of coating


and the workpiece

material is avoided. If thespra^


Maintain a gun speed ol about 250 feet/minute

gun is arched 45*. the overspray


Hold gun perpendicular to the surface

can be as high as 65%.


Trigger gun at the beginning and end ol each



Proper training of operators



Use robots lor spraying



Avoid excessive air pressure for coating

By air pressure adjustment,



overspray can be reduced to 40%.


Recycle overspray



Use electrostatic spray systems

Overspray can be reduced by 40%.



Use air-assisted airless spray guns in place of

Increases transfer efficiency.


air-spray guns

Stripping wastes

Coating removal from parts


Avoid adding excess thinner

Reduces stripping wastes due to rework.


before applying a new coat


Use abrasive media stripping

Solvent usage is eliminated.


Use bead-blasting for paint stripping

Solvent usage is eliminated.



Use cryogenic stripping

Solvent usage is eliminated.



Use caustic stripping solutions

Solvent usage Is eliminated.



Clean coating equipment after each use


Solvent emissions

Evaporative losses from


Keep solvent soak tanks away from heat sources


process equipment and


Use high-solids formulations

Lower usage of solvents.

coated parts


Use powder coatings

Avoids solvent usage.



Use water-based formulations

Avoids solvent usage.


Equipment cleanup

Process equipment cleaning


Light-to-dark batch sequencing



with solvents


Produce large batches of similarly coated

objects instead of small batches of differently

coated items


Isolate solvent-based paint spray booths from


water-based paint spray booths


Reuse cleaning solution/solvent


Standardize solvent usage



Reexamine the need for coating, as well as

available alternatives

Table E-2. Waste Minimization Options for Equipment Cleaning Operations

Waste	Source/Origin	Waste Reduction Measures	Remarks	References

Spent solvent- or Tank cleaning operations


cleaning solutions

•	Maximize dedication of process equipment

•	Use squeegees to recover cling of product
prior to rinsing

•	Avoid unnecessary cleaning

•	Closed storage and transfer systems

•	Provide sufficient drain time for liquids

•	Lining the equipment to prevent cling

•	'Pigging* process lines

•	Use high-pressure spray nozzles

•	Use countercurrent rinsing

•	Use clean-in-place systems

•	Clean equipment immediately after use

•	Reuse cleanup solvent

•	Rework cleanup solvent into useful products

•	Segregate wastes by solvent type

•	Standardize solvent usage

•	Reclaim solvent by distillation

•	Schedule production to lower cleaning

Scaling and drying up can be prevented.
Minimizes leftover material
Reduces ding.	18


Minimizes solvent consumption.

Prevents hardening of scale that requires
more severe cleaning.

sludges, spent
acidic solutions

Heat exchanger cleaning

Use bypass control or pumped recycle to
maintain turbulence during turndown
Use smooth heat exchange surfaces
Use on-stream cleaning techniques
Use hydroblasting over chemical cleaning
where possible

Onsite or offsite recycling.

Electroplated or Teflon<8 tubes.
"Superscrubber". for example.



Table E-3. Waste Minimization through Good Operating Practices

Good Operating Practice

Program Ingredients



Waste minimization assessments

•	Form a team ol qualified individuals

•	Establish practical short-term and long-term goals

•	Allocate resources and budget (or the program

•	Establish assessment targets

•	Identify and select options to minimize waste
Periodically monitor the program's effectiveness

These programs are conducted to reduce
waste In a facility.


Environmental audits/reviews

*	Assemble pertinent documents

*	Conduct environmental process reviews

*	Carry out a site inspection

*	Report on and follow up on the findings

These audits are conducted to monitor
compliance with regulations.


toss prevention programs

•	Establish Spill Prevention, Control, and
Countermeasures (SPCC) plans

•	Conduct hazard assessment in the design and
operating phases

SPCC plans are required by law for oil
storage facilities.


Waste Segregation

•	Prevent mixing of hazardous wastes with
non-hazardous wastes

•	Isolate hazardous wastes by contaminant

•	Isolate liquid wastes from solid wastes

These measures can result In lower waste
haulage volumes and easier disposal of
the hazardous wastes.


Preventive maintenance programs

•	Use equipment data cards on equipment location,
characteristics, and maintenance

•	Maintain a master preventive maintenance (PM)

•	Deferred PM reports on equipment

•	Maintain equipment history cards

•	Maintain equipment breakdown reports

•	Keep vendor maintenance manuals handy

•	Maintain a manual or computerized repair history file

These programs are conducted to cut
production costs and decrease
equipment downtime, In addition
to preventing waste releases due
to equipment failure.


Table E-3. Waste Minimization through Good Operating Practices (continued)

Good Operating Practice

Program Ingredients




Effective supervision

Employee participation
Production scheduling/planning

Cost accounting/allocation

Provide training for

-	Safe operation of the equipment

-	Proper materials handling

-	Economic and environmental ramifications of
hazardous waste generation and disposal

• Detecting releases of hazardous materials

-	Emergency procedures

-	Use of safety gear

Closer supervision may improve production efficiency
and reduce inadvertent waste generation
Management by objectives (MBO), with goals for
waste reduction

"Quality circles" (free forums between employees
and supervisors) can identify ways to reduce waste
Solicit employee suggestions for waste reduction ideas

Maximize batch size

Dedicate equipment to a single product

Alter batch sequencing to minimize cleaning frequency

(light-to-dark batch sequence, for example)

Schedule production to minimizing cleaning frequency

Cost accounting done for all waste streams leaving
the facilities

Allocate waste treatment and disposal costs to the
operations that generate the waste

These programs are conducted to reduce
occupational health and safety
hazards, in addition to reducing
waste generation due to operator
or procedural errors.

Increased opportunity for early detection
of mistakes.

Better coordination among the various
parts of an overall operation.

Employees who intimately understand the
operations can identify ways to reduce

Altering production schedule can have a
major impact on waste minimization.

Allocating costs to the waste-producing
operations will give them an incentive
to cut their wastes.

Table E-4. Waste Minimization Options In Materials Handling, Storage, and Transfer

Waste/Source	Waste Reduction Measures	Remarks	References

Material/waste tracking and	• Avoid over-purchasing	These procedures are employed to find 30,31

inventory control	• Accept raw material only after inspection	areas where the waste minimization

•	Ensure that inventory quantity does not go to	efforts are to be concentrated. ป

•	Ensure that no containers stay In inventory
longer than a specified period

•	Review material procurement specifications

•	Return expired material to supplier

•	Validate shell-life expiration dates

•	Test outdated material for effectiveness

•	Eliminate shed-life requirements for stable

•	Conduct frequent inventory checks

•	Use computer-assisted plant Inventory system

•	Conduct periodic materials tracking

•	Proper labeling of al containers

•	Set up manned stations for dispensing
chemicals and collecting wastes

Loss prevention programs	* Use properly designed tanks and vessels only for

their Intended purposes

*	Install overflow alarms for all tanks and vessels

*	Maintain physical integrity of ad tanks and vessels

*	Set up written procedures for all loading/unloading
and transfer operations

*	Install secondary containment areas

*	Forbid operators to bypass Interlocks, alarms, or
significantly alter setpoints without authorization

*	Isolate equipment or process lines that leak or are
not in service

*	Use seal-less pumps

*	Use bellows-seal valves

*	Document all spillage

*	Perform overall material balances and estimate
the quantity and dollar value of all losses

*	Use lloatlng-roof tanks for VOC control

*	Use conservation vents on fixed roof tanks

*	Use vapor recovery systems

Table E-4. Waste Minimization Options In Materials Handling, Storage, and Transfer (continued)

Waste/Source	Waste Reduction Measures	Remarks	References

SpiHs and leaks	• Store containers in such a way as to a How (or

visual inspection for corrosion and leaks

•	Stack containers In a way to minimize the chance
of tipping, puncturing, or breaking

•	Prevent concrete "sweating* by raising the
drum off storage areas

•	Maintain MSDSs to correctly handle spill

•	Provide adequate lighting In the storage area

•	Maintain a clean, even surface In transportation

•	Keep aisles dear of obstruction

•	Maintain distance between incompatible chemicals

•	Maintain distance between different types of
chemicals to prevent cross-contamination

•	Avoid stacking containers against process

•	Follow manufacturers' suggestions on the storage
and handling of all raw materials

•	Insulation and Inspection of electric circuitry for
corrosion and potential sparking

•	Use large containers instead of small containers
whenever possible

•	Use containers with height-to-diameter ratb equal
to one to minimize wetted area

•	Empty drums and containers thoroughly before
cleaning or disposal

Table E-S. Waste Minimization Options for Parts Cleaning Operations

Waste	Source/Origin	Waste Reduction Measures	Remarks	References

Spent solvent

Contaminated solvent from

• Use water-soluble cutting fluids instead

This could eliminate the need for solvent

parts cleaning operations

of oil-based fluids

•	Use peef coatings In place of protective oits

•	Use aqueous cleaners

•	Use aqueous paint stripping solutions

•	Use cryogenic stripping

•	Use bead blasting for paint stripping

•	Use multi-stage countercurrent cleaning

•	Prevent cross-contamination

•	Prevent drag-in from other processes

•	Prompt removal of sludge from the tank

•	Reduce the number of different solvents


A single, larger waste that is more
amenable to recycling.


Air emissbns

Solvent loss from

• Use roll-type covers, not hinged covers

24 to 50% reduction in emissions.


degreasers and cold tanks

• Increase freeboard height

39% reduction in solvent emissions.


•	Install freeboard chillers

•	Use silhouette entry covers

•	Proper equipment layout


• Avoid rapid insertion and removal of items

The speed that items are put into the


tank should be less than 11 leet/min.

• Avoid Inserting oversized objects into

Cross-sectional area of the Item should


the tank

be less that 50% of tank area to reduce
piston effect.

• Allow for proper drainage before removing


• Avoid water contamination of solvent

in degreasers

Rinse water

Water rinse to remove

• Reduce solvent dragout by proper design and

The dragout can be 0.4 gal/1000 sqft,


solvent carried out with

operation of rack system

versus 24 gal/1000 sqft for poorly

the parts leaving the

drained parts.

cleaning tank

• Install air jets to blow parts dry

•	Use fog nozzles on rinse tanks

•	Proper design and operation of barrel system

•	Use countercurrent rinse tanks


• Use water sprays on rinse tanks

More efficient rinsing is achieved.


Appendix E

1.	Kohl, J.. J. Pearson, and P. Wright. Managing and Recycling Solvents in the Furniture Industry.
North Carolina State University, Raleigh, 1986.

2.	Lencku?, D. "Increasing productivity". Finishing Wood and Wood Products Magazine. Vol. 87, No.
4, May 1982, pp 44-66.

3.	Campbell, M. E., and W. M. Glenn. Profit from Pollution Prevention. The Pollution Probe
Foundation. Toronto, Canada, 1982.

4.	Kohl, J., P. Moses, and B. Triplett. Managing and Recycling Solvents: North Carolina Practices.
Facilities, and Regulations. North Carolina State University, Raleigh, 1984.

5.	Dumey, J. J. "How to improve your paint stripping". Product Finishing. December 1982, pp 52-53.

6.	Higgins, T. E Industrial Process Modifications to Reduce Generation of Hazardous Waste at OOP
Facilities: Phase I Report. CH2M Hill, Washington, D.C., 1985.

7.	"Cryogenic paint stripping". Product Finish. December 1982.

8.	Maliamee, W. M. "Paint and varnish removers". Klik-Othmer Encyclopedia of Chemical Technology.
3rd edition, Volume 16, pp 762-767,1981.

9.	Sandberg.J. Final Report on the Internship served at Gaoe Tool Company. Minnesota Technical
Assistance Program, Minnesota Waste Management Board, Minnesota, 1985.

10.	Powder Coatings Institute. Information brochure. Washington, D. C., 1983.

11.	Cole, G. E. "VOC emission reduction and other benefits achieved by major powder coating
operations'. Paper No. 84-38.1 presented at the Air Pollution Control Association. June 25,1984.

12.	California State Department of Health Services. Alternative Techno logy for Recycling and Treatment
of Hazardous Waste. 3rd Biennial Report. Sacramento, 1986.

13.	California State Department of Health Services. Guide to Solvent Waste Reduction Alternatives.
October 1986, pp 4-25 to 4-49.

14.	Kenson, R. E. "Reoovery and reuse of solvents from VOC air emissions". Environmental Progress.
August 1985, pp 161-165.

15.	Dumey, L. J., editor. Electroplating Engineering hindhook. 4th edition. Van Nostrand Reinhold,
New York, 1984.

16.	American Society of Testing Materials. Handbook of Vapor Deareasina. Special Technical
Publication 310-A., ASTM, Philadelphia, April 1976.

17.	Smith, C. "Troubleshooting vapor degreasers". Product Finish. November 1981.

18.	Loucks, C. M. "Boosting capacities with chemicals". Chemical Engineering Deskbook Issue. Vol.
80. No. 5, pp 79-84,1973.

19.	3M Corporation. Ideas - A Compendium of 3M Success Stories St. Paul, MN.


20.	Fromm, C. H., S. Budaraju, and S. A. Cordery. "Minimization of process equipment cleaning waste".
Conference proceedings of HAZTECH international, Denver. August 13*15,1986, pp 291-307.

21.	Versar, Inc. and Jacobs Engineering Group. Waste Minlmfratinn- Issues and Options. Vol. II. U. S.
Environmental Protection Agency, Washington, D. C., October 1986.

22.	Fromm, C. H. and M. S. Callahan. "Waste reduction audit procedure". Conference proceedings of
the Hazarddus Materials Control Research institute. Atlanta, 1986, pp 427-435.

23.	North Carolina Pollution Prevention Pays Program. Environmental Auditing. North Carolina
Department of Environmental Health. 1985.

24.	Baumer, R.A. Making environmental audits". Chemical Engineering. Vol. 89, No. 22. November 1,
1982.p 101.

25.	Kletz, T. A. "Minimize your product spillage". Hydrocarbon Processing. Vol. 61. No. 3.1982, p 207.

26.	Sarokin, D. "Reducing hazardous wastes at the source: Case studies of organic chemical plants in
New Jersey. Paper presented at Source Reduction of Hazardous Waste Conference, Rutgers
University, August 22,1985.

27.	Singh, J. B. and R. M. Alien. "Estabfishing a preventive maintenance program". Plant Engineering.
February 27.1986. p 46.

28.	Rimberg, D. "Minimizing maintenance makes money". Pollution Engineering. Vol. 12, No. 3,
December 1983, p 46.

29.	Parker, N. H. "Corrective maintenance and performance optimization". Chemical Engineering. Vol.
91, No. 7, April 16,1984, p 93.

30.	Geltenan, E. "Keeping chemical records on track". Chemical Business. Vol. 6, No. 11,1984, p 47.

31.	Hickman, W. E. and W. D. Moore. "Managing the maintenance doUar". Chemical Engineering. Vol.
93, No. 7, April 24,1986, p 68.


Appendix F

Government Technical/Financial Assistance Programs

The EPA's Office of Solid Waste and Emergency Response has set up a telephone call-in service to answer
questions regarding RCRA and Superfund (CERCLA):

(800) 424-9346 (outside the District of Columbia)

(202) 382-3000 (in the District of Columbia)

The following states have programs that offer technical and/or financial assistance in the areas of waste
minimization and treatment.


