United States Office of Enforcement and
Environmental Protection Compliance Assurance
Agency Washington, DC 20460
EPA300-B-94-012
November 1994
EPA Federal Facility Pollution
Prevention Planning Guide
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This document was prepared
by the Federal Facilities
Enforcement Office (2261 ) in
the Office of Enforcemeig
and Compliance Assurance':
Consulting assistance and
document design/layout ser-
vices were provided by
Science Applications Inter-
national Corporation (SAIC).
For additional copies of this
document, please contact:
Pollution Prevention
Information Clearinghouse
U.S. EPA (3404)
401 M Street, SW
Washington, DC 20460
Tel: (202) 260-1023
Fax: (202) 260-0178
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TABLE OF CONTENTS
PAGE.
SECTION I: INTRODUCTION
Background 1
Purpose of This Document 1
Pollution Prevention Defined 2
Executive Orders 3
Federal Laws 5
State Laws 5
Federal Agency Pollution Prevention Policies 6
SECTION II: FACILITY POLLUTION PREVENTION PLAN
DEVELOPMENT STEPS
Introduction 7
Developmentof a Facility Plan for Pollution Prevention 7
Step 1: Develop Goals 7
Step 2: Obtain Management Commitment 8
Step 3: Build abeam 8
Step 4: Develop a Baseline 10
StepS: Conduct Pollution PreventionActivities and
Opportunity Assessments 12
Step6: Develop Criteria and Rank Facility-Wide
Pollution Prevention Activities 13
Step7: Conduct aManagementReview 17
Public Participation 17
Measurements ofProgress 18
Implementation of the Plan 18
SECTION III: TECHNICALASSISTANCEAND LITERATURE
Pollution Prevention Planning Documents 21
Agency Guidance Documents 21
Technical Assistance Programs 22
Federal Facility Pollution Prevention Contacts 23
State Pollution Prevention Programs 24
ANNEX A: EXECUTIVE ORDER 12856
Recycled/Recyclable • PrintedwithVegetable Oil Based Inks on 100% Recycled Paper (50% Postconsumer) • PleaseRecydeas Newsprint
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SECTION I: INTRODUCTION
"... Federal facilities will set the example for the rest of the country and
become the leader in applying pollution prevention to daily operations,
purchasing decisions and policies... By stopping pollution at its source,
the Federal government can make a significant contribution to protecting
the public health and our environment. " President Clinton
FEDERAL FACILITY POLLUTION
PREVENTION PLANNING GUIDE
BACKGROUND
The Federal government is the Nation's
largest consumer of raw materials, power,
water, and products. The government
consumes these resources in its produc-
tion, maintenance, and operational activi-
ties. In many cases, these activities result
in the generation of harmful liquid, solid,
and gaseous wastes. Such wastes may
have adverse impacts on people and the
environment. In addition, the manage-
ment and disposal of these wastes (as well
as the cleanup of improperly managed
wastes) are costly.
The cost for material use, the manage-
ment of solid and hazardous wastes, the
control of discharges to the air and water,
and the cleanup of improperly managed
materials is rising. Rising costs in the
Federal community translates into costs to
every American. In addition, the require-
ments for the management of hazardous
materials and the release of chemicals to
the environment are becoming more com-
prehensive. The increasing costs and
expanding requirements create incentives
for Federal facilities to reduce the
amounts of hazardous materials used and
wastes generated.
Federal agencies can reduce their envi-
ronmental impacts and the costs associat-
ed with managing these impacts by incor-
porating pollution prevention into their
facilities activities. The Federal govern-
ment is in a unique position to demon-
strate leadership by protecting the envi-
ronment using pollution prevention.
Through its purchasing practices, for
example, the government can demonstrate
the use of less toxic and environmentally
protective products and materials. The
government can also create the demand
for goods and products with recycled con-
tent by establishing minimum recycled
content standards in its procurement con-
tracts. By embracing pollution preven-
tion as the preferred environmental man-
agement technique, the Federal govern-
ment can promote pollution prevention in
all its forms, including source reduction,
recycling, and affirmative procurement.
The Federal government can fundamen-
tally change the way in which the govern-
ment and, in the long-run, the Nation con-
duct business.
PURPOSE OF THIS
DOCUMENT
This document is designed to help
Federal facility environmental coordina-
tors comply with the pollution prevention
planning requirements of Section 3-
302(d) of Executive Order 12856 (see
Annex A), which states that "the head of
each Federal agency shall ensure that
each of its covered facilities develops a
written pollution prevention plan no later
than the end of 1995, which sets forth the
facility's contribution to the goal estab-
lished in set uon 3-302(a) of this order.