Hazardous Material Management and Resource

Recovery Program
University of Alabama
P.O. Box 6373
Tuscaloosa, AL 35487-6373


Alaska Health Project
Waste Reduction Assistance Program
431 West Seventh Avenue, Suite 101
Anchorage, AK 99501


Arkansas Industrial Development Commission
One State Capitol Mall
Little Rock, AR 72201


Alternative Technology Section
Toxic Substances Control Division
California State Department of Health Services
714/744 P Street
Sacramento, CA 94234-7320
(916) 324-1807


Connecticut Hazardous Waste Management Service
Suite 360

900 Asylum Avenue
Hartford, CT 06105
(203) 244-2007

Connecticut Department of Economic Development
210 Washington Street
Hartford CT 06106
(203) 566-7196


Hazardous Waste Technical Assistance Program

Georgia Institute of Technology

Georgia Technical Research Institute

Environmental Health and Safety Division

OKeefe Building, Room 027

Atlanta. GA 30332

(404) 894-3806

Georgia (contlnuad)

Environmental Protection Division

Georgia Department of Natural Resources

Floyd Towers East, Suite 1154

205 Butler Street

Atlanta, CA 30334

(404) 656-2833


Hazardous Waste Research and Information Center
Illinois Department of Energy and Natural Resources
1808 Woodfield Drive
Savoy. IL 61874
(217) 333-8940

Dlinois Waste Elimination Research Center

Pritzker Department of Environmental Engineering

Alumni Building, Room 102

Illinois Institute of Technology

3200 South Federal Street

Chicago, IL 60616



Environmental Management and Education Program

Young Graduate House. Room 120

Purdue University

West Lafayette, IN 47907

(317) 494-5036

Indiana Department of Environmental Management

Office of Technical Assistance

P.O. Box 6015

105 South Meridian Street

Indianapolis. IN 46206-6015



Iowa Department of Natural Resources

Air Quality and Solid Waste Protection Bureau

Wallace State Office Building

900 East Grand Avenue

Des Moines, IA 50319-0034


Center for Industrial Research and Service

205 Engineering Annex

Iowa State University

Ames, IA 50011

(515) 294-3420



Bureau of Waste Management
Department of Health and Environment
Forbes Field, Building 730
Topeka, KS 66620


Division of Waste Management

Natural Resources and Environmental Protection Cabinet

18ReHly Road

Frankfort, KY 40601

(502) 564-6716


Department of Environmental QuaOty
Office of Solid and Hazardous Waste
P.O. Box 44307
Baton Rouge, LA 70804
(504) 342-1354


Maryland Hazardous Waste Facilities Siting Board
60 West Street, Suite 200A
Annapolis, MD 21401

Maryland Environmental Service
2020 Industrial Drive
Annapolis, MD 21401
(800) 492-9188 On Maryland)


Office of Safe Waste Management
Department of Environmental Management
100 Cambridge Street, Room 1094
Boston, MA 02202

Source Reduction Program

Massachusetts Department of Environmental Quality

1 Winter Street
Boston, MA 02108


Resource Recovery Section
Department of Natural Resources
P.O. Box 30028
Lansing. Ml 48909


Minnesota Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Road
St. Paul. MN 55155

Mlnnaaota (eontlnuad)

Minnesota Technical Assistance Program

W-140 Boynton Health Servioe

University of Minnesota

Minneapolis, MN 55455

(612) 625-9677

(800) 247-0015 (in Minnesota)

Minnesota Waste Management Board
123 Thereon Center
7323 Fifty-Eighth Avenue North
Crystal, MN 55428
(612) 536-0816


State Environmental Improvement and Energy

Resources Agency
P.O. Box 744
Jefferson City, MO 65102

Naw Jaraay

New Jersey Hazardous Waste Facilities Siting

Room 614

28 West State Street
Trenton. NJ 08608
(609) 292-1459

Hazardous Waste Advisement Program

Bureau of Regulation and Classification

New Jersey Department of Environmental Protection

401 East State Street

Trenton, NJ 08625

Risk Reduction Unit

Office of Science and Research

New Jersey Department of Environmental Protection

401 East State Street

Trenton, NJ 08625

Naw York

New York State Environmental Facilities Corporation
50 Wort Road
Abany, NY 12205
(518) 457-3273

North Carolina

Pollution Prevention Pays Program
Department of Natural Resources and Community

P.O. Box 27687
512 North Salisbury Street
Raleigh. NC 27611
(919) 733-7015

Governor's Waste Management Board
325 North Salisbury Street
Raleigh, NC 27611
(919) 733-9020


North Carolina {continued)

Technical Assistance Unit
Solid and Hazardous Waste Management Branch
North Carolina Department of Human Resources
P.O. Box 2091
306 North Wilmington Street
Raleigh, NC 27602
(919) 733-2178.


Division of Solid and Hazardous Waste Management

Ohio Environmental Protection Agency

P.O. Box 1049

1800 WaterMaifc Drive

Columbus. OH 43266-1049


Ohio Technology Transfer Organization
Suite 200

65 East State Street
Columbus. OH 43266-0330


Industrial Waste Elimination Program
Oklahoma State Department of Health
P.O. Box 53551
Oklahoma City. OK 73152
(405) 271-7353


Oregon Hazardous Waste Reduction Program
Department of Environmental Quality
811 Southwest Sixth Avenue
Portland. OR 97204
(503) 229-5913


Pennsylvania Technical Assistance Program
501 F. Orvts Keller Building
University Park, PA 16802
(814) 865-0427

Bureau of Waste Management

Pennsylvania Department of Environmental Resources

P.O. Box 2063

Fulton Building

3rd and Locust Streets

Harrisburg, PA 17120


Center of Hazardous Material Research
320 William Pitt Way
Pittsburgh. PA 15238
(412) 826-5320

Rhoda laland

Ocean State Cleanup and Recycling Program

Rhode Island Department of Environmental Management

9 Hayes Street

Providence, Rl 02908-5003


(800) 253-2674 (in Rhode Island)

Rhoda laland (eontlnuad)

Center of Environmental Studies
Brown University
P.O. Box 1943
135 Angell Street
Providence, Rl 02912


Center for Industrial Services
102 Alumni Hall
University of Tennessee
Knoxville, TN 37996
(615) 974-2456

Office of Policy and Planning
Virginia Department of Waste Management
11th Floor, Monroe Building
101 North 14th Street
Richmond, VA 23219
(804) 225-2667


Hazardous Waste Section
Mail Stop PV-11

Washington Department of Ecology
Olympia.WA 98504-8711


Bureau of Solid Waste Management

Wisconsin Department of Natural Resources

P.O. Box 7921

101 South Webster Street

Madison. W! 53707

(608) 266-2699


Solid Waste Management Program

Wyoming Department of Environmental Quality

Herachler Building, 4th Floor. West Wing

122 West 25th Street

Cheyenne, WY 82002



Appendix G
Option Rating
Weighted Sum Method

The Weighted Sum Method is a quantitative method
for screening and ranking waste minimization options.
This method provides a means of quantifying the
important criteria that affect waste management in a
particular facility. This method involves three steps.

1.	Determine what the important criteria are in terms
of the WM assessment program goals a
constraints, and the overall corporate goals an
constraints. Examples of criteria are the following:

•	Reduction in waste quantity

•	Reduction in waste hazard (e.g.. toxicity,
flammability, reactivity, corrosivity, etc.)

•	Reduction in waste treatment/disposal costs

•	Reduction in raw material costs

•	Reduction in liability and insurance costs

•	Previous successful use within the company

•	Previous successful use in industry

•	Not detrimental to product quality

•	Low capital cost

•	Low operating and maintenance costs

•	Short implementation period (and minimal
disruption of plant operations)

•	Ease of implementation

The weights (on a scale of 0 to 10, for example) are
determined for each of the criteria in relation to
their importance.For example, if reduction in waste
treatment and disposal costs are very important,
while previous successful use within the company
is of minor importance, then the reduction in waste
costs is given a weight of 10 and the previous use
within the company is given a weight of 1 or 2.
Criteria that are not important are not included (or
given a weight of 0).

2.	Each option is then rated on each of the criteria.
Again, a scale of 0 to 10 can be used (0 for low and
10 for high).

3.	Finally, the rating of each option from particular
criteria is multiplied by the weight of the criteria. An
option's overall rating is the sum of the products of
rating times the weight of the criteria.

The options with the best overall ratings are then
selected for the technical and economic feasibility
analyses. Worksheet 13 in Appendix A is used to rate
options using the Weighted Sum method. Table G-1
presents an example using the Weighted Sum Method
for screening and ranking options.

Table G-1. Sample Calculation ualng the
Walghtad Sum Method

ABC Corporation has determined that reduction in waste
treatment costs is the most important criterion, with a weight
factor of 10. Other significant criteria include reduction in
safety hazard (weight of 8), reduction in liability (weight of 7),
and ease of implementation (weight of 5). Options X, Y, and
Z are then each assigned effectiveness factors. For
example, option X is expected to reduce waste by nearly
80%, and is given an rating of 8. It is given a rating of 6 for
reducing safety hazards, 4 for reducing liability, and
because it is somewhat difficult to implement, 2 for ease of
implementation. The table below shows how the options are
rated, overall,, with effectiveness factors estimated for
options Y and Z.

Ratings for each option

Rating Criteria





Reduce treatment costs





Reduce safety hazards





Reduce liability





Ease of implementation


. 2



Sum of weight times ratings




From this screening, option Z rates the highest with a score
of 169. Option X's score is 166 and option Y's score is 122.
In this case, option Z and option X should both be selected
for further evaluation because both of their scores are high
and relatively close to each other.


Appendix H
Economic Evaluation Example

The following example presents a profitability analysis
for a relatively large hypothetical waste minimization
project. This project represents the installation of a
package unit that improves plant production while
reducing raw material consumption and disposal costs.
The analysis was done on a personal computer using a
standard spreadsheet program. The salient data used
in this evaluation are summarized below.

Capital Costs

•	The delivered price of the equipment is quoted by
the vendor at $170,000. This includes taxes and

•	Materials costs (piping, wiring, and concrete) are
estimated at $35,000.

•	installation labor is estimated at $25,000.

•	Internal engineering staff costs are estimated at
$7,000. Outside consultant and contractor costs
are estimated at $15,000.

•	Miscellaneous environmental permitting costs are
estimated at $15,000.

•	Working capital (including chemical inventories, and
materials and supplies) is estimated at $5,000.

•	Start-up costs are estimated by the vendor at

•	A contingency of $20,000 for unforeseen costs
and/or overruns is included.

•	Planning, design, and installation are expected to
take one year.


•	The project will be financed 60% by retained
earnings and 40% by a bank loan.

•	The bank loan will be repaid over 5 years of equal
installments of principal, plus interest at an annual
percentage rate of 13%. Interest accrued during
installation will be added into the total capital costs.

•	All capital costs, except working capital and interest
accrued during construction, will be depreciated
over 7 years using the double-declining balance
method, switching to the straight-line method when
the charges by this method become greater.

•	The marginal income tax rate is 34%.

•	Escalation of all costs is assumed to be 5% per year
for the life of the project.

•	The firm's cost of capital is 15%.

Operating Costs and Revenues

•	The WM project is estimated to decrease raw
materials consumption by 300 units per year at a
cost of $50 per unit The project wDI not result in an
increased production. However, it will produce a
marketable by-product to be recovered at a rate of
200 units per year and a price of $25 per unit.

•	The project will reduce the quantity of hazardous
waste disposed by 200 tons per year. The following
items make the total unit disposal costs:

Costs per ton nfwasta

Off site disposal fees	$500

State generator taxes	10

Transportation costs	25

Other costs		25


•	Incremental operating labor costs are estimated on
the basis that the project is expected to require one
hour of operator's time per eight-hour shift. There
are three shifts per day and the plant operates 350
days per year. The wage rate for operators is
$12.50 per hour.

•	Operating supplies expenses are estimated at 30%
of operating labor costs.

•	Maintenance labor oosts are estimated at 2% of the
sum of the capital costs for equipment, materials,
and installation. Maintenance supplies costs are
estimated at 1% of these costs.

•	Incremental supervision costs are estimated at 30%
of the combined costs of operating and
maintenance labor.

•	The following overhead costs are estimated as a
percentage of the sum of operating and
maintenance labor and supervision costs.

Labor burden and benefit 28%

Plant overhead	25%

Headquarter overhead	20%


•	Escalation of all costs b assumed to be 5% per year
for the life of the project.

•	The project We is expected to be 8 years.

•	The salvage value of the project is expected to be
zero after eight years.


The four-page printout in Figures H-1 through H-4
presents the WM project profitability spreadsheet
program. Figure H-1 represents the input section of
the program. Each of the numbers in the first three
columns represents an input variable in the program.
The right hand side of Figure H-1 is a summary of the
capital requirement. This includes a calculation of the
interest accrued during construction and the financing
structure of the project.

Figure H-2 is a table of the revenues and operating
cost items for each of the eight years of the project's
operating life. These costs are escalated by 5% each
year for the life of the project.

Figure H-3 presents the annual cash flows for the
project. The calculation of depreciation charges and
the payment of interest and repayment of loan principal
is also shown here. The calculation of the internal rate
of return (IRR) and the net present value (NPV) are
based on the annual cash flows. Since the project is
leveraged (financed partly by a bank loan), the equity
portion of the investment is used as the initial cash
flow. The NPV and the IRR are calculated on this basis.
The IRR calculated this way Is referred to as the "return
on equity". The program is structured to present the
NPV and IRR after each year of the project's operating
life. In the example, after six years, the IRR is 19.92%
and the NPV is $27,227.

Figure H-4 is a cash flow table based entirely on equity
financing. Therefore, there are no interest payments
or deb principal repayments. The NPV and the IRR in
this case are based on the entire capital investment in
the project. The IRR calculated this way is referred to
as the "return on investment".

The results of the profitability analysis for this project
are summarized below:

Method of financing	PR	NPV

60% equity/40% debt 26.47% $84,844
100% equity	23.09% $81,625

The IRR values are greater than the 15% cost of
capital, and the NPVs are positive. Therefore, the
project is attractive, and should be implemented.


Figure H-1. Input Information and Capital Investment


Operating Year Number









Escalation Factor











Increased Production









Marketable By-products









Annual Revenue











Raw Materials









Disposal Costs



Maintenance Labor

1 1 ($4,830)1 ($5,074)1 ($5,327)1 ($5,594)1 ($5,874)1 ($8,169)1 ($6,477)1 ($6,799)1

Maintenance Supplies







Operating Labor








Operating Suoofles


















Labor Burden









Plant Overhead









Home Office Overhead









Total Operetta Coals









Figure H-2. Revenues and Operating Costs



Construction Year


Operating Year









Book Value








. $0


Depreciation (by straight-l










Depredation (by doubleDE



















Debt Balance










Interest Payment









Principal Repayment










Construction Year


Operating Year


















-I- Operatlna Savings









Net Revenues









• Depredation









- Interest on Debt









Taxable Income









- Income Tax









Profit after Tax









ฆi- Depreciation









- Debt Repayment









After-Tax Cash Flow










Cash Flow for ROE










Net Present Value










Return on Eauitv










Figure H-3. Cash Flows for Return on Equity


1 Construction Year












Book Value





Depredation (by stralght-l










Depredation (by double C




















Construction Year


Operating Year


















~ Ooeratina Savinas









Net Revenues


















Taxable Income









-Income Tax









Prafk after Tax








til JOQ |


til AOO


#99 fl97



+ Depredation
Altar-Tax Cash Row

I Business

i lor Private Use. S300

Cenier (or Environmental Research


Cincinnati OH 45268

bulk rate



Contrasting Approaches to
Pollution "Prevention Auditing

Robert B. Pojasek and Lawrence J. Cali

Most pollution prevention
audit teams currently use
protocols developed for
compliance auditing. The
inability of these
prescriptive audit
protocols to describe the
functionality of the
process limits their
effectiveness. This paper
presents a descriptive
audit approach designed
to provide the in-depth
understanding of the
process that is essential
for the development of
meaningful reduction
opportunities. Ways in
which the traditional nuriit
approach can be
integrated with the
descriptive approach to
provide a more effective
audit tool are also

As the number of environmental regulations continues to grow,
compliance auditing of industrial facilities has become increasingly
important. The many auditing protocols developed over the past
fifteen years all seek to expedite the collection of the large amount of
information needed to assess a facility's compliance. Checklists,
worksheets, and questionnaires that direct the audit process form the
heart of this directive approach or "prescriptive" audit approach.