Federal agencies shall conduct assess-
ments of their facilities as necessary to
ensure development of such plans and of
the facilities' pollution prevention pro-
grams. " Specifically, the manual will
support facilities in developing written
pollution prevention plans that describe
how facilities will contribute to meeting
the Agency 50 percent reduction goals in
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the release of or the transport for disposal
of toxic chemicals as identified under
Section 3-302(a) of Executive Order
12856. This document also provides
guidance for Federal facility environmen-
tal coordinators to meet pollution preven-
tion requirements and goals established in
several other Executive Orders, Federal
laws, State laws, and Federal agency poli-
cies. More importantly, this manual is
intended to describe how you, the envi-
ronmental coordinator, can strengthen the
environmental program at your facility
using pollution prevention approaches.
This guide is intended to introduce you to
multimedia pollution prevention planning
techniques. It is intended to be a quick
reference guide that can assist in first
developing a pollution prevention facility
plan (as required under Executive Order
12856) and, second, initiating a compre-
hensive environmental management pro-
gram. This document is not a compre-
hensive technical guide to pollution pre-
vention facility planning. For additional
planning support, EPA encourages you to
refer to pollution prevention planning
guidance documents that your agency or
EPA has developed (see Section III).
The remainder of Section I provides an
overview of pollution prevention and
related Executive Orders, Federal laws,
State laws, and Federal agency policies
that require pollution prevention activi-
ties. Section H outlines steps for develop-
ing a facility-wide, multimedia pollution
prevention facility plan and building the
plan into a pollution prevention program.
Section III provides a list of pollution pre-
vention guidance documents, technical
assistance programs, and contacts that
might provide further assistance in devel-
oping and implementing your facility's
pollution prevention plan.
POLLUTION PREVENTION
DEFINED
Over the past several years, a new envi-
ronmental protection concept has evolved
that focuses on eliminating or modifying
activities that result in adverse environ-
mental impacts. This concept, known as
pollution prevention, has gained support
throughout the Nation, especially in
Federal agencies, as a means to meet or
exceed environmental goals and stan-
dards.
The Pollution Prevention Act of 1990 and
Executive Order 12856 define pollution
prevention as "... any practice which
reduces the amount of a hazardous sub-
stance, pollutant, or contaminant enter-
ing any waste stream or otherwise
released into the environment (including
fugitive emissions) prior to recycling,
treatment, or disposal; and any practice
which reduces the hazards to public
health and the environment associated
with the release of such substances, pollu-
tants, or contaminants.
Pollution prevention refers to the use of
materials, processes, or practices that
eliminates or reduces the quantity and
toxicity of wastes at the source of genera-
tion. It includes practices that eliminate
the discharge of hazardous or toxic chem-
icals to the environment and that protect
natural resources through conservation
and improved efficiency. Pollution pre-
vention also reduces the use of hazardous
materials, energy, and water.
Pollution prevention is a novel approach
to waste management not only because it
seeks to avoid the generation of waste or
environmental releases, but also because
it stresses the management of all environ-
mental media (i.e., air, land, and water)
together. Within this framework, pollu-
tion prevention aims to eliminate or
reduce waste released to land, air, and
water without simply transferring or dis-
tributing pollutants among these media.
Pollution prevention represents the first
step in a hierarchy of options for manag-
ing waste. This environmental protection
hierarchy lists, in descending order of
preference, source reduction, recycling,
treatment, and disposal as the recom-
mended options for waste management.
Source Reduction
Activities
Process Efficiency Improvements
Perform the same task with
less energy or materials by
designing new systems or
modifying existing ones.
Material Substitution
Replace hazardous chemicals
with less toxic alternatives.
Inventory Control
Prevent product expiration
and damage by improving
inventory management.
Preventive Maintenance Routinely
check for and repair leaks and spills
and maintain equipment in good
working order to extend useful life.
Improved Housekeeping
Keep the facility neat and
organized to reduce chances of
spills and releases of chemicals.
Source Reduction
Environmental Protection
Hierarchy
Section /: Introduction
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Source reduction is assigned the highest
priority because it eliminates or reduces
wastes at the source of generation.
Recycling is the next preferable approach
because it involves the reuse or regenera-
tion of materials and wastes into usable
products. Treatment and disposal are
considered last-resort measures.
Key benefits of pollution prevention may
include reductions in reporting require-
ments, compliance costs, and environ-
mental liability. Pollution prevention
may also reduce expenditures for raw
materials, waste disposal, transportation,
handling and storage, training, manage-
ment overhead, and emergency response.
This approach will result in a cleaner
environment, more efficient operations,
and safer working environments.
EXECUTIVE ORDERS
To promote pollution prevention as the
preferred environmental management
technique throughout the Federal govern-
ment, the President has issued numerous
Executive Orders. These orders instruct
Federal agencies to integrate waste reduc-
tion and recycling programs into their
environmental management initiatives.