Today, however, many companies are adopting a proactive stance
toward environmental regulation by implementing pollution pre-
vention programs. A key element in the success of such programs is
the pollution prevention audit. The aim of a pollution prevention
audit is not to assess a facility's compliance with existing environmental
regulations, but to identify and eliminate or reduce the sources of
pollution. Nevertheless, these audits are often performed using a
prescriptive approach similar to that used for compliance auditing.

A more useful technique for auditing pollution prevention programs
might be what has been termed a "descriptive" audit approach, that
is, one that focuses on describing processes and their associated
wastes. In this article we discuss both the prescriptive and descriptive
approaches and their relative merits. Knowing the advantages of each
approach and how they might be successfully combined can improve
the effectiveness of pollution prevention audits.1

The Prescriptive Audit Approach

When initially confronted with the need to reduce environmental
releases and waste generation, environmental scientists and engineers
typically use compliance audit procedures to assess waste reduction
opportunities. Environmental professionals had substantial training
and experience in using these procedures, so it is not surprising that
they applied them to the area of pollution prevention. The widespread
use of this prescriptive approach led to its adoption by the U.S.
Environmental Protection Agency (EPA). With the publication of the
Waste Minimization Opportunity Assessment Manual by the EPA,2

This article is prepared by Dr. Robert B. Pojasek. Vice President at CEI Consultant< Inc..
in charge of this engineering firm's corporate environmental programs. For information,
contact CEI Consultants, Inc.. 1021 Main Street. Winchester, MA 01890, (617) ฆ -UXX)
FAX (617) 721-4073.

Pollution Prevention Review/Summer 1991


Robert B. Pojasek and Lawrence J. Call

the prescriptive audit approach became the most widely recognized
and implemented procedure for pollution prevention audits. Many
states, including Oregon, New York, Connecticut, Washington, and
Minnesota, have now adopted the prescriptive approach for their
pollution prevention programs.

The prescriptive audit process is described in detail in the EPA
manual and in Chapter 3 of Hazardous Waste Minimization.'
Figure 1 shows the steps in the prescriptive audit process and how
it fits into the larger pollution prevention assessment program. It is
clear that worksheets (checklists and questionnaires) form the heart
of the prescriptive approach. Figure 2 shows one such worksheet
from the EPA manual. Each of these worksheets is designed to
facilitate collection and organization by category of important process

Figure 1. The Prescriptive Audit Process

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Aaaaaamant Program



*	Gal managamant commitmant

*	Sat ovarail aaaaaamant program goals

*	Orgamza aaaaasmam program tasK tore*


Aaaaaamant organsaran
and commitmant to procaad


Select now

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and raavaluata	* Pnom,z# ,nt3 se,#cl aaaaaamant targatt

' Salact paopM lor aaaaaamant team*
previous options	n ^

•	Roviow dau and inapoa via

•	Gtniriti optena

•	Savon and sotod oodont for furthor study


Aimimini rapoft ot
taiactad ootnna


•	TachntcaJ avaJuaicn

•	Eoonomc avaluatan

•	Salad opuona tor tmplamamation

Fmal raooft. inctuamc |
raeommandad ootens i


_ _• Juatify proiacta and obtain funding
l^ *Pa tha procaaa

•	tmpiamamauon (proeadura)

•	Evaluata partormanca


Suecaaatulty oparattng
waata minimization projaeta


Pollution Prevention Review/Summer 1991

Contrasting Approaches to Pollution. Prevention Auditing

Figure 2. Sample EPA Worksheet


Waste Minimization Assessment

Pmj Nn

Prepared Bv


Checked By


Sheet 1 of 1 Page	of 	







Stream No.	

Stream No.	

Stream No.	

Nam a/10


Component/Attribute ot Concern

Annual Consumption Rate


Component(s) ot Concern

Purchase Price, $ per

Overall Annual Cost

Delivery Mode1

Shipping Container Size & Type1

Storage Mode*

Transfer Mode*

Empty Container Disposal/Management*

Shell Lite

Supplier Would

ฆ accept expired material (Y/N)

• accept shipping containers (Y/N)

• revise expiration date (Y/N)

Acceptable Substitute^), If any

Alternate Suppliers)

' stream numbers. It applicable, should correspond to those used on process flow diagrams.

*	e.g., pipeline, tank car, 100 bbl. tank truck, truck, etc.

' e.g., 55 gal. drum, 100 lb. paper bag, tank, etc.

4 e.g., outdoor, warehouse, underground, aboveground, etc.

•	e.g, pump, forkllft, pneumatic transport, conveyor, etc.

' e.g., crush and landfill, clean and recycle, return to supplier, etc.

Pollution Prevention Review/Summer 1991


Robert B. Pojasek and Lawrence J. Call

Table 1 lists the EPA waste minimization worksheets and their
respective purposes. The categories dealt with include:

•	Haw materials

•	Finished products

•	Process wastes

•	Equipment design

•	Maintenance

•	Personnel organization

Table 1. EPA Waste Minimization Assessment Worksheets

Worksheet	Purpose

Site Description

Lists background information

about the facility, including loca-

tion, products, and operations.


Records information about the

personnel who work in the

area to be assessed.

Process Information

This is a checklist of useful process

information to look for before

starting the assessment

Input Materials Summary

Records input material informa-

tion for a specific production or

process area. This includes name.

supplier, hazardous component or

properties, cost, delivery and

shelf-life information, and possible


Products Summary

Identifies hazardous components,

production rate, revenues, and

other information about products.

Individual Waste Stream

Records source, hazard, generation


rate, disposal cost, and method of

treatment or disposal for each

waste stream.

Waste Stream Summary

Summarizes all of the information

collected for each waste stream.

This sheet is also used to prioritize

waste streams to assess.


Pollution Prevention Review/Summer 1991

Contrasting Approaches to Pollution Prevention Auditing

Given the shortcomings
inherent in the
prescriptive approach, it is
only natural to look for
alternative auditing
methods. One possibility
is to make the process
itself the central focus of
the audit and to view
wastes and releases as
process losses.

The checklists are quite comprehensive. No important source of
data is overlooked Even for small facilities, the amount of informa-
tion to be collected can be quite large.

Advantages of the prescriptive approach

The prescriptive audit approach offers several advantages.
Checklists and worksheets used in this type of audit provide a
standardized approach that can be used by almost anyone. Special-
ized audit training or detailed process knowledge are not really
needed because the forms provide the necessary structure and direc-
tion. As a result, the audit team can include nontechnical personnel
from areas such as purchasing or finance. Finally the comprehensive
nature of the checklists ensures that the audit team does not overlook
important information.

Disadvantages of the prescriptive approach

Despite these advantages, the prescriptive audit approach leaves
a great deal to be desired. This is not unexpected because the objective
of a pollution prevention audit is quite different from that of a
compliance audit. In a pollution prevention audit the auditor must not
only identify process wastes but also their sources. This requires
understanding the interrelationships among process elements. For
example, raw material usage data must be correlated with scrap and
waste generation rates. Although the checklists ensure that material
usage and waste generation data are collected, they do not make clear
how the data interrelate or to what process they apply. This basic
shortcoming of the prescriptive approach has become more apparent
now that companies are moving beyond good housekeeping proce-
dures into more fundamental, process-related reduction measures.

Another drawback of the descriptive approach is the generic
nature of the checklists. Users of the checklists in the EPA manual
have found that many of them are not applicable to their manufactur-
ing operations. Auditors find that reworking the checklists to suit
their facility's needs requires a significant amount of effort. The
EPA, recognizing this problem, has recently published customized
versions of checklists for seven selected industries." Users in other
industries, however, must still do their own customizing.

The Descriptive Approach

Given the shortcomings inherent in the prescriptive approach, it
is only natural to look for alternative audi ting methods. One possibility
is to make the process itself the central focus of the audit and to view
wastes and releases as process losses. This concept is illustrated in
Figure 3. The left side of Figure 3 shows the throughput sequence of
any industrial operation. Because the use of chemicals is rarely 100
percent efficient, there are losses of chemicals from the operation as
depicted. There can also be losses of the inputs (e.g., shelflife expira-
tion of stored feedstocks) and the products (e.g., defective or otherwise

Pollution Prevention Review/Summer 1991


Robert B. Pojasek and Lawrence J. Call

Figure 3. Conceptualization of the Industrial Process


nonfunctional products). The goal of the descriptive audit approach is
then to identify all potential process losses so that appropriate
reduction measures can be implemented.

The two basic components of the descriptive approach are a
process flow diagram and a materials accounting. Figure 4 shows an
example of a process flow diagram constructed for a metal parts
manufacturing facility. The magnitude of the process flows, devel-
oped from a materials accounting, are also noted on the diagram.

Constructing a process flow diagram

A process flow diagram depicts the series of steps through which
the input materials pass in the course of their transformation into
product. For any operation, be it the manufacture of chairs of the
maintenance of a pump, there is a functional sequence of events or
actions. One action initiates others, which in turn initiate still others
until the overall function is completed, resulting in some kind of out-


Pollution Prevention Review/Summer 1991

Contrasting Approaches to Pollution Prevention Auditing

Figure 4. Metal Parts Process Flow Diagram

Metal Stock
(200 lbs /hr)



(5 lbs /hr)


Waste Rod
(0.1 lb /hr)

Air Emissions
(0.01 lb /hr)

(.1 gal/hr)

Spent Thinner
(.2 gals/hr)



(10 lbs /hr)

Rod (1 Ib./hr)
O, (30 ftVhr)



Paint (1 gal/hr)

(.5 gals/hr)


put. The process flow diagram clearly illustrates the functional
sequence. The knowledge of the process that is gained from using the
process flow diagram is critical, because only by understanding the
process can one hope to change it to reduce losses.

The first step in constructing a process flow diagram is to identify

Pollution Prevention Review/Summer 1991


Robert B. Pojasek and Lawrence J. Call

the fundamental or unit operations that lead to the final product or
the end result of the process. In the metal parts process depicted in
Figure 4, the unit operations consist of steam cleaning, sandblasting,
welding, and painting. Figure 5 shows a maintenance procedure that
includes the operations of disassembly, degreasing, inspection, repair,
and reassembly. The unit operations are shown as blocks on the
diagrams. Material flows into and out of each operation are depicted
as arrows. Each arrow is labeled to identify the material being
represented. Wastes are shown on the diagram just like any other
material flow.

It is important to recognize that the arrows can indicate material
flows in time as well as through equipment. In the maintenance
procedure shown in Figure 5, the arrows depict the pump as it
undergoes the sequence of operations over time. The pump itself will
be stationary during most of the process.

For a complex process, preparing a workable process flow diagram
generally requires subdividing the process into two or more
subprocesses. Efforts can then be focused on developing a diagram for
the more promising subprocess. The other subprocesses can be ad-
dressed by other teams or as available resources permit.

Materials accounting

A materials accounting for a process is similar to an engineering
mass balance in that it attempts to quantify and balance process
inflows and outflows. The materials accounting, however, is much less
rigorous than is amass balance. The purpose of a materials accounting
is to ensure that substantially all material flows have been accounted
for. Purchasing records and other readily available information are
used to provide semiquantitative data on the size of each material
flow. Installation of flow meters or other stream monitoring equipment
is not generally performed.

Descriptive audit process

The process flow diagram and materials accounting are prepared
before the audit team's tour of the facility. Preparation of the diagram
can be the responsibility of an individual or the team as a whole. The
plan tour is then used to verify that the diagram accurately depicts the
process as it operates in the plant. Areas of opportunity where further
investigation seems warranted can be easily highlighted on the
diagram. After completing the audit, the audit team has an in-depth
understanding of the process and the sources of the process losses.

Advantages of the descriptive approach

The descriptive approach has many advantages when compared
with the use of checklists. Information gathering using the descnp
tive approach is much more focused. All information that is collectec
contributes directly to the team's understanding of the fundaments,
aspects of the process. The process flow diagram conveniently suit

For a complex process,
preparing a workable
process jlow diagram
generally requires
subdividing the process
into two or more


Pollution Prevention Review/Summer 195:

Contrasting Approaches to Pollution Prevention Auditing

Figure 5. Pump Maintenance Operation



Air Emissions
(0.01 lb-/hr)

Spent Degreaser ^—
(0.99 lb./hr)

Z— Degreaser
(1 lb./hr)


Broken Parts


New Parts





Pollution Prevention Review/Summer 1991

Robert B. Pojasek and Lawrence J. Call

For small facilities with
limited resources, a
prescriptive audit can. be
implemented and can
improve operating
practices. For larger, more
complex facilities, a
descriptive audit can lead
to more fundamental
waste reductions.

marizes this information in one or two sheets.

Additionally, the descriptive approach is dynamic and can be used
to describe any type of operation. Production and maintenance
operations can be conceptualized using these diagrams. The dia-
grams can accommodate any sequence of operations, including series
flows, and recycling streams. The need to customize checklists to fit
a particular process or industry is eliminated.

Most importantly, the process flow diagram makes clear the
source of each loss. Knowing the source of each loss provides the
foundation upon which ideas for reducing or eliminating the loss can
be developed.

Disadvantages of the descriptive approach

The descriptive approach, despite its power, does have some
drawbacks. The most important of these is that the descriptive
approach is potentially more technically demanding than the pre-
scriptive approach. A technical background and some familiarity
with the process are generally required to prepare a meaningful
process flow diagram. This additional expertise may not be available
in a small facility.

This disadvantage does not present an insurmountable problem.
There are a number of excellent references that discuss the basics of
preparing a process flow diagram.5 Alternatively, the required ex-
pertise can be supplied by an outside consultant or agency.

A Combined Audit Approach

The descriptive audit approach is a fundamental approach to
pollution prevention auditing in that it identifies the sources of losses,
making it much easier to develop meaningful reduction alternatives.
This is not to imply that the descriptive approach is the only approach
that can be used or that the prescriptive approach cannot work. In
fact, many facilities have made significant and rapid progress using
simple checklist audits.

In presenting the descriptive approach, the aim has been to
provide environmental professionals and others with another tool for
auditing. Common sense dictates that whatever approach is selected
should be based on the task at hand. For small facilities with limited
resources, a prescriptive audit can be inexpensively implemented and
can improve operating practices. For larger, more complex facilities,
a descriptive audit can lead to more fundamental waste reductions.
Checklists can be used to collect information needed to fill the data
gaps identified during development and verification of the process
flow diagram.

Verification of the process flow diagram leads both the inspectors
and the equipment operators to a true understanding of the function-
ality of the equipment and the manner in which chemical losses can
occur. Without this approach, an operator usually contemplates how
to operate the equipment but does not focus on what is actually

234	Pollution Prevention Review/Summer 1991

Contrasting Approaches to Pollution Prevention Auditing

The key to a successful
pollution prevention audit
is to cleariy identify at the
start the audit's objective
and resource constraints
and choose an approach
based on these factors.

happening. By understanding what causes the losses, ideas for
equipment redesign, material substitutions, or changes in process
conditions that will reduce the losses can be more easily developed.

Such a combined audit approach was informally tested using the
student teams taking a pollution prevention course at Tufts Univer-
sity. Teams used both the prescriptive approach and the descriptive
approach to audit a single process. The students expressed a strong
preference for the descriptive approach because it allowed them to
understand the functionality of the process. Nevertheless, they saw
value in the checklists as a vehicle for collecting important process in-
formation and for assessing the completeness of the descriptive audit.

In Conclusion

The key to a successful pollution prevention audit is to clearly
identify at the start the audit's objective and resource constraints and
choose an approach based on these factors. For companies that have
the appropriate resources, the descriptive audit is a targeted ap-
proach that can help develop a rapid understanding of the relation-
ship between wastes and the manufacturing process.* Incorporating
the descriptive audit approach into pollution prevention audits can
help companies move beyond first-tier opportunities to achieve funda-
mental reduction in waste generation. It is expected that use of the
descriptive approach will increase as the shortcomings of the pre-
scriptive approach become more apparent. ~


1.	In "Waste Reductions Audits," in Eric B. Rothenberg and Dean J. Telego (eds.).
Environmental Risk Management—A Desk Reference (RTM Communications. 1991).
Dr. Pojasek introduced the concept of the descriptive pollution prevention audit and
also discussed the idea of using this approach for independent validation of existing
pollution prevention programs. Readers may wish to refer to this article for more
information on this aspect of the audit process.

2.	United States Environmental Protection Agency, Waste Minimization Opportunity
Assessment Manual (EPA/625/7-88/003, July 1988).

3.	Deborah Hanlan and Carl Fromm, "Waste Minimization Assessments,* in Harry
Freeman (ecL), Hazardous Waste Minimization (McGraw-Hill, 1990).

4.	These checklists are in the Guides to Pollution Prevention for The Pesticide
Formulating Industry (625/7-90-004), The Paint Manufacturing Industry (625/7-90-
005), The Fabricated Metal Industry (62Sr7-90-006), The Printed Circuit Board
Manufacturing Industry (625/7-90-007), The Commercial Printing Industry (625/7-
90-008), Selected Hospital Waste Streams (625/7-90-009), and Research and Educa-
tional Institutions (625/7-90-010). All guides are available from CERL, Technology
Transfer, USEPA. P.O. Box 19963, CincinnaQ, OH 45219-0963.

5.	See, for example, Ernest E. Ludwig, Applied Process Design for Chemical and
Petrochemical Plants (Gulf Publishing, 1964) and J. P. ODonnell, "How Flowsheets
Communicate Engineering Information,"CAemicaiEngineering (McGraw-Hill. 1957'.

6.	The manner in which this descriptive audit approach fits into an overall pollur.or.
prevention program is described by Dr. Pojasek in "Pollution Prevention Ptoctps
sion," in Eric B. Rothenberg and Dean J. Telego (eds.). Environmental Risk Mc i
agtment—A Desk Reference (RTM Communications, 1991).

Pollution Prevention Review/Summer 1991	^35

annotated bibliography



March 1988
Seventh Edition

Prepared for

Regulatory Innovations Staff
Office of Policy, Planning and Evaluation
VS. Environmental Protection Agency
401 M Street, SW
Washington, D.C. 20460

The seventh edition of the bibliography on environaental auditing was

prepared	by Policy, Planning, t Evaluation, Inc., Vienna, Virginia, under

contract	No. 68-01-7252 for the Regulatory Innovations Staff, Office of Policy,

Planning	and Bvaluation, U.S. Environaental Protection Agency.


This bibliography is meant to be a reference for individuals interested in
environmental auditing, i.e., internal management systems for reviewing facility
operations and practices to assess and verify compliance with environaental
regulations and corporate policies. Environaental auditing, as an internal
aanafeaent tool, offers significant potential benefits for the environment, for
industry, and for state and Federal agencies. It can better proaote reduction in
emissions, effluents, and solid wastes; assure corporate management that its
facilities are in compliance with environaental requirements; and identify areas
of potential cost savinga while reducing strains on governmental enforcement
prograas. EPA has endorsed the concept of environaental auditing and is
coasiitted to encouraging ita expanded use.

This bibliography categorizes entries by subject area, based on each
publication's aajor area of eaphasia. Many publications cover several subject
areas, but each publication is listed only once in this bibliography. The
subject areas are:

A.	General Literature on Environaental Auditing

B.	Audit Systea Design and Methodology

C.	Confidentiality, Disclosure, and Other Legal Issues

D.	Industry Experience and Perspectives

E.	Environaental Impairaent Liability, Risk Assessaent, & Property Transfer

F.	Federal, State, and Local Perspectives and Activities

Bach entry includes the author and type of docuaent as well as a brief
abstract which suaaarizes the subject areas covered. The annotation should allow
the reader to determine whether a publication covers subjects other than the one
under which the publication is categorized in this bibliography. In addition,
each entry provides the source froa which the reader Bay obtain the docuaent.
Sow of the materials listed aay be obtained at no cost; however, others may have
to be purchased from the source listed or obtained froa a library.

This bibliography does not exhaust the list of all of the published
articles, papers, and reports on environmental auditing. Rather, it includes
those publications providing unique perspectives and facts on environaental
auditing or which seea of greatest potential use to organizations establishing
auditing prograa. Any co—ante or questions regarding this bibliography can be
directed to the Environaental Auditing Project, Regulatory Innovations Staff (PM-
223), U.S. Environaental Protection Agency, 401 M Street, S.W., Washington, DC
20460 or (202) 382-2726.

Note: The materiala included in this bibliography have not been endorsed by EPA
or any other government entity. Any views or interpretations contained in these
referenced documents are solely each author's and should not be attributed to




A-4, A-10, A-12, B-l, D-l, D-2,



Atkins, Patrick


Barisas, Susan et.al.


Barzotti, Joseph P.


Basta, Michael F.


Blakeslee, H. Willian


Bleiweiss, Shell J.


Brandwein, David


Brooknan, Gordon T.


Cahill, Lawrence B. (editor)


Capasso, Edward


Case, David R. (editor)


Christiff, Harold


Cogen, Richard M.



Cundall, Cheryl L.


Cutler, Robert W.



Danzig, Allen J.



DiBerto, Maryanne


Edward, Janes R.


Eisen, Ellen




vironaental Law Institute



ohrenthold, Paul D.


Allison, Richard C.
Andrews, Richard N.
Arthur D. Little. Inc.

Fischer, Kenneth E.
Fleckenstein, Leonard J.
Ford, Mary Elizabeth
Giannotti, David A.

Gibson-, Michael M.

Goerth, Charles R.
Goldsaith, Harold I
Golob, Richard S. (editor)
Grabowski, Theodore M.
Greeno, J. Ladd
Guida, Joseph
Hall, Ridgway M.

Harlow, Kirk C.

Harrison, Lee (editor)
Hedstroa, Gilbert S.

Henz, Donald J.

Holtzclaw, Gary D.
Kalagnaaan, Raaesh
Kane, Rayaood W. (editor)
Keller, Jaaea R.

Kent, Thoaaa D.

Koha, Robert F.

Krouse, Richard S.
Levenatein, Charles
Maclntyre, Stephen T.
Marcus, Alfred A.


A-6, K-l







A-l, B-6

A-l, A-5

A-l, E-2

A-12, C-l







Marfolis, Joshua 0.

Maya, Richard
MiIvy, Paul
Nadel, Mark V.

National Wildlife Federation

Neaeth, John C.

Palaiaano, John

Pearse, Williaa M.

Pico, Richard F.

Plaut, Jonathan

Policy Planning t Evaluation

Pollard-Cavalli, Roberta

Price, Courtney M.

Raffle, Bradley I.

Reed, John W.

Reed, Phillip 0.

Rene11a, John R.

Rhodes, Ralph L.

Robertson, Edwin B. Jr.

Roy F. Weston, Inc.

Russell, David L.

Saaela, O.A.

Scheid, Daniel C.

Shields, Jacqueline

Singh, Jasbinder

Saith, Martin A.












A-3, F-2

C-l, C-2

A-8, A-9











A-7, D-8, F-3, F-4

Spiegel. Stuart J.	D-l

Stiahl, Fred	C-3

Struts, Deania E.	A-7

THC Environmental Consultants, Inc.	B-2

Truitt, Thomas et.al.	B-4

U.S. Air Force	B-2

U.S. Department of Energy	B-5

U.S. Environmental Protection Agency	8-1, r-1
U.S. EPA Nat'l Enforcement Inveat. Ctr. B-3

U.S. Sandia National Laboratoriea	B-6

Walker, Michael J.	C-l

Weiss, Malcola C.	A-10, C-5

Willborn, Walter	A-ll

Williams, John K.	D-4

Young, R. Victor	0-3


Title: Environmental Audits
Authors: Lawrence B. Cahill (Ed.) with Raymond W. Kane
Doc. Type: Book (5th Edition, March 1987)

Abstract: Discusses the concept of environmental auditing; its evolution, and
advantages and disadvantages; perspectives of EPA and state
regulatory agencies, including EPA's Environaental Auditing Policy
Statement and the Agency's guidance on including audit provisions in
settlement agreements; legal issues such as confidentiality and
liability; planning and implementing an environmental audit program
and evaluating the results; and techniques and tools for training
auditors. Includes a section on international audits, a survey of
audit programs of 20 companies, sample questionnaires, and audit

Source: Government Institutes Inc., 966 Hungerford Drive, #21, Rockville, MD

Title: Environaental Auditing: Fundamentals and Techniques
Author: J. Ladd Greeno, Gilbert S. Hedstrom, and Maryanne Difierto
Doc. Type: Book (1985) (Revised edition forthcoming: 1988]

Abstract: Addresses the emerging principles as well as the techniques of
environmental auditing, and provides practical guides to audit
program design and implementation. Includes appendices with audit
protocols and questionnaires for air and water pollution and solid
and hazardous waste management.

Source: Center for Environmental Assurance, Arthur D. Little, Inc., 15 Acorn
Park, Cambridge, MA 02140.


Title: Environmental Auditor
Author: Articles are contributed by various authors
Doc. Type: Professional Journal (Forthcoming May 1988)

Abstract: The journal is devoted to the applied practice of environmental
auditing, and is ฆultidisciplinary in approach. Its thesis is that
through environmental e^diting, businesses can anticipate and manage
pollution control problems and related environmental concerns,
rather than being forced to react to crises as they occur. A typical
issue will examine legal, scientific, and economic problems and
solutions, and raise environmental issues for further analysis.

Source: Published by Springer International, Springec^Verlag New York, Inc.,
175 Fifth Avenue, New York, New York 10010. More information may be
obtained from Robert S. DeSanto, Bditor-in-Chief, Environmental
Auditor. P.O. Box 3818, Hartford, CT 06103


Doc. Type:


"Study of the Benefits of Environmental Auditing Provisions in
Enforcement Settlements"

Jasbinder Singh, Policy Planning & Evaluation, Inc.

Report (1988)

Evaluates the effect of including environmental auditing provisions
in enforcement settlement agreements. Examines twenty settlement
cases requiring compliance and management audits and containing a
variety of settlement provisions. Demonstrates the benefits to
regulated entities, including improved environmental management
systems and business benefits; and identifies benefits to EPA,
including savings in inspection and enforcement resources, and
facilitation of follow-up inspections.

Prepared for the Office of Enforcement Policy, U.S. EPA Office of
Enforcement and Compliance Monitoring, 401 M Street S.W.,
Washington, D.C. 20460


Title: "Benefits to Industry of Environmental Auditing"

Author: Arthur D. Little, Inc., Center for BnvironBestal Assurance
Doc. Type: Report (August 1383)

Abstract: Identifies principal objectives of environmental auditing programs
and analyzes expected benefits to fins adopting environmental
auditing programs. Benefits are categorized in terms of two main
effects: (1) increased management effectiveness, and (2) increased
management comfort or aecurity that the company is meeting its
legal, corporate and ethical requirements. Identifies measures to
evaluate those effects.

Source: Prepared for the Regulatory Reform Staff, U.S. EPA. Available from
the National Technical Information Service, U.S. Dept. of Coamrce,
Springfield, VA 22161; NTIS No. PB85-240422-AS.

Title: "Safety in the Chemical Laboratory"

Author: Kenneth E. Fischer
Doc. Type: Periodical article

Abstract: Discusses the use of audits by many laboratories, including some in
colleges and universities, to ensure that their hazardous waste
handling operations are in compliance with state and federal
regulations. Covers areas cosmos to both state and federal
regulations, including: waste determination; facility requirements;
use of the manifest; vendor, transporter end site selection
requirements; and training, contingency planning, and documentation.
Referencea for checfcliats are provided.

Source: Journal of Chemical Education. September 1987, pp A207-A210


Doc. Type:

"Auditing Certification is no Guarantee for Quality
John C. Nemeth


Periodical article

Briefly discusses the issue of certificatior	environmebt&l

auditors. Presents the idea that one individual ^ at be able to
handle the myriad of disciplines affected by a typx.::l environmental
audit, making certification difficult. Raises, but doesn't resolve,
some regulatory issues involved in certification, such as licensing,
and competition among environmental auditing companies.

Source: Environmental Management News. September/October 1987, pg 17

Title: "Increased Assurance: The Response of Senior Management to Recent
Environmental, Health, and Safety Events"

Author: Gilbert S. Hedstrom
Doc. Type: Conference paper

Abstract: Review external and internal factors resulting in the development
of environmental auditing as an environmental management tool to
assure compliance. These factors include increased regulatory
enforcement, internal cost control, integration of environmental
health and safety programs, and decentralization. Describes the
characteristics of leading environmental, health, and saf^y audit
programs. Explores likely directions for this emerging discipline.

Source: The author is with Arthur D. Little, Inc., Acorn Park, Cambridge, MA
02140-2390. Presented at the Annual Meeting of the American
Institute of Chemical Engineers, August 24-27, 1986, Boston, MA.


Title: "Who Should Conduct the Environmental Audit?"

Author: 0. A. Samela
Doc Type: Conference paper

Abstract: Reviews definitions of environmental auditing and outlines the
elements of an effective environaental auditing system. Contrasts
the advantages and disadvantages of performing an in-house versus
using outside contractors. Concludes that well-established, larger
firms would benefit from in-house audits while -smaller,
inexperienced firms may require external assistance. For any firm,
an outside audit is recoanended when the firm's public image is at

Source: The author is with Stone and Webster Engineering Corporation, 250 W.

34th Street, 1 Penn Plaza, New York, NY, 10119. Presented at the
Annual Meeting of the American Institute of Chemical Engineers,
August .24-27, 1986, Boston, MA.

Title: "Using Environaental Auditing as an Affirmative Compliance Tool"
Authors: Mary Elizabeth Ford and Richard M. Cogen
Doc. Type: Conference paper

Abstract: Identifies and describes three major types of environmental audits
(pre-purchase, one-time or "snapshot", and continuing). Provides
constructive guidance regarding; (1) determining the need for an
environmental auditing program; (2) establishing an environmental
auditing program; (3) maintaining confidentiality of audit
information; (4) staffing the audit; (5) the use of checklist and
questionnaire; and (6) the audit follow-up. Concludes that a well-
implemented auditing program can aid a company in effectively making
a transition from a reactive to an affirmative environmental
compliance program.