To do this, the President has identified
specific source reduction and recycling
goals that all Federal agencies and facili-
ties should meet. By requesting Federal
agencies to respond to the goals of the
Executive Orders, the Federal govern-
ment demonstrates its commitment to the
environment and ultimately to each citi-
zen of the United States.
These Executive Orders (discussed on the
following page) translate into various
requirements that you should consider
when developing and implementing your
facility pollution prevention plan. The
general requirements for these Executive
Orders are summarized in the box. You
should check with your headquarters to
obtain information concerning goals,
requirements, assistance programs, and
research efforts specific to your agency.
Facility Requirements Under Pollution Prevention
Executive Orders
Executive Order 12856—Federal
Compliance with Right-to-Know Laws
and Pollution Prevention
Requirements (August 3, 1993)
• Develop a facility-wide pollution pre-
vention plan by December 31,1995,
to reduce releases and transport of
toxic chemicals by 50 percent.
• Ensure that the plan supports
agency-wide reduction strategies
and goals.
• Establish agency plans and goals to
eliminate or reduce unnecessary
acquisition of products containing
hazardous substances or toxic
chemicals.
• Make strategies, plans, and Toxic
Release Inventory (TRI) reports
available to the communities sur-
rounding your facility.
• Comply with EPCRA emergency
planning and response require-
ments.
• Report releases and transfers of
toxic chemicals to the TRI.
Executive Order 12873—Federal
Acquisition, Recycling, and Waste
Prevention (October 20, 1993)
• Establish goals for solid waste pre-
vention and recycling to be achieved
by 1995.
• Procure products that are environ-
mentally preferable or that are made
with recovered materials, and set
annual goals to maximize the num-
ber of recycled products purchased.
Executive Order 12902—Energy
Efficiency and Water Conservation
(March 8, 1994)
• Reduce the overall energy use in
Federal buildings by 30 percent by
2005.
• Increase overall energy efficiency in
industrial facilities by 20 percent by
2005.
• Significantly increase the use of
solar and other renewable energy
sources.
• Minimize the use of petroleum
products at Federal facilities by
switching to less polluting alterna-
tive energy sources.
Executive Order 12843—Procurement
Requirements and Policies for
Federal Agencies for Ozone-Depleting
Substances (April 21, 1993)
.Maximize use of alternatives to
ozone-depleting substances.
.Modify procurement specifications
and practices to substitute non-
ozone-depleting substances,
Executive Order 12844—Federal Use
of Alternative Fueled Vehicles
(April 21, 1993)
• Procure and use alternative fueled
vehicles, where possible, to reduce
toxic and hazardous air pollutants.
• Purchase 50 percent more alterna-
tive fueled vehicles from 1993
through 1995 than currently speci-
fied in the Energy Policy Act of
1992. While your facility may not
be scheduled to purchase such
vehicles, you should investigate and
purchase such vehicles if possible.
Executive Order 12845—Purchasing
Energy Efficient Computer Equipment
(April 21, 1993)
• Meet EPA "Energy Star" energy effi-
ciency requirements in the purchase
of computer equipment.
• Equip existing computer equipment
with energy efficient low-power
stand-by feature.
• Educate staff about the environmen-
tal and economic benefits of energy
efficiency.
Executive Order 12898—Federal
Actions to Address Environmental
Justice
.Encourages Federal facilities to doc-
ument potential environmental im-
pacts in environmental justice areas
and target such impacts for reduc-
tion through pollution prevention.
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Executive Order 12856-Federal
Compliance with Right-to-Know
Laws and Pollution Prevention
Requirements
One of the most important milestones in
Federal pollution prevention activities
was the signing of Executive Order 12856
(Federal Compliance with Right-to-Know
Laws and Pollution Prevention Require-
ments) in August 1993. This order is
expected to serve as a central directive to
Federal agencies and facilities on pollu-
tion prevention during the coming years.
Executive Order 12856 calls on Federal
agencies to develop a 50 percent reduc-
tion goal by 1995 for their releases of
toxic chemicals, or pollutants, with the
baseline being no later than 1994.
To accomplish this, Executive Order
12856 requires Federal facilities subject
to the order to develop facility-specific
pollution prevention program plans.
These plans should set goals, identify
activities, and establish a timeline to
reduce and eliminate the acquisition,
manufacture, processing, or use of toxic
chemicals and extremely hazardous sub-
stances at the facility. The plans should
consider all activities and processes that
rely on toxic and extremely hazardous
materials. In addition, the plans should
include any other activities that may
adversely impact the environment. The
plans should consider all environmental
media (i.e., land, air, and water) and iden-
tify specific activities that will result in
reductions of impacts to these media.