Source: Published in the Proceedings of the Industrial Waste Symposium at
the 57th Annual Conference of the Water Pollution Control
Federation, September 30-October 1, 1984. The authors are with

Nixon, Hargrave, Devans,
Tower, Rochester, NY 14603.

and Doyle, P.O. Box 1051, Lincoln First


Title: "Environmental Audit Program Development."

Authors: Joshua 0. Margolis, Dennis E. Struts, and Richard S. Krouse
Doc. Type: Conference paper

Abstract: Presents overview and brief history of environmental auditing.

Provides questions about a company's current environmental
management program to use in determining the need for environmental
auditing. Discusses the different types and scopes of an EA
program, the advantages and disadvantages, and the issues that can
be addressed. Reviews procedures for staffing and organization.

Source: Mr. Margolis is with HMT/AER*X Division, 1625 I Street, NW, Suite
719, Washington, DC 20006. Presented at HazMat 1985, Philadelphia,

sntal Auditing and

Title: "A Contingency View of Corporate Enviroc
Implications for Public Policy."

Author: Martin A. Smith
Doc. Type: University dissertation

Abstract: Analyzes the factors influencing management decisions on
environmental auditing. Compares characteristics of firms with
auditing programs to those without and investigates reasons to
establish programs, including efforts to meet societal
responsibilities, protect reputations, and cope with- thereased
complexity. Concludes that the major factor affecting the decision
to establish auditing programs is the complexity of corporate
environmental organization and activity.

Source: Submitted to the faculty of the Department of Environmental Sciences
and Engineering, University of North Carolina, Chapel Hill, NO,


Title:	"The Environmental Audit: Friend or Foe?"

Author:	Charles R. Goerth

Doc. Type:	Periodical article

Abstract:	Presents the views of a number of experts in the field of

environmental auditing, including
Explains that although an audit is
cite the company for any violations
company in its dealings with EPA.
effective auditing specified in EPA's
Statement", including support from
regularity, and clear reporting.

lawyers and EPA personnel,
no guarantee that EPA will not
uncovered, it will help the
Lists the seven conditions for
"Environaental Auditing Policy
top management, objectivity,

Source: Converting Magazine, pp 66-74, January 1987

Title: "Environmental Auditing: Practices in Canadian Industry"

Author: J.W. Reed
Doc. Type: Journal article

Abstract: Discusses the use of environmental auditing by Canadian firms as
part of their overall approach to environmental protection and
compliance assurance. Describes the results of a survey of the
Canadian industrial sector, including the fact that individual firms
use auditing programs to meet diverse objectives, such as verifying
compliance with environmental regulations, identifying environmental
risks and hazards, and limiting corporate liability.

Source: Pulp t Paper Canada. Vol. 88, No. 6, June 1987.


Title: Conservation Exchange
Author: National Wildlife Federation
Doc- Type: Newsletter

Abstract: Several articles in the newsletter's Fall 1987 issue addressed
different aspects of environaental auditing. Among aspects
discussed are: the institutionalization of environaental auditing
within industries; formation of environmental auditing
organizations; reasons for popularity; benefits; and the lack of
national certification standards for environmental auditors.
Recommends industry efforts to establish uniform educational and
professional standards for the field. Speculates that federal
legislation mandating environmental auditing for regulated entities
is not likely in the near future. Discusses the efforts of a few
states to use legislative leverage to encourage environaental

Source: Conservation Exchange. Vol. 5, No. 1, Fall 1987. Published by the
National Wildlife Federation, 1412 Sixteenth St. N.W., Washington,
D.C. 20036

Title: "Environaental Auditing: A Review of Current Practice"

Author: John W. Reed
Doc. Type: University thesis

Abstract: Describes environaental auditing and its roles and objectives in
industry, drawing comparisons between EA and financial auditing.
Defines the characteristics of audits with particular emphasis on
management structure within the company conducting audits. Benefits
of audits are seen to be an increased awareness of environaental
regulations which would culminate in increased environmental
protection. Disadvantages are seen primarily to be the newness 6f
EA, and the misunderstanding of ideas. Identifies disclosure and
confidentiality as issues that may be a disincentive to auditing.

Source: Submitted to York University, March 1984. Resource Center, Faculty
of Environmental Studies, York University, 333 Lumbers Building,
North York, Ontario M3J 1P3. Also available from Publications,
Conservation and Protection, Environment Canada, Ottawa Ontario KlA
0E7 (Pub. Ref. • IP-17). Mr. Reed is with Texaco, Canada Inc., 1210
Sheppard Ave. East, Willowdale, Ontario M2K 2S8.


Title: "Environaental Auditing: An Overview"

Author: Arthur D. Little, Inc., Center for Environaental Assurance
Doc. Type: Report (1983)

Abstract: Describes the different functions and objectives which
private-sector environaental auditing can serve. Develops an audit
process designed to create an audit report giving corporate aanagers
reliable inforaation on which to base decisions.

Source: Center for Environaental Assurance, Arthur D. Little, Inc., 15 Acorn
Park, Cambridge, Massachusetts, 0Z140. Presented at Seainar on
Private Sector Environaental Auditing, February 15, 1983,
Washington, DC.

Title: "Environaental Auditing: What Is It?"

Author: John Palaisano and Malcola C. Weiss
Doc. Type: Journal article

Abstract: States that different professional groups, each vying for auditing
accounts, iapart to it different attributes promoting their own
interests. Notes three ayths about auditing: (1} disclosure
problems outweigh the benefits gained by auditing; (2) benefits
derived froa auditing are primarily psychological, not financial;
and (3) snail businesses cannot adopt auditing because costs are
prohibitively high.

Source: Environaental Analyst; Vol.4. Nd.11, Novcaber 1983, pp. 13-17. Mr.

Palaisano and Mr. Weiss are with RMT/AKBtX Division, 1625 I Street,
NW, Suite 719, Washington, D.C. 20006.


Title: "Compendium of Audit Standards"

Author: Walter Willborn
Doc. Type: . Report (1983)

Abstract: Sunarizes existing audit stanusrds and guidelines issued by: the
Institute of Internal Auditors, the American Institute of CPAs,
Canadian Standards Association, ANSI/ASME, Government of Canada, and
the U.S. General Accounting Office. Emphasizes cononalities among
these standards. Addresses general features of audit standards and
major audit issues such as: auditor requirements, organization,
audit planning and procedures, audit reports, audit completion, and
quality assurance.

Source: American Society for Quality
Milwaukee, Wisconsin 53203.

Control, 230 W. Wells Street,

Title: "A Practical Look at Environmental Audits"

Author: Joseph Guida
Doc. Type: Journal article

Abstract: Discusses the rise of the audit trend and advantages gained by using
an auditing system. Broadly defines different approaches available
to corporations instituting auditing programs. Concluded*that the
strategy employed by a particular firm is dependent upon the
characteristics of that firm and the type of data corporate officers

Source: Journal of the Air Pollution Control Association.
August 1982, pp. 568*.

Vol. 32, No.5,


Doc- Type:


"Internal Environmental Review Programs — Pitfalls and Benefits"
Thomas D. Kent
Journal article

Allied Corporation's associate general counsel argues that using the
term "audit" to describe internal environaental review programs
might increase the risk of legal sanctions for negligent
interpretations. Describes the genesis of the "environmental
surveillance" program at Allied. Points out possible pitfalls in
such programs, which are outweighed by far by the benefits. States
that an ounce of cost-effective prevention in addition to making one
feel good, is far better than a pound of lawsuits, negotiated or
imposed cleanup schedules, and headaches.

Journal of the Water Pollution Control Federation.
57, No. 3, pp. 191-195.

March 1985, Vol.

Title: "Benefits of Environmental Auditing: Case Examples"

Author: Arthur D. Little, Inc., Center for Environmental Assurance.

Doc. Type: Report (December 1984)

Abstract: Documents the benefits of environmental auditing as reported by
managers responsible for their organizations', environmental audit
program. In some cases, the examples illustrate actual benefits
derived form individual audits, while in other cases the benefits
result from having conducted a number of audits over a period of
time. Provides insights into how environmental auditors conduct
their field work, what type of situations they are likely to
uncover, and how facility-level environmental management can improve
as a result of an audit.

Source: Prepared for the Regulatory Reform Staff, U.S. EPA. Available from
the National Technical Information Service, U. S. Dept. of Commerce,
Springfield, VA 22161; NTIS No. PBB5-239531-AS.


Title: "Certified Environmental Audits: A Proposal"

Authors: Ellen Eisen and Charles Levenstein
Doc. Type: Conference paper

Abstract: Proposes the developaent of an independent and certified compulsory
environmental auditing system for all foreign facilities of any U.S.
company raising domestic funds. Suggests that funders would serve
as source of pressure for compliance with environmental regulations.
Compares the World Bank compulsory audit system with EPA's voluntary
approach, and proposes a model similar to the World Bank's.

Source: Or. Eisen is Asst. Prof, of Occupational Health, Harvard School of
Public Health, Boston, MA 02115. Dr. Levenstein is Visiting Prof,
of Management, Center for Productivity Enhancement, University of
Lowell, Lowell, MA 01854. Presented at the Annual Meeting of the
American Association for the Advancement of Science, May 30, 1986,
Philadelphia, PA.



Doc. Type:


"Environmental Auditing Skills and Techniques Workbook"

Arthur D. Little, Inc., for the Bdison Electric Institute
Manual (1987)

Provides the field auditor with the basic skills and techniques
needed to conduct an effective audit. Topics include the use of
audit protocols and working papers; the interview process and ways
to increase its effectiveness; understanding and assessing internal
controls of the organization; soapling techniques; and evaluating
audit results and reporting the findings. The workbook includes a
comprehensive glossary of auditing tex

Edison Electric Institute, Environaental Auditing Task Force, 1111
Nineteenth St. N.W., Washington, D.C. 20036

Title: Environaental Audit Protocol for EPA Facilities (Final Draft)

Author: U.S. Environaental Protection Agency
Doc. Type: Manual (November 1986)

Abstract: Protocol intended to serve'as a guide for auditors to plan and
conduct environaental audits at EPA facilities. Consists of four
major sections: (1) Pre-audit activities (e.g. notification review
of background information, agency contacts); (2) Understanding
manageaent systeas (e.g. review of audit plan); (3) Gathering audit
evidence (on different environaental areas); (4) Evaluating evidence
and reporting findings. Includes observation checklist for air and
water pollution, spill prevention, and hazardous waste aanageaent.
Includes complete questionnaire.

Source: Environaental Compliance Program, Occupational Health and Safety
Staff (W-273), U.S. Environmental Protection Agency, 401 M Street
SW, Washington, DC 20460.


Title: A Procedure for Evaluating Hazardous Waste Vendor*

Author: TRC Environmental Consultants, Inc. for Edison Electric Institute,
Environmental Auditing Task Force.

Doc. Type: Manual (1988)

Abstract: Manual for use by an electric utility company to understand the
benefits and purposes of auditing hazardous waste contractors,
particularly to reduce waste generator liability. Reviews use of
audit questionnaires that assess technical, financial, and
management aspects of vendors to determine risk potential.
Discusses alternative approaches to performing audits, and includes
sample facility site audit (35 pp), telephone audit (4 pp), and
property transfer audit (30 pp).

Source: Edison Electric Institute, 1111 19th Street NW, Washington DC 20036.


Doc. Type:


Environaental Compliance Assessment and Manage

U.S. Air Force

snt Program (BCAMP):

Manual (1986)

A protocol manual for conducting internal audits to assess the
environmental compliance status of Air Force installations.
Siamarizes Federal, state, and local regulations, lists key
compliance requirements, and provides protocol checklist for the
following compliance categories: air emissions; wastewater
discharge; aolid and hazardous waste management;
pesticides/herbicides; PCB management; drinking water; POL
it; and hazardous materials management.

Major Boy Solomon, AF/LEBV, Boiling Air Force Base, Washington, DC,
20332-5000. Availability of this document may be limited.


Doc. Type:


A Practical Guide to Plant Environmental Audits
H. William Blakeslee and Theodore M. Grabowski

Book (1985)

Provides step-by-step
air, water, waste,
Provides information
especially at small

advice on auditing a plant's compliance for
oil spills, toxic substances and others,
for the engineer responsible for compliance,
and medium-sized manufacturing and chemical

Van Nostrand Rheinhold Company, Inc., 135 West 50th Street, New
York, NY, 10020. Mr. Blakeslee is with CertaioTeed Corporation,
1400 Union Meeting Road, Blue Bell, PA 19422. Mr. Grabowski is with
Sun Refining and Marketing Company.

Title: Multi-Media Compliance Audit Procedures
Author: EPA National Enforcement Investigations Center
Doc. Type: Manual (June 1987)

Abstract: Details the procedures used by EPA or state inspectors authorized to
conduct multi-media compliance inspections of facilities. The
approach is intended to more effectively schedule the time of
investigatory personnel and support a rational system for analyzing
the compliance status of particular sources. Discusses the roles
and responsibilities of inspectors.

Source: U.S. EPA, National Enforcement Investigations Center, Federal
Center, Bldg. 53, Box 25227, Denver, Colorado 80225. EPA Report No.



gnvironmental Audit Handbook: Basic Principles of Environmental
Compliance Auditing

Doc. Type



H. Truitt, et. al.

Book (1983)

Comprehensively addressee the managerial, legal and procedural
elements necessary to produce a quality environmental audit. The
audit is characterized as a way to Measure a plant's compliance
performance against regulatory standards. Includes a lenfthy
section on planning and conducting audits as well ss evaluating the
data generated. Addreasee legal issues arising from potential
disclosure of audit information under. SBC and major federal
environmental regulations.

Executive Enterprises Publications Co., Inc., 33 West 60th Street,
New York, NY, 10023. Mr. Truitt is with Wald, Harkrader L Ross,
1300 Nineteenth Street NW, Washington DC, 20036

Title: "Applicability of Environmental Auditing to Underground Storage

Author: Roy F. Weston, Inc.

Doc. Type: Draft report (1986)

Abstract: Identifies recent Federal, state, and local regulatory initiatives
for underground storage tanka. Sumarizes and describes auditing
procedures applicable to tank assessment and management syston.
Includes sample audit check lists for underground storage tanks.

Source: Prepared for the Regulatory Reform Staff, FM-223, EPA, 401 M Street,
SW, Washington, DC 20460.


Title: "Reporting Environmental Audit Findings"

Author: Ralph L. Rhodes
Doc. Type: Conference paper

Abstract: Discusses factors to be considered ia assuring effective
comnication of environmental auditing results, including: (1)
fundamental principles of effective ccmmication; (2) appropriate
reporting and confidentiality of information, and (3) opportunity
for additional conunication.

Source: The author is with Allied-Signal, Inc. PO Box 2332B, Morristown,
NJ, 07960. Presented at the Annual Meeting of the American
Institute of Chemical Engineers, August 24-27, 1986, Boston, HA.

Title: The Environmental Survey Manual
Author: U.S. Department of Bnergy
Doc. Type: Manual (August 1987)

Abstract: Provides guidance to the U.S. Department of Bnergy's Survey fc
Sampling and Analysis teams conducting a one-time environmental
survey of aajor DOE operating facilities. [This survey differs from
an environmental audit: an audit is generally characterized as a
regulatory compliance check that may alao involve a review or
critique of management systems. In contrast the Survey is a
compilation or inventory of environmental problems for purposes of
prioritization.) The various sections of the manual deal with:
proceduraa and protocols to be used by the Survey teams; criteria to
evaluate existing environmental data; generic technical checklists;
health and safety guidelines for the personnel conducting the
Survey; required formats for the Survey reports; issues of problem
identification and prioritization; and sapling and analysis

Source: U.S. Department of Bnergy, Office of the Assistant Secretary
Environment, Safety, L Health, Office of Environmental Audit, 1000
Independence Ave., S.W., Washington, D.C. 2058S. Available from the
National Technical Information Service, U.S.' Department of Cooaerce,
Springfield, VA 22161. Ref. No. DOE/BH-0053



Doc. Type:

'An Approach to ES fc H Assurance Progress for Institutions"


Sandia National Laboratories, Andrew
Jr., editors

Report (Septeaber 1982)

Ellingson and Charles Trauth,

A collection and condensation of material contained in 17 separate
Sandia National Laboratories' publications concerning Environmental,
Safety and Health (BSU1) progress. Provides a detailed description
of the coaponents of an ES&H prograa including assurance, staff
review activities and appraisals, institutional emergency response
programs and institutional accident investigations.

Prepared by Sandia National Laboratories, Albuquerque, New Mexico
87185. Volume I: Institutional ES&H Staff Functions available from
National Technical Information Service, U.S. Dept. of Commerce,
Springfield, VA 22161; NTIS No. DE-83-004254.

Title: "Increasing the Effectiveness of Environmental Auditing Programs"
Author: J. Ladd Greeno
Doc. Type: Conference paper


Abstract: Examines the impact of various program design and implementation
considerations on the effectiveness of an audit program. Audit
objectives, approach and staffing are key determinants of the
effectiveness of an environmental audit program. It is important
that these three aspects of the design and implementation of an
audit program be congruent and mutually supportive.

Source: Mr. Greeno is with the Center for Environmental Assurance, Arthur D.

Little, Inc., 15 Acorn Park, Cambridge, MA 02140. Presented at the
78th Annual Meeting of the Air Pollution Control Association, June
18, 1985.


Title: "Managing Your Environmental Audit"

Author: David L. Russell
Doc. Type: Periodical article

Abstract: Discusses problems frequently uncovered during an audit and tips for
conducting an audit. Suggests what a facility manager should
consider before, during, and after an audit of his operations is
conducted and what to do if serious problems are uncovered.

Source: Cheaical Engineering. June 24, 1985, pp. 37-43.

Title: Environmental Protection Appraisals: A Suggested Guide for U.S.
Department of Energy Field Organizations, and

Internal Environaental Protection Audita: A Suggested Guide for
U.S. Department of Energy Facilities.

Author: Susan Barisas, et al.

Doc. Type: Audit Manual (August 1983) and Appraisal Manual (March 1985)

Abstract: Prepared for use by DOE facilities as aids for conducting internal
environmental protection audits and on-site operating level
appraisals. Consist of sets of audit questions organized with
respect to specific areas of environmental protection (e.g.,
nonradioactive air pollution, asbestos, radio-nuclides, toxic
substances, PCB materials, hazardous waste, laboratory quality
assurance). Develops questions within each specific area from
existing DOE orders, executive orders, federal statutes and
regulations. Provide methodologies which have the potential to be
used by facilities other than DOE's.

Source: Argonne National Lab (Reports *ANL/EES-TW-237 and ANl/EES-TM-264),
Energy and Environmental Systems Division, Integrated Assessment and
Policy Evaluation Group, 9700 S. Cass Ave., Argonne, IL, 60439.



"Technical Coosiderations in Conducting a Hazardous Waate Facility

Author: Edward Capaaao
Doc. Type: Conference paper

Abetract: Discuaaea technical aapecta to be conaidered in conducting an audit
at a coapany-owned hazardous waate storage facility. Elements of an
effective audit include aanageaent and teas support t teas
objectivity, audit boundaries, and review procedures and follow-upe.
Also preaenta procedures within the audit that ahould be given
special attention.

Source: The author ia with Troy Cheaical Corporation, 1 Avenue L, Newark NJ,
07105. Presented at HAZPRO, April 1986, in Baltiaore MD.

Title: "Can You Trust Your Environmental Auditing Prograa?

Author: Alfred A. Marcus and Mark V. Nadel
Doc. Type: Report (Noveaber 1983)

Abetract: Discusses organizational issues affecting environmental audits and
whether aanagera can have faith in the capability and integrity of
their auditing prograa. Suggests factora managers say take into
account when eatabliahing or upgrading audit prograaa. Because so
aany variables exiat with in a fira regarding audit ayataaa,
aanagera ahould take a position allowing thaa to evaluate evolving
prograae and sake corrections when appropriate.

Source: Prepared for Regulatory Reform Staff, U.S. EPA. Available froa
National Technical Information Service, U.S. Dept. of Coverce,
Springfield, VA 22161; NTIS No. PB 86-240166-AS.



Title: "Environmental Auditing: Reaching the Bottoa Line in Compliance"
Authors: Allen J. Danzig, Michael J. Walker, and Courtney M. Price
Doc. Type: Journal Article

Abstract: Describes EPA's efforts to encourage environaental auditing by
regulated entities. Discusses the evolution of government and
corporate interest in environaental auditing and its benefits; EPA's
efforts to promote environaental auditing through policy stateaents;
and major settlement agreements under TSCA and RCRA that contain
environaental auditing provisions. Concludes that audit prograas
save money for regulated entities in the long run, and create an
ataosphere of improved cooperation with regulated entities, while
complementing the latters' compliance efforts.

Source: National Environmental Enforcement Journal. Vol. 2, No. 1, January
1987, pp 3-14. Published by the National Association of Attorneys
General, Suite 403, 444 North Capitol St., Washington, D.C. 20001

Title: "Risk of "Saoking Gun" Papers is Outweighed by the Benefits"

Author: Thomas D. Kent
Doc. Type: Periodical article

Abstract: Focuses on the environmental compliance prograas at a particular
company, Allied-Signal Inc. Describes the corporate-wide
"Environmental Surveillance Program", which is the company's term
for an environmental audit program. Raises the issue of potential
penalties and liabilities arising out of accidental release of
reports prepared as part of the program; and suggests ways to
ainiaize the risk of potential damage to the company. Concludes
that the econoaic, safety, and health benefits of such a program
outweigh the risk of being found in non-compliance with regulations.

Source: Preventive Law Reporter. Vol. 6, No. 3, pp 12-16, September 1987


Doc. Type:

"Legal Considerations in Environmental Audi;. Uacisions'
Shell J. Bleiweiss

Periodical article

Discusses the legal benefits of conduct
including assuring corporate compliance at t
potential liability, and improving public
also be critical factors in negotiating the saie or acquisition of
property or stock. Concludes that audits must be carefully planned
to maximize credibility while protecting confidential and
potentially damaging information.

ironmental audits
: level, reducing
i<.cions. Audits can

Source: Chemical Engineering Process. January 1987, pp 15-19


Doc. Type:


"Environmental Auditing: Developing a 'Preventative Medicine*
Approach to Environmental Compliance"

Courtney M. Price and Allen J. Danzig

Journal article

Reviews EPA effort to encourage use of environmental auditing and
development of EPA auditing policy with emphasis on Agency access to
audit results. Explores the evolution of corporate interest in
environmental auditing and identifies benefits gained by firms
instituting auditing programs. Includes major settlement agreements
containing environmental auditing proviaions.

Loyola of Los Angeles Law Review. Vol. 19, No. 4, pp. 801-824, 1986.
Ms. Price is a partner with Rivkin, Radler, Dunne, and Bayh, 1575 I
St., NW, Suite 1025, Washington DC 20005. Nr. Danzig is Special
Assistant to the Assistsnt A
Title: "Environmental Auditing"

Author: Fred Stiehl
Doc. Type: Conference paper

Abstract: Reviews state and federal approaches to the concept of environmental
auditing and principles governing EPA's use of auditing in
enforcement programs. Addresses two main concerns expressed in
public coaaents to EPA's programs: (1) EPA request for audit
report* and (2) potential use of audits in enforcement action*.
Discusses current issues EPA ia evaluating that will affect use of
environmental auditing in enforcement settlements.

Source: The author is with the Office of Enforcement and Compliance
Monitoring, LE-134S, EPA, Washington, DC, 20460. Presented at
HAZPRO, April 1986, Baltimore, MD.


Doc. Type:


"Duties to Report or Disclosure Information on the Environmental
Aspects of Business Activities"

Environmental law Institute

Report (September 1985)

Delineates corporate obligations to record and report information on
the environmental and health impacts of their activitiea and EPA
obligations to disclose or protect such information. Examines: (1)
selected statutes and regulations; (2) SEC requirements; (3) common
law; (4) ethical obligations under professional codes of conduct,

and (5) EPA's obligationa to report
public. Lays out the factual background
environmental audit policy options.

compliance information to the
for EPA examination of

Prepared for the Regulatory
SW, Washington, DC 20460.

Reform Staff, Ftf-223, EPA, 401 M St.,


Title: "Corporate Environmental Compliance Progress"

Author: Bradley I. Raffle
Doc. Type: Conference paper

Abstract: Discusses legal issues presented by corporate vironaental quality
assurance (audit) programs. Concludes that t . benefits associated
with these progress outweigh any legal concerns. As environmental
compliance costs and liabilities escalate, auch programs should gain
even broader acceptance. Development would be advantageous to the
public and environaental enforcement agencies as well as to the
companies that implement the progn

Source: Mr. Raffle is Supervising Counsel with Conoco. Inc.. PO Box 2197,
Houston, TX 77079. Presented at the 78th Annual Meeting of the Air
Pollution Control Association, June 18, 1985.

Title: "Environaental Audits: Addressing Root Causes"

Author: Richard Mays
Doc. Type: Periodical article

Abstract: An EPA enforcenent attorney presents his personal views on the value
of negotiating environaental auditing provisions in certain
out-of-court settlements. By doing so, EPA would go beyond
addressing only the outward aanifestations of the problea (the
violation) and respond to what nay be the root cause of
noncoapliance: lack of adequate environaental policies and

Source: Cheaical Week. May 29, 1985, pp. 3-4.



"Can What You Know Hurt You as Much as What You Don't Know''"

Author: Phillip D. Reed
Doc. Type: Journal article

Abstract: Suggests that increases in industrial auditing programs indicate a
maturity of pollution control laws. Asserts that although industry
is accepting environmental compliance, there are concerns about
legal consequences and confidentiality of audit reports. Reviews
EPA policy governing access to audits and questions use of audits in
adninistrative enforcement actions.

Source: Environmental Law Reporter. Vol. 13, No. 10,
10303-8. Mr. Reed is with the Environmental
Connecticut Avenue NW, Washington. DC 20036.

October 1984, pp.
Law Institute, 1346

Title: "Issues of Confidentiality and Disclosure In Environmental Auditing"
Author: Malcolm C. Weiss
Doc. Type: Paper (April 1984)

Abstract: Presents and analyzes legal issues surrounding the confidentiality
of environmental audit generated information. Addresses the
confidentiality and disclosure issues by examining to what extent
audit information, if disclosed, could adversely affect its
producer; and legal principles and developing case law which may be
useful in securing legitimate confidentiality of audit information.

Source: Prepared by Mr. Weiss while a member of the Regulatory Reform Staff,
U.S. EPA. Available from the National Technical Information
Service, U.S. Dept. of Coonerce, Springfield, VA 22161; NTIS No.


Doc. Type


"Safeguarding Confidential Business Information"

Donald J. Henz
Conference paper

Suggests that certain information generated f.an environmental
auditing program will have to Bade confidential. Identifiea
auditing data that say be used against a coapany, including
inforaation on capacity, production rates, process flow, expected
life of facilities, and expenditures. Discusses methods to enhance
confidentiality of data in the context of two rules: (1) never
volunteer inforaation and (2) aaintain a confidential aentality.

PEDCO Environmental, Inc. 11499 Chester Road, Cincinnati, OH 45246.
Presented at the 76th Annual Meeting, Air Pollution Control
Asaociation, June 1983, Atlanta, GA.

Doc. Type


"Environmental Auditing and Inspections'
David A. Giannotti
Report chapters

Describes the elements of an environmental auditing program
including: coapany description, policy and organization,
categorization of facilities, internal procedures for reporting
environmental matters, and issues with unascertainable aspects.
Discusses the issue of disclosure, concentrating on attorney-client
privilege and the work product doctrine. Asaerta that
communications between an attorney and a client may be kept
confidential, depending on how "client" is defined.

Report prepared for inclusion in Organizing Corporate Compliance
Efforts (American Bar Asaociation, June 1983) and Environmental
Compliance in a . Changing Legal Environment (Practicing Law
Institute, New York; Sept. 1983.) Nr. Giannotti is with Occidental
Petroleum Corporation, 10889 Wilshire Blvd., Los Angeles, CA 90024.



Title: "Case Studies in Environmental Audits: A Practical Focus for Plant
Managers and Auditors"

Author: Stuart J. Spiegel and Cheryl L. Cundall
Doc. Type: Conference paper

Abstract: Argues that the objective of environaental audits is to evaluate
procedures and practices that could results in systematic
contamination, rather than to detect the potential for severe,
one-time catastrophic releases. Includes four case studies which
deaonstrate the variety of probleas that can be identified through
an audit.

Source: The authors are with O'Brien and Gere Engineers, Inc., P.O. Box
4873, Syracuse, NY 13221. Presented at the Annual Meeting of the
Aaerican Institute of Choaical Engineers, August 24-27, 1986,
Boston, MA.

Title: "Current Practices in Environaental Auditing"

Author: Arthur D. Little, Inc., Center for Environmental Assurance
Doc. Type: Report (February 1984)

Abstract: Discusses environaental auditing to further the understanding of how
various companies approach the subject. Describes five individual
environaental audit programs based on in-depth interviews with the
companies' audit program managers. The companies interviewed
represent a diversity of audit approaches and have aade significant
commitments to their auditing efforts. Includes program
documentation, e.g. checklists, protocols, and audit reports, to
illustrate the nature and scope of each program.

Source: Prepared for the Regulatory Reform Staff, U.S. EPA. Available from
the National Technical Information Service, U.S. Dept. of CoMerce,
Springfield, VA 22161. NTIS No. PB-240125-AS.



Doc. Type:

Environmental Auditing Case Studies'


Arthur D. Little, Inc., Center for Environmental Assurance, for the
Edison Electric Institute

Report (1984)

Siailsr to "Current Practices in Environmental Auditing", this
publication focuses on environmental auditing systems in the
electric utility industry. Descriptions of five electric utility
companies' audit programs sre presented in considerable detail.

Bdiaon Electric Inatitute, Environmental Auditing Task Force, 1111
Nineteenth Street NN, Washington, DC 20036.

Title: "The Most Common Sins Discovered During Environmental Audits"
Authors: David Brandwein and Gordon T. Brookman
Doc. Type: Conference paper

Abstract: Discusses the fourteen most cobmd deficiencies discovered during
audits conducted at more than 150 industrial operations in 30
states. Findings include inadequate waste containment, insufficient
inspection of storage areaa, lack of SPCC plan, and incomplete
analysis of wastewaters. Concludes that many problems can be solved
by better management practices and procedures rather than major
capital improvements.