Executive Order 12873-Acquisition,
Recycling, and Waste Prevention
Executive Order 12873 directs Federal
agencies and facilities to implement
acquisition programs aimed at encourag-
ing new technologies and building mar-
kets for environmentally preferable and
recycled products. Toward this end, all
agencies are directed to review and revise
their specifications, product descriptions,
and standards to enable procurement and
acquisition personnel to meet the goals set
forth in the Executive Order. Agencies
also must set goals for waste prevention
and the acquisition of recycled products
and report on their progress in meeting
the goals.
Executive Order 12902-Energy
Efficiency and Water Conservation
Under Executive Order 12902, Federal
agencies and facilities are directed to
increase efforts to conserve energy and
water by improving efficiency. Each
agency must undertake a prioritization
survey of all its facilities leading to a 10-
year plan to conduct comprehensive ener-
gy and water audits. In response to this
plan, each Federal facility will be expect-
ed to contribute to its agency-wide con-
servation and reduction goals.
Executive Orders 12S43, 12844,
12845—Ozone-Depleters, Alternative
Fueled Vehicles, Energy Star
Computers
Three other executive orders, signed on
Earth Day 1993, commit the Federal gov-
ernment to accelerated action on several
fronts—phasing out ozone-depleting sub-
stances, purchasing alternative fueled
vehicles, and buying energy-efficient
computers.
Executive Order 12843—Procurement
Requirements and Policies for Federal
Agencies for Ozone-Depleting Substances
Executive Order 12843 directs Federal
agencies to change their procurement
policies to reduce the use of ozone-
depleting substances earlier than the 1995
phase-out deadline called for in the
Montreal Protocol. Federal agencies are
directed to modify specifications and con-
tracts that require the use of ozone-deplet-
ing substances and to substitute non-
ozone-depleting substances to the extent
economically practicable. Through affir-
mative acquisition practices, the Federal
government will provide leadership in the
phase-out of these substances on a world-
wide basis, while contributing positively
to the economic competitiveness on the
world market of U. S. manufacturers of
innovative safe alternatives.
Executive Order 12844 —Federal Use of
Alternative Fueled Vehicles
Executive Order 12844 places the
Federal government in a leadership role
in the use of alternative fueled vehicles,
calling on each agency to adopt aggres-
sive plans to exceed the purchase .
requirements of such vehicles estab-
lished by the Energy Policy Act of
1992. The use of alternative fueled
motor vehicles can reduce air pollution,
stimulate domestic economic activity,
reduce vehicle maintenance costs, and
provide market incentives for the devel-
opment of such vehicles and the fueling
infrastructure needed to support large
numbers of privately owned alternative
fueled vehicles.
Executive Order 12845—Purchasing Energy
Efficient Computer Equipment
The U.S. government became a participant
in the Energy Star Computer program by
agreeing to buy energy-efficient computers,
monitors, and printers to the maximum
extent possible. To the extent possible,
Federal agencies must now purchase only
those computer products that qualify for the
Energy Star logo, as long as they meet other
performance requirements and are available
in a competitive bid.
Executive Order 12898—Federal
Actions to Address Environmental
Justice in Minority Populations and
Low-Income Populations
Section 3-302(c) of Executive Order 12898
requires that "each Federal agency, when-
ever practicable and appropriate, shall col-
lect, maintain and analyze information on
the race, national origin, income level and
other readily accessible and appropriate
information concerning areas surrounding
Federal facilities that are (1) subject to the
reporting requirements under the
Emergency Planning and Community
Right-to-Know Act, 42 U.S.C. section
11001-11050 as mandated in Executive
Order 12856: and (2) expected to have a
substantial environmental, human health, or
economic effect on surrounding popula-
Section 1: Introduction
-------
tions. Such information shall be made
available to the public, unless prohibited
by law." Facilities are encouraged to con-
sider these requirements in developing
facility baselines and pollution prevention
plans. Facilities also are encouraged to
develop and implement pollution preven-
tion alternatives that will reduce the envi-
ronmental impacts to environmental j us-
tice areas where socioeconomic factors
are of concern.
FEDERAL LAWS
For several years, Congress has promoted
pollution prevention by legislating
Federal laws that either directly or indi-
rectly require the implementation of pol-
lution prevention. For example, the
Pollution Prevention Act of 1990 estab-
lished pollution prevention as the pre-
ferred environmental management
approach for all waste generators, includ-
ing Federal facilities. The Federal
Facilities Compliance Act of 1992 indi-
rectly encourages pollution prevention by
waiving sovereign immunity for Federal
facilities concerning hazardous waste
compliance requirements.
The Pollution Prevention Act and the
Federal Facilities Compliance Act strong-
ly demonstrate the Federal government's
desire to protect the environment through
pollution prevention approaches. Each of
these acts is discussed in greater detail in
the following paragraphs.