Source: The authors are with Environmental Risk, Ltd., 120 Mountain Ave.,
Bloomfield, CT, 06002. Presented at the Annual Meeting of the
American Institute of Chemical Bngineers. August 24-27, 1986,
Boston, MA.


Title: "Another Approach to Environments! Auditing"

Author: R. Victor Young
Doc. Type: Conference paper

Abstract: Traces the development of ARCO's environmental audit program and
describes criteria for an effective audit, including management
coHitaent; review scope, staffing, schedule, procedures, and
reports; follow-up; and documentation. ARCO's unique approach
involves two levels of assurance: each division* is given
responsibility to conduct environmental audits, and there is an
oversight corporate audit of the operating company's review

Source: The author is with the Atlantic Richfield Company, 515 South Flower
Street, Los Angeles, CA, 90071. Presented at the Annual Meeting of
the American Institute of Chemical Engineers, August 24-27, 1986,
Boston, MA.

Title: "Corporate Experience in Environmental Auditing"

Author: Roberta Pollard-Cavalli
Doc. Type: Conference Paper

Abstract: Traces the development of Celanese Chemical Company's environmental
auditing program. Details the objectives and format of the auditing
process. Describes key factors influencing the effectiveness of an
audit program, particularly the independence and authority of the
auditor. Includes the Celanese audit policy and an environmental
review checklist.

Source: The author is with Celanese Chemicsl Company, PO Box 47320, Dallas,
TX 75247. Presented at the Environmental Law Implications of
Business Activities Conference, November 7-8, 1985, Southern
Methodist University School of Law.



Doc. Typo:


"Internal Environmental Audits - Assuring Compliance with the

Harold I. Goldsmith, Richard F. Pico, and John K. Williams
Conference paper

Case history of Kraft's efforts to insure that individual locations
coaply with basic environmental regulations. Areas reviewed in ซach
plant include: Wastewater discharges, spill prevention control and
counter-eeasure plana, water supply, air emissions, other wastes and
OS HA. Describes training and use of non-environmental

professionals. Includes auditor's checklist.

The authors are with Kraft, Inc., Kraft Court, Qlenview, IL 60025.
Presented at the 58th Annual Conference of the Water Pollution
Control Federation, October 6-10, 1985, Kansaa City, Hiaaouri.

Title: "Environmental Auditing - A Management Tool"

Author: Patrick Atkins and Robert F. Kohm
Doc. Type: Conference paper

Abstract: Discusses environmental auditing as implemented within the Aliainum
Company of America (Alcoa) and focuses on auditing aa a management
tool. Covers the auditing program from conceptualization to current
implementation. Concludes that auditing has proven to be an
effective tool for improving environmental management even while on
going changes.

Source: The authors are with Aluainum Compeny of America, 1501 Alcoa
Building, Pittaburgh, PA 15219. Presented et the annual meeting of
the Environmental Diviaion of the American Society of Civil
Engineers, July 3, 1985.



"General Motors Environaental Auditing Experience"

Author: Joseph P. Barzotti and Janes R. Keller
Doc. Type: Conference paper

Abstract: Traces the developaent of and explains the auditing operation within
General Motors Environaental Activities Staff. The audit prograa's
focus is on prevention of problems. Its goal is to assure that all
GM facilities achieve and aaintain compliance with current and
projected environaental laws, regulations and GM standards. Audit
teaaa help share solutions to conon probleas aaong GM facilities.
Self-identification of probleas has enhanced the Corporation's
reputation with governaent agencies at the local, state and federal

Source: The authors are with General Motors Corporation, General Motors
Technical Center, Warren, MI 48090. Presented at the 78th Annual
Meeting of the Air Pollution Control Association, June 18, 1985.

Title: "Environaental Auditing — TVA's Experience"

Author: Edwin B. Robertson, Jr., and Williaa M. Pearse
Doc. Type: Conference Paper

Abstract: TVA's auditing experience has been very satisfactory and auditing
has becoae an iaportant eleaent of facility environaental
management.	Facilities and operations are audited against

legislation, regulation, TVA policy, organization procedures,
specific peraits, NEPA docuaents and coanitaents to regulators. The
prograa serves as a tool for regular intra-agency comunication.
Describes TVA's auditing process and one operating organization's
reception to the prograa.

Source: Mr. Robertson is Environaental Scientist, Environaental Quality
Staff with the Tennessee Valley Authority, Muscle Shoals, AL 35660.
Presented at the annual aeeting of the Environaental Division of the
Aaerican Society of Civil Engineers, July 3, 1985.



Doc. Type:


"Union Carbide Corporation's Health, Safety
Protection Program"

Daniel C. Scheid

iod Environmental

Conference paper

Deec'ibee the objectives, organization, staffing, scope, d
reporting aspects of the corporate internal audit prograa developed
by Union Carbide with the assistance of Arthur D. Little, Inc.
Focuses oa the compliance audits, used to dsteraine compliance
status of operating locations with respect to governmental and
internal requirements. Outlines the audit methodology, Including
understanding and assessing management systMs; and gathering,
evaluating, and reporting audit findings.

The author is with Union Carbide Corporation, Old Ridgebury Road,
Danbury, CT 06817. Presented at the Annual Meeting of the Ameri
Institute of Chemical Bnginears, August 24-27, 1986, Boston, MA.

Doc. Type:


"Self-Auditing Prograa Monitors Compliance"

Robert Cutler
Periodical article

Robert Cutler of Olin Corporation discusses environments! auditing
based on his experience as msnsger of the Regulatory Compliance
Audit Department. He believes a successful audit program requires
(a) good people, (b) analysis of the regulatory requirements
applicable to a company's operations, and (c) that the auditing
office be kept independent of the activities being audited.

Hazardous Waste and Pollution Manage
February 10, 1983, pp 1-2.

snt Bulletin. Vol. 1, B303,


Title: "Profiles of Environmental Auditing Programs"

Author: Arthur D. Little, Inc.

Doc. Type: Report (1980)

Abstract: Surveys provided the information froa which profiles of 17
corporations' environaental auditing prograas comprising this report
are drawn. The profiles show a diversity and creativity of auditing
models. The implications of the profiles are discussed in a
companion piece, "A Survey of Environaental Auditing."

Source: Center for Environaental Assurance, Arthur D. Little, Inc., 15 Acorn
Park, Caabridge, Massachusetts, 02140.

Title: "Environaental Auditing - A Timely and Effective Tool"

Author: Stephen T. Maclntyre
Doc. Type: Journal article

Abstract: Defines environmental auditing; discusses auditing approaches
currently being utilized by soae Fortune 100 coapanies; reviews soae
of the potential benefits and liabilities associated with
environmental auditing; and suggests that the benefits to be derived
froa auditing are enough of an incentive that industry
representatives should work with regulators to enhance its

Source: Journal of the Air Pollution Control Association. Vol. 33, No. 9,
Sept. 1983, pp. 909-913. Mr. Maclntyre is with Rochester Gas and
Electric Corporation, 89 East Avenue, Rochester, NY 14649.


Title: "A Utility's Experience With An Environmental Quality Assessment

Author: Michael F. Basta
Doc. Type: Conference paper

Abstract: Details the background, scope and design of the Pennsylvania Power
and Light (PPM) auditing prograa to achieve environmental
compliance at its facilities. Explains the auditor's role as
providing management assistance to the line organization so they may
carry out the company's policies. Examines how two key business
documents supply guidance, the assessment process and follow-up
response. PP&L advocates auditing as a way that industry can take a
leadership role in helping to improve the environmental regulatory

Source: Pennsylvania Power and Light Company, Two North Ninth Street,
Allentown, Pennsylvania, 18101. Presented at the 76th Annual
Meeting of the Air Pollution Control Association, June 1983,
Atlanta, Georgia.

Title: "Environmental Auditing Policy: An Exploratory Analysis from the
Corporate Perspective"

Author: Martin A. Smith
Doc. Type: University paper (May 1983)

Abstract: Examines how corporations sight respond toward environmental
auditing as a tool to achieve management goals, both for corporate
activities related to the environment and for the company as a
whole. Establishes three general categories as policy alternatives:
(1) traditional non-auditing controls; (2) informal auditing; and
(3) formal auditing. These categories form the vertical component
of a matrix employing "criteria for choice" as the horizontal
component. Concludes that after costs and benefits are weighed,
corporate policy should include formal auditing as a management

Source: Institute for Environmental Studies, University of North Carolina
311 Pittsboro Street 256H, Chapel Hill, North Carolina 27514.


Title: "Environaental Auditing: The Keystone to a Management Compliance,
Control and Risk Assessaent Prograa"

Author: Robert W. Cutler
Doc. Type: Journal article

Abstract: Establishes a franework and analyzes characteristics of a viable
environmental auditing prograa. Focuses on top management's
coramtnปent as the key to a successful systea. Personnel training,
preparation, field work and reporting are also considered basic
aspects of a regulatory auditing prograa.

Source: Environnental Analyst. April 1982, pp. 12-16. Mr. Cutler is
Manager, Regulatory Audits, Olin Corporation, 120 Long Ridge Rd.,
Stanford, CT 06904.




Doc. Type:



Audits in Connection with Property Purchases and

Richard N. Cogen and Mary Elizabeth Ford
Conference paper

Discussee use of pre-purchase environmental audita to help companies
sake informed decisions about environmental risks posed by planned
acquisitions or divestitures. Suggests that audita can save
coapenies aoney by providing information relevant to decisions
beyond the basic decision to buy or sell. Concludes that
pre-purchaae audita are a beneficial resource that all coapani.es
should consider when purchasing or selling property.

The authors are with Nixon, Hargrave, Devans, and Doyle, PO Box
1051, Lincoln First Tower, Rochester, NY 14603. Presented at the
78th Annual Meeting of the Air Pollution Control Association, June
18, 1985.

Title: "Environmental, Health, and Safety Concerns in Acquisition Review"
Author: Jonathan Plaut
Doc. Type: Journal article

Abstract: Identifies three major concerns requiring consideration in any
acquisition activity: (1) substsntial hidden defecta or probleas
(e.g. buried haxardoue waste or emerging employee health probleaa),
(2) environmental, health, or aafety problem requiring significant
capital expenditure, (3) overlooked latent opportunities revealing
aignificant additional financial advantages to the buyer. Briefly
discusses how acquiaition teaas should include these considerations
in the audit of coapany being acquired.

Source: Toxic Substances Journal. Vol.2, No. 3, Winter 1980-81, pp. 243-250.


Title: "Evaluation of Environmental Accident Risk Assessments in New

Authors: John R. Renella, Harold Christiff, and Ramesh Kalagnanam
Doc. Type: Conference paper

Abstract: Reviews the N.J. Department of Environmental Protection's shift in
policy regarding accidental releases of air contaminants. Discusses
the "Environmental Accident Risk Assessments" conducted by two major
chemical companies at the request of the DEP. The EARAs included a
chemical screening analysis, detailed environmental accident
assessment, and a remedial action plan. Results indicated numerous
deficiencies at both facilities.

Source: New Jersey Department of Environmental Protection, 383 Nest State
St., Trenton, NJ 08618. Presented at the Annual Meeting of the
American Institute of Chemical Engineers, August 24-27, 1986,
Boston, MA.

Doc. Type:

"Ways to Avoid Liability when Purchasing Property"
Raymond W. Kane

Book chapter

Suggests that an environmental audit can be an effective mechanism
to identify potential liabilities during property transactions.
Describes six key steps in conducting an environmental audit:
review of Federal, state, and local regulatory requirements; review
of records and documentation related to environmental issues, for
information on compliance with regulations; interviews with key
staff; onsite physical inspection; risk evaluation; and reporting
the audit findings. Provides examples for each step, such as types
of regulations and ordinances to review, and suggests specific
areas, procedures, and equipment to inspect for audits of various
types of facilities.

Source: Impact of Environmental Law on Real Estate Transactions. Steven A.

Tasher (Bd.), Government Inatitutes Inc., 966 Hungerford Drive, #24,
Rockville, MD 20850. October 1986, pp 180-191


Title: "A Systos Approach to Contingency Planning for Incidents Involving
Hazardous Waste Materials"

Authors: Jacqueline Shields, Richard C. Allison, Gary D. Holtzclaw, and Kirk
C. Harlow.

Doc. Type: Conference paper

Abstract: Develops the use of a systems approach to developing contingency
plans for hazardous waste releases and events. Using environmental
audits, companies can identify areas with the greatest potential for
uncontrolled events and can prioritise contingency planning efforts.

Source: Dr. Shields is with the Environmental Management Program, School of
Business and Public Administration, University of Houaton-Clear
Lake, Box 317, 2700 Bay Area Blvd, Houston, TX 77098. Presented at
HAZFRO, April 1986, Baltimore, KD.

Title: "New Perspectives on Corporate Risk and Mays to Reduce It"

Author: Michael M. Gibson and Paul D. Fahrenthold
Doc. Type: Journal articles

Abstract: Part 1: Suggests that corporate environmental affairs will change
from being reactive to anticipatory in the relationahip between
corporate production and environmental activities. One need for
this anticipatory approach arises from "toxic tort" cases where
liabilities may exceed the net worth of the company.

Part II: Discusses attorneys' role in private-sector environmental
audits in the context of information gathering and confidentiality.
Explores competing dwands an attorney may be subject to as
corporate counsel involved with auditing. Suggests hซw attorneys
should conduct themselves relating to ethica, who their clients are,
how to exercise independent judgment, how to protect confidences and
secrets, and what may occur whan criminal conduct is found.

Source: The Environmental Forum. Vol.1, No.11, March 1983, pp. 35-41; Vol.
1, No. 12, April 1983, pp. 37-44.


Title: "Environmental Impairment Liability Insurance ar.s "isk Assessment"
Author: Paul MiIvy
Doc. Type: Journal article

Abstract: Briefly discusses the insurance industry's initial attempts to
insure against pollution episodes and focuses on environmental
impairment liability (EIL) insurance. EIL covers costs arising from
non-sudden events, a type of coverage which was not previously
available. Notes two main risks to be evaluated by underwriters in
offering an appropriate policy: (1) the risk to the environment and
public health and (2) the legal risks associated with a pollution

Source: The Environmental Forum. Vol.1, No.6, October 1982, pp. 30-37.

Title: "Environmental Risk Assessments and Environmental Audits"

Author: Richard S. Golob, Executive Editor
Doc. Type: Periodical article

Abstract: Presents an overview of insurance requirements and policy options
for firms mandated to carry insurance to meet RCRA regulations.
Includes sunaries of insurance policies covering non-sudden
pollution and profiles of environmental auditing and risk assessment

Source: Hazardous Materials Intelligence Report. August 20, 1982, pp. 1-8.



Doc. Type:


'Environmental Auditing Policy Stat

U.S. Environmental Protection Agency

Federal Register notice

EPA's final policy statement on environmental auditing encourages
the use of auditing by regulated entities. Specifically encourages
development and implementation of auditing pro grass in industry, and
of initistives of local governments. Discusses when the Agency may
request audit reports and explains how EPA's enforcement activities
may respond to industrial auditing efforts.

Federal Register Vol. 51,

No. 131, Wednesday, July 9, 1986, pp.

Title: "Federal Government Initiativee in Environmental Auditing"

Author: Leonard Fleckenstein
Doc. Type: Conference paper

Abstract: Review recent Federal activities to advance the practice of
environmental auditing, including audit policy development and
iapleaentation at EPA; audit program developments; availability of
audit protocols; audit-related regulatory and program
recommendations of the GAD; EPA guidance on audit provisions in
consent decrees; and a 1984 conference on environmental auditing for
Federal agencies.