Pollution Prevention Act of 1990
The Pollution Prevention Act of 1990
clearly establishes pollution prevention as
the Nation's preferred approach to envi-
ronmental protection and waste manage-
ment. Although the Act does not mandate
specific pollution prevention activities, it
does establish pollution prevention as the
national environmental protection policy.
The Act states, "The Congress hereby
declares it to be the national policy of the
United States that pollution should be
prevented or reduced at the source when-
ever feasible; pollution that cannot be
prevented should be recycled in
ronmentallv safe manner whenever feasi -
hie; pollution that cannot be prevented or
recvcled should be treated in an environ-
mentally safe manner whenever feasible;
and disposal or other release into the
environment should be employed only as
a last resort and should be conducted in
an environmentally safe manner. "
Federal Facilities Compliance Act
of 1992
The Federal Facilities Compliance Act
requires all Federal facilities to comply
with all applicable hazardous waste laws
and corresponding Federal, State, and
local regulations. The Act makes Federal
facilities fully responsible for violations
of the Resource Conservation and
Recovery Act (RCRA) resulting from
their management of hazardous wastes.
By making Federal facilities responsible
for RCRA compliance violations, the Act
provides Federal facilities with incentives
to minimize hazardous wastes regulated
under RCRA.
Other Federal Laws
Other Federal environmental laws pro-
mote pollution prevention by creating
requirements that must be met by all
waste generators. Waste generators can
reduce the burden of these regulations by
implementing pollution prevention alter-
natives. Such environmental laws include
the Clean Air Act, Clean Water Act,
RCRA, Comprehensive Environmental
Response, Compensation, and Liability
Act (CERCLA), and Emergency Planning
and Community Right-to-Know Act
(EPCRA).
STATE LAWS
States have promoted pollution preven-
tion as a means to improve environmental
management approaches since the early
1980s. In general, State pollution preven-
tion programs maintain technical assis-
tance functions that disseminate pollution
prevention information to support indus-
trial facilities in their efforts to reduce
wastes and eliminate environmental
Pollution Prevention
Incentives in Federal
Legislation
Clean Air Act
The 1990 Amendments added pol-
lution prevention as a primary goal
of the Clean Air Act.
Clean Water Act
The overall goal of the Clean Water
Act is to reduce and eventually
eliminate the discharge of pollu-
tants into U.S. waterways.
Resource Conservation
and Recovery Act
The Hazardous and Solid Waste
Amendments (HSWA) of RCRA
established as national policy the
reduction or elimination of haz-
ardous waste generation wherever
possible.
Comprehensive Environmental
Response, Compensation, and
Liability Act
CERCLA indirectly promotes pollu-
tion prevention through its perva-
sive liabilityscheme. Any misman-
agement of hazardous materials
can result in liability and can lead to
enforcement action.
Emergency Planning
and Community
Right-to-Know Act
Waste minimization is an explicit
goal of EPCRA; however, it does
not directly mandate pollution pre-
vention. Instead, EPCRA promotes
pollution prevention through the
reporting and public right-to-know
requirements.
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impacts. These technical assistance pro-
grams may also support your Federal
facility.
In addition, many States have modified
their regulatory programs, including per-
mitting, compliance inspections, and
enforcement actions, to incorporate and
promote pollution prevention approaches
as a means to meet environmental quality
goals. Moreover, several States have
enacted legislation or regulations promot-
ing or mandating pollution prevention
facility planning. As such, it is critical
that each Federal facility meet not only
the pollution prevention requirements as
directed under Section 5-505 of Executive
Order 12856 but also the pollution pre-
vention requirements of the State environ-
mental program. In cases where the State
and Federal requirements overlap, the
facility should meet the more stringent of
the two requirements.
The following table lists the States that
have facility planning or other prevention
requirements. Since new projects are
emerging with increasing frequency, it is
critical to periodically check with your
State regulators on developing require-
ments and programs. A list of contacts for
State pollution prevention programs is
provided in Section III.
FEDERAL AGENCY
POLLUTION PREVENTION
POLICIES
Pollution prevention program planning
will be the key to successfully addressing
the requirements and goals established in
the Executive Orders and Federal and
State regulations. To reinforce these goals,
Executive Order 12856 requires each
Federal agency to develop a pollution pre-
vention strategy. EPA prepared the docu-
ment entitled, Pollution Prevention in the
Federal Government: Guide for Develop-
ing Pollu lion Prevention Strategies for
Executive Order 12856 and Beyond, to
assist Federal agencies in developing pol-
lution prevention strategies in accordance
with Section 3-301 of the Executive
Order. Information on obtaining this doc-
ument is given in Section HI. Each
agency's strategy will describe how it will
meet the 50 percent toxic release reduc-
tion goal by December 31, 1999, as out-
lined in Section 3-302 of Executive Order
12856. Your facility-specific prevention
plan, as required under the Executive
Order, will support your agency in meet-
ing its source reduction goals as described
in its pollution prevention strategy.