Source: The author is with the Regulatory Innovations Staff, B4-223, U.S.

EPA, 401 M Street SW, Washington, DC 10460. Presented at the Annual
Meeting of the American Institute of Chemical Engineers, August 24-
27, 1986, Boston, MA.

Title: "A Review of Environmental Auditing Activities in Federal Agencies"

Author: Engineering-Science and Policy Planning L Evaluation Inc., for U.S.
Environaental Protection Agency

#oc. Type: Report (February 1987)

Abstract: Reviews the status of environmental auditing activities of Federal
agencies, and reports on energing trends. For each existing Federal
environaental auditing program, information is presented on:
program status (comprehensive, partial, under development); the
number of facilities audited; frequency with which the facilities
are audited; whether or not a formal protocol for auditing is used
during the audits; scope of the audits (which environmental
regulations or impacts the audit covers); and the source of auditing
personnel (internal agency staff, contractor staff, etc).

Source: U.S. EPA, Office of Federal Activities, Office of External Affairs,
401 M St. S.W., Washington, D.C. 20460

Title: An Introduction to Environmental Auditing

Author: Environmental law Institute for Michigan Department of Natural
Resources (DNR)

Doc. Type: Booklet (1985)

Abstract: Summarizes reasons for undertaking audits and DNR's interest in
auditing. Discusses alternative audit approaches, key elements of
effective programs, how audits can be performed, and relevant
recordkeeping and disclosure issues.

Source: Local Assistance Section, Coaaunity Assistance Division, Michigan
Department of Natural Resources, Box 30028, Lansing, MI 48909.



A Handbook of Environmental Auditing Practices and Perspectives in
North Carolina

Author: Martin A. Smith
Doc. Type: Report (1985)

Abstract: Provides a brief description and history of environmental auditing
and presents perspectives toward auditing of industry, the
environaental cosnunity, environaental lawyers and local governments
in North Carolina. Outlines four organizations' auditing systeas,
lists reference materials, and discusses important considerations in
undertaking an auditing program, especially its potential for
pollution prevention and hazardous waste minimization.

Source: North Carolina Department of Natural Resources and Comnity
Development, Pollution Prevention Pays Program, P.O. Box 27687,
Raleigh, N.C. 27611.


Doc. Type:


"EPA's Environmental Auditing
Enforcement Office View"

James R. Edward

Outlook: The Compliance and

Conference paper

Discusses the evolving role of EPA's Office of Enforcement and
Compliance Monitoring in environmental auditing, the critical need
for corporate facilities to meet their environmental
responsibilities, and the importance of self-monitoring and
reporting by companies. Also presents a brief history and status
update of EPA's recent activities involving Environmental Auditing,
and concludes with some perspectives on possible future directions
EPA's policy toward auditing may lead.

Office of Enforcement and Compliance Monitoring, EPA, 401 M Street
SW, Washington, DC 20460. Presented at the Environmental Auditing
Workshop for Electric Utilities, September 27, 1984, Duluth, MN.



Doc. -?e:


"Environaental Auditing: Opportunities

and Implications for State

A. D. Little, Inc., Center for Environnental Assurance
Meeting/Workshop Notes (July 1984)

Sunnarizes an A.D. Little-hosted discussion of environaental
auditing among interested states. Highlights the topics discussed
and key points raised during the aeeting, which focused on potential
public sector applications of and policies toward environaental

A.O. Little, Inc., Center for Environaental Assurance, 15 Acorn
Park, Cambridge, MA 02140.

Title: "Opportunities for Proaotion of Environaental Auditing Through
State-Level Initiative: Observations and Reconendations Drawn Froa
Other States"

Author: Richard N. Andrews and Martin A. Saith
Doc. Type: University paper (1983)

Abstract: Exaaines environaental auditing using inforaation gained through
reports, journal articles, an inforaal survey of all states, and
conversations with state and industry representatives. Suggests
alternate methods for promoting environaental auditing at the state
level through legislation, adainistrative actions, enforcement
programs, technical support and nuaerous private-sector efforts.
Identifies aethods for proaoting environaental auditing aaong state
industries and public-sector entities, and discusses what steps will
be taken to institutionalize the state's auditing initiative.

Source: Institute for Environaental Studies, University of North Carolina,
311 Pittsboro Street 256H, Chapel Hill, North Carolina 27514.




SEPTEMBER 29, 1992





Robotic Painting

C02 Depaint

Foam Removal


C02 Depaint

Foam Removal

Robotic Painting


Foam Removal

Robotic Painting

C02 Depaint












9:15 - 11:15




11:25 - 12:20




12:30 - 13:10

Robotic Painting

d)02 Depaint

Foam Removal

13:10 - 13:50

C02 Depaint

Foam Removal

Robotic Painting

13:50 - 14:30

Foam Removal

Robotic Painting

C02 Depaint



Current methods of stripping paint from aircraft use methylene
chloride strippers and produce large quantities of hazardous waste.
As of January, 1991, the F-15 Management Directorate started a test
program that may significantly reduce flow time, hazardous waste
disposal costs, and manpower. The new process blasts paint off
aircraft with pellets of carbon dioxide. The paint chips which
fall to the floor are swept up and disposed of. The blast media
evaporates into the atmosphere. The carbon dioxide used in this
new method is obtained as a by-product of other industrial

A future project will look into recovering the evaporated carbon
dioxide for reuse.


•	The new process produces a small amount of hazardous waste - the
paint chips themselves.

•	Eliminates toxic air emissions from solvents.

•	Eliminates wastewater and the generation of sludge resulting from
the treatment of that wastewater.






Paint particulates which contain toxic metals such as chromium
and lead suspended in the air of paint booths and hangars are
filtered before the air is exhausted to the environment. These
filters are changed every three weeks regardless of workload
through the facility. Differential pressure meters that measure
filter efficiency are being installed on all paint booths. These
meters indicate when the filters are clogged and require changing.
This simple measure ensures that the filters are used for their
entire useful life.


• Projected cost savings in filter installation cost, new filter
cost, and used filter disposal cost is 60%.

FUNDING: $2 00/booth




Prior to 1980, used chemicals such as paint thinners, freons,
isopropyl alcohol, methyl ethyl ketone (MEK), PD-680, acetone, and
1,1,1 trichloroethane were disposed off base. Since 1930, Robins
AFB has been reclaiming these chemicals for reuse in industrial
processes. This is done in two simple batch stills, each with a
capacity of 200 gallons per day. In 1990, 30,000 gallons of waste
solvents were reclaimed for a disposal and raw material cost
avoidance of $330K.


•	Reduces volume of chemicals disposed in the environment.

•	Eliminates the cost of hazardous waste disposal.

•	The product directorates which use the chemicals avoid the cost
of purchasing new chemicals.




As a result of Total Quality Management training, employees in
the Technology and Industrial Support Directorate's fabric shop
started a new program by which a local school for the handicapped
receives foam scraps for free. The foam is for use in fire
suppression in fuel cells of aircraft. Approximately 25,500 pounds
of foam scraps are generated per year during the process of cutting
the foam to conform to the fuel tanks. Until recently, the excess
foam was deposited in a local landfill. Now, the school bales and
sells it to carpet manufacturers for a profit.




•	Increases base service to handicapped people as well as
eliminates another source of waste being deposited in landfills.

•	Saves $12,000 per year in waste disposal costs.






Sponge-like foam is installed in Air Force aircraft for
explosion suppression, in the unlikely case that one should occur,
as well as to decrease buildup of static electricity in fuel tanks.
Until recently, deteriorated fcam and sealant were removed from the
wing tank by soaking in methyl ethyl ketone (MEK) and brushing
vigorously to loosen deteriorated sealant. Now, maintenance
workers use water under high pressure of up to 10,000 pounds per
square inch, using a device called a waterknife or waterpik, to
remove foam.


•	Replaces 400 gallons of MEK per year.

•	Eliminates worker exposure to hazardous materials.

•	Eliminates atmospheric contamination due to evaporation of
hazardous solvents.

FUNDING: $8700 per system





Foliation Prevention
Assessment Tools

What is a Pollution Prevention
Opportunity Assessment?

The environmental compliance assessment:

-	focus is on wastes after generation

-	determine regulatory compliance status

The pollution prevention opportunity

-	focus is on production and other waste sources

-	further reduction of wastes and emissions

Steps of q Pollution Prevention

Select assessment target

Select assessment team

Prepare for and conduct the on-site assessment

Identity potential waste reduction options

Examine technical and economic feasibility


Existing Tools to Assist in
Conducting an Opportunity

•	Pollution Prevention Information Clearinghouse
(PPIC) and other information sources

•	State Assistance Programs

• Waste Reduction Opportunity Assessment

Pollution Prevention Information

The PPIC provides users with:

-	A centralized repository of technical and policy
information concerning pollution prevention

-	An on-line computer system of summary
information for documents contained in the
repository including

-	A forum for asking questions of people who work
on pollution prevention programs

State Technical Assistance


Many States have active pollution prevention
technical assistance programs that provide
resident waste generators with:

-	Technical assistance in conducting pollution
prevention opportunity assessments

-	In some cases, pollution prevention assessments

-	Guidance for conducting assessments

-	Assistance in developing installation-wide
pollution prevention program plans

Slates Offering Technical
Assistance Programs

States providing such services include:






















New Hampshire

New Jersey

New Mexico

New York

North Carolina




Rhode Island

South Carolina

South Dakota





West Virginia



Waste Redaction Opportunity
Assessment Manual

•	Organization

•	Assessment

•	Feasibility

•	Implementation


Facility Pollution Prevention Guide

-	Draft in the Spring of 1992

-	Final by end of 1992

Federal Facility Pollution Prevention Program Guide
-Draft September 1992

-	Final September 1992

Program Plan Development

Program Plan Concept and Goal

Program Plan Concept

-	Develop a pollution prevention p.ogram for an
entire generating community.

Program Plan Goal

-	Institutionalize pollution prevention approaches in
the research community, both in practice and
mindset, across all sectors and activities.

Program Objective

Develop an integrated multimedia pollution
prevention plan that includes both short- and
long-term projects which will introduce all
researchers to the benefits of pollution
prevention. Once concepts are accepted,
researchers will routinely consider prevention
opportunities in all activities.

Pollution Prevention Program

Developing a waste generation baseline

Assessing environmental impacts for non-waste
generating operations

Developing priorities based upon site-specific
considerations (Decision matrix)

Establishing a schedule for conducting
opportunity assessments

Pollution Prevention Program
Development (continued)

•	Establishing criteria and techniques for
measuring progress

•	Developing an implementation plan

•	Establishing an implementation schedule

•	Implementation

•	On-going research

•	Project review

Pollution Prevention Strategy

Apply "Integrated Management" Principles

-	Eliminate or reduce pollutants at the source

-	Recycle pollution that cannot be eliminated

-	Treat pollution which cannot be recycled

-	Dispose of wastes only as a last resort

-	Conserve natural resources

-	Use clean, efficient energy sources

-	Pass on lessons learned

Program Approach

Focus pollution prevention efforts to address
multi-media environmental and conservation
issues including:

-	Municipal Waste

-	Manufacturing Waste

-	Materials and Energy Conservation

-	Land Management

Target activities based upon the initial waste
generation baselines and objectives

Program Approach (continued)

Identify pollution prevention opportunities for all
installations activities including:

Administration Offices	Procurement/Acquisition

Materials Distribution	Maintenance Operations

Housing/Food Services	New Constructions

Land Management Activities Manufacturing Processes
Vehicle Storage and Fueling Areas




V [7

17 17


Model Community Concept

The Model Community Concept is designed to:

•	Demonstrate an approach to identify pollution
prevention alternatives for any and all activities
that may result in adverse environmental

•	Provide a proving ground for prevention
concepts, techniques and strategies.

•	Study societal factors and incentives that may
17 impact the acceptance of pollution prevention

V concepts.


Model Community Concept

Assist a defined community in the development of
a prevention program.

Document successes and failures to assist other
communities in development of such programs.

Pollution Prevention Strategy

Apply "Integrated Management" Principles

•	Eliminate or reduce pollutants at the source

•	Recycle pollution that cannot be eliminated

•	Treat pollution which cannot be recycled

•	Dispose of wastes only as a last resort

•	Conserve natural resources

•	Use clean, efficient energy sources

•	Pass on lessons learned

TIPPP Concept

Develop a pollution prevention pilot
demonstration for well-defined generating
communities to better define a pollution
prevention program development approach.

y TIPPP Goal


•	Institutionalize pollution prevention approaches in
the Tidewater communities, both in practice and
mindset, across all sectors and activities.

•	Transfer results from this effort to other Federal


y^TIPPP Objective

• Develop an integrated multi-media pollution
prevention plan that includes both short- and
long-term projects which are easily transferable to
other community settings.



TIPPP Process

The TIPPP program will consist of the following
components performed by installation personnel
and supported by EPA and DoD:

•	Pollution Prevention Plans

•	Pollution Prevention Opportunity Assessments

•	Outreach and Training

•	Research and Development

•	Technical Transfer

Program Approach

Define a pollution prevention program targeting a
controlled community. Program components
should include:

•	Projects undertaken by individual bases

•	Cooperative projects by multiple bases

•	Cooperative projects between the bases and
r7 the surrounding communities


y Program Approach
/ (continued)

Include pollution prevention/energy conservation
projects of both short- and long-term duration.

Focus projects to address multi-media
environmental and conservation issues including:

•	Municipal Waste

•	Manufacturing Waste

7 • Materials and Energy Conservation
[7 • Land Management




Program Approach

Identify pollution prevention opportunities for all
installations activities including:

Administration Offices

Materials Distribution

Housing/Food Services

Land Management

Vehicle Storage and Fueling Areas

Maintenance Operations
Manufacturing Processes
New Constructions




Warner-Robins Air Force Base
September 28-30, 1992

Day 1

1. Please rate the panel of speakers using the following scale, 1 = Excellent 2 = Good
3 = Fair 4 = Poor

a.	Clarity and Organization of Presentations		

b.	Technical Quality of Presentations		

c.	Use of audiovisual materials		

d.	Overall rating of presentation		

Please provide any additional comments

2. Were presenters receptive to comments and questions? (circle one)

1.	Most were receptive

2.	Some were receptive

3.	Most of the presenters were not receptive to questions
Please explain

3. Do you feel the role-playing exercises were beneficial? (circle one)

1.	The exercises were very beneficial

2.	The exercises were somewhat beneficial (please explain)

3.	The exercises were not beneficial (please explain)

Please explain how you would improve the exercises.

Day 1 (Continued)

4. Do you feel the Pollution Prevention Assessment tools will be useful?

1.	The tools will be very useful

2.	The tools will be somewhat useful

3.	The tools will not be useful to me

Do you have any suggestions on how these tools can be improved?

Day 2

5. Do you feel the Demonstration Portion of the program was useful? (circle one)

1.	Yes

2.	No (Please explain)

6. Was the breakout discussion group useful? (circle one)

1.	Yes

2.	No (Please explain)

Day 3

7. Please rate the panel of speakers using the following scale, 1 = Excellent 2 = Good
3 = Fair 4 = Poor

a.	Clarity and Organization of Presentations		

b.	Technical Quality of Presentations		

c.	Use of audiovisual materials		

d.	Overall rating of presentation		

Please provide any additional comments

8. Do you feel this training program has been useful and what training format changes would you
recommend, if any?