In response to all of these requirements
and directives, several Federal agencies have
demonstrated their commitment to pollution
prevention by developing pollution preven-
tion policies. These policies direct facilities
to develop facility pollution prevention
plans. As a Federal facility environmental
coordinator, it is your responsibility to ensure
that these policies are implemented. For fuj-
ther information on your agency's pollution
prevention policy, contact your Federal facil-
ity pollution prevention contact. A list of
contacts is provided in Section III.
Summary of State Pollution Prevention Legislation
State
Alaska
Arizona
California
Colorado
Connecticut
Delaware
Florida
Georgia
Illinois
Indiana
Iowa
Kentucky
Louisiana
Maine
Massachusetts
Michigan
Minnesota
Legislation
Facility
Planning
Prevention
X
X
X
X
X
X
X
X
X
X
X
X
X
Other
Pollution
(Requirements
X
X
X
X
X
X
X
X
X
X
X
X
State
Mississippi
Missouri
New Jersey
New York
North Carolina
Ohio
Oregon
Pennsylvania
Rhode island
South Carolina
Tennessee
Texas
Vermont
Virginia
Washington
Wisconsin
Legislation
Facility
Planning
Prevention
X
X
X
X
X
X
X
X
Other
Pollution
Requirements
X
X
X
X
X
X
X
X
X X
X
Section 1: Introduction
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SECTION II: FACILITY POLLUTION
PREVENTION PLAN DEVELOPMENT STEPS
INTRODUCTION
This discussion translates all of the
requirements (summarized in Section I)
into specific activities that will help you
define, develop, and implement a pollu-
tion prevention program at your Federal
facility. Specifically, this section de-
scribes the components of a pollution
prevention facility plan. It provides a
stepwise process for the development
and implementation of a facility-wide,
multimedia pollution prevention plan
that will help you and your facility meet
all of the pollution prevention require-
ments and goals.
Once the plan is completed, you will
have a strategy and a list of action items
for integrating pollution prevention into
your facility's environmental protection
program. A facility pollution prevention
plan can be prepared in many different
ways. The exact approach you take will
depend upon the types of organizational
structures, management styles, and mis-
sions within your facility. The remainder
of this section defines EPA-recommend-
ed steps for developing your facility-
wide pollution prevention plan and dis-
cusses public participation, measurements
of progress, and plan implementation.
DEVELOPMENT OF A
FACILITY PLAN FOR
POLLUTION PREVENTION
tent of the plan and the environmental
issues targeted will depend upon your
goals and facility's requirements from
your headquarters, EPA region, and State
environmental regulators. The greatest
challenge to you will come in applying
the pollution prevention planning ap-
proach to develop a plan that meets the
needs of your facility and its specific
environmental concerns.
This sub-section discusses the seven
steps commonly used to develop a facili-
ty pollution prevention plan.
Step 1: Develop Goals
The first step in preparing a facility pol-
lution prevention plan is to develop
goals. These goals will identify specific
reductions and accomplishments that you
envision for the facility's pollution pre-
vention program. Section 3-302(a) of
Executive Order 12856 requires each
Federal agency to develop "voluntary
goals to reduce the agencv's total releas-
es of toxic chemicals for treatment and
disposal from facilities covered by this
order by 50percent by December 31,
1999. " Specifically, your facility pollu-
Step 7:
Step 8:
Step 5:
FEDERAL FACILITY POLLUTION
PREVENTION PLANNING GUIDE
Before you initiate a facility-
wide, multimedia pollution
prevention program, you P
should define specific
goals, actions to accom-
plish those goals, and
a schedule for these
actions. In short,
you should have
a plan. The
exact con-
Step 1:
Conduct a Management Review
Develop Criteria and (tank
Activities/Opportunities
Conduct P2 Opportunity Assessments
Develop a Baseline
Pollution Prevention
Obtain Management Commitment
Steps
Step 2
Develop Pollution Prevention Goals
Steps for
Developing a
Facility
Pollution
Prevention Plan
-------
tion prevention plan should define how
your facility will contribute to your
agency's overall pollution prevention
reduction goals (see Section 3-302(d) of
Executive Order 12856). Some recom-
mended goals might include the following:
• Reductions in the release and use of
toxic and extremely hazardous chemi-
cals at your facility (see Executive
Order 12856)
• Reductions in the release and use of
other pollutants as identified by your
agency's pollution prevention strategy
• Reductions in the unnecessary pur-
chase of toxic and hazardous chemi-
cals (see Executive Order 12873)
• Affirmative procurement practices to
ensure the purchase of recycled con-
tent materials as directed by EPA (see
Executive Order 12873)
• Increases in the volumes of materials
captured for recycle
• Reductions in the generation of solid
wastes
• Reductions in the consumption of
materials, water, and power (see
Executive Order 12902)
• Reductions in the use and release of
toxic chemicals to environmental jus-
tice areas where socioeconomic fac-
tors are of concern (see Executive
Order 12898).
EPA is currently developing guidance on
specific pollution prevention approaches
that can be used by agencies and facili-
ties in meeting their 50 percent reduction
goals.
By setting goals, you will define the na-
ture of the pollution prevention program
and direct its initial efforts toward a quan-
tifiable objective. As you develop the
facility pollution prevention plan, you
may identify new goals or modify original
goals. Be sure to document and publicize
any major changes to the program goals.
Step 2: Obtain Management
Commitment
The next step is obtaining a commitment
from upper management. When man-
agement is committed to pollution pre-
vention, the development (and imple-
mentation) of the program plan proceeds
more smoothly. As with any new pro-
ject, obtaining management support for
pollution prevention involves providing
managers with the information they need
to make decisions. Managers should
understand the goals of pollution preven-
tion, the reasons for developing a pollu-
tion prevention plan (e.g., the Executive
Orders), and the elements of a pollution
prevention program. Most important,
the facility managers should understand
all of the potential benefits that they will
reap in developing and implementing a
pollution prevention program.
To obtain upper management commit-
ment, you have to sell the concept. To
do that, you have to convince managers
that a pollution prevention facility plan
will help the facility mission by:
• Improving compliance with all
applicable environmental require-
ments, regulations, and Executive
Orders
• Reducing operating costs with re-
spect to waste management and the
purchase of raw materials
• Reducing the facility's chances of
creating environmental contamina-
tion that may result in environmental
liabilities and large-scale cleanup
requirements
• Improving the productivity of staff by
providing a cleaner, healthier work-
ing environment through reduced use
of toxic materials
. Increasing efficiency through innova-
tive pollution prevention techniques
identified and implemented under the
pollution prevention program.
Once upper management agrees to
developing a facility plan, the facility
director should sign a formal policy
statement that expresses approval for the
plan. In addition to the policy statement,
upper management must provide the
authority for the environmental staff to
develop and implement the pollution
prevention plan.
Step 3: Build a Team
A pollution prevention program cannot
succeed without the support of all facility
staff. Therefore, the facility pollution
prevention plan should be developed by
facility staff who are led through the
process by the environmental personnel
responsible for the plan. EPA suggests a "
team approach in which various staff
support the planning and implementation
steps. Realize that various facility staff
should participate in the planning process
because they will ultimately be responsi-
ble for implementing pollution preven-
tion options.
The same staff will not necessarily sup-
port the planning process throughout the
effort. You will need assistance from
staff who understand and operate differ-
ent processes or missions at the facility.
You will draw on different facility per-
sonnel when characterizing their opera-
tions and defining pollution prevention
Obtaining the Right Kind
of Commitment
When briefing management on
the pollution prevention planning
process, be sure you obtain the
following:
.Authority to develop, implement,
and facilitate a facility-wide pollu-
tion prevention program.
• A policy statement that confirms
this authority and emphasizes
management's support for this
effort.
• Resources to initiate the program.
Be careful not to scare away man-
agement with expensive or man-
power intensive programs. Once
you have demonstrated the cost-
effectiveness of pollution preven-
tion, funding for projects will be
easier to obtain.
8
Section II: Facility Pollution Prevention Plan Development Steps
-------
A Successful
Model
Under the Tidewater Interagency
Pollution Prevention Program
(TIPPP) plan, Ft. Eustis Army
Transportation Center, Langley Air
Force Base, NASA Langley
Research Center, and Naval Base
Norfolk in the Tidewater, Virginia,
area have joined together to
address pollution prevention
issues at the community level. The
four facilities worked with EPA and
the Commonwealth of Virginia to
develop a four-facility plan for
cooperative pollution prevention
projects and information sharing.
The plan described base-specific
and TlPPP-wide goals, as well as
efforts and approaches for meeting
pollution prevention targets identi-
fied under the 1990 Chesapeake
Bay Agreement. In addition, each
facility has developed its own pol-
lution prevention plan that is inte-
grated with the TIPPP plan and
focuses on facility-specific issues.
The TIPPP provides a model for
planning across a variety of facili-
ties and issues. In the long-term,
the planning conducted for the
TIPPP allowed the program to
achieve desired goals and to
demonstrate the utility of commu-
nication among facilities within a
geographic region.
Issue the Policy
\.
Create
Incentives
Enlist
Mid-Management
support
Establish an
Oversight Group
Choose Staff for
Baselining and
I Opportunity
Assessment
Activities
Building a Team
options that apply to them. You should
also enlist staff who support the entire
facility, including maintenance engineers,
supply staff, and health/safety personnel.
These staff will be invaluable in defining
facility-wide characteristics and pollution
prevention opportunities.
To ensure that the right staff are available
when needed, EPA suggests a team build-
ing approach that relies on education and
flexibility so that facility staff can partici-
pate when needed. The following types
of activities may support you in building
a personnel pool that you can rely on
throughout the development and imple-
mentation stages.
Issue the Policy Statement
All staff should have access to the pollu-
tion prevention policy. At first, this doc-
ument will serve as the license for the
pollution prevention planning and imple-
mentation process. Everyone should
know that it exists and what is says.
Enlist Middle Management Support
To ensure program success, it is critical
that middle managers understand and
support the initiative. You will have to
convince them that the pollution preven-
tion program will help make their lives
simpler with respect to the environment.
You will be relying on their good will
and access to information so it is critical
to enlist their support. Provide them with
the policy statement, a description of pol-
lution prevention, the benefits of pollu-
tion prevention, and how they can sup-
port the effort.
Establish an Oversight Group
The oversight group is a team of individ-
uals who will help to develop and imple-
ment the program. This team will be
responsible for:
• Developing the facility pollution pre-
vention program plan
• Encouraging staff participation in the
planning and implementation of the
program
• Monitoring the program as it develops
• Acting as advocates for the pollution
prevention program
• Publicizing the program.
Team members should be chosen from
all areas of the facility and should in-
clude both supervisors and shop-level
employees. Although the team may con-
sist of several members, the environmen-
-------
Pollution Prevention Team
Members
• Environmental coordinator
• Facility director
• Senior management
• Public affairs department
• Shop personnel
Developing A Team
Approach
The U.S. Coast Guard at Governor's
Island has several tenant facilities
that were managing environmental
issues independently. Each tenant
command, therefore, was manag-
ing its own wastes. In developing
pollution prevention alternatives,
the different tenant organizations
worked together to develop and
exchange innovative pollution pre-
vention options and approaches.
This team approach resulted in
information sharing and coopera-
tion not only on pollution preven-
tion approaches but also on future
waste management practices.
tal coordinator may be responsible for
leading the oversight group.
Select Stafffor Baselining and
Opportunity Assessment Activities
As you begin to develop a baseline and
conduct opportunity assessments, you
should identify and enlist the help of
staff who work in areas where wastes are
generated. These staff will support you
in defining the operations for the facility
baseline and in developing pollution pre-
vention alternatives. In using this
approach, your baselining and opportuni-
ty assessment team will change as you
move through the facility. Each opera-
tion will have staff who are familiar with
your activities and may be willing to
help once implementation occurs.
Publicize tile Program
You must have cooperation from facility
staff. If they will not participate, you
may never accomplish anything other
than the initial planning effort.
Publicizing the program can be difficult
depending on the size of the facility and
staff attitudes concerning the environ-
ment. To publicize the program, the
oversight group can hold public forums
to discuss the program. You might also
distribute brochures or factsheets to all
staff through the mail or electronic bul-
letins. Starting a new environmental or
pollution prevention newsletter might
help as well. Again, the goal of the pub-
licity program is to clearly demonstrate
management commitment to the pollu-
tion prevention program.
Create Employee incentives
Nothing will encourage facility staff to
participate like financial or recognition
incentives. Employee incentives for par-
ticipating in the pollution prevention pro-
gram definitely capture people's atten-
tion. Many facilities offer bonuses or
other awards to employees who suggest
viable ways to prevent pollution.
Announcing the incentives program in
conjunction with the publicity effort will
spark interest and participation. If your
agency has a suggestion program or other
financial compensation programs, you
might use these to reward good ideas and
participation.
Step 4: Develop a Baseline
Executive Order 12856 (Section 3-304)
requires all Federal facilities to comply
with the Toxic Release Inventory (TRI)
reporting requirements under Section 313
of the Emergency Planning and Com-
munity Right-to-Know Act (EPCRA).
As explained in Section 2-207 of
Executive Order 12856, these additional
toxic pollutants may include "extremely
hazardous chemicals" as defined in
Section 329(3) of EPCRA, hazardous
wastes as defined under the Resource
Conservation and Recovery Act (RCRA)
of 1976 (42 U.S.C. 6901-6986), or haz-
ardous air pollutants under the Clean Air
Act Amendments (42 U.S.C. 7403-7626).
For the purposes of establishing the base-
line (under 3-302(c)), "other chemicals"
are in addition to (not instead of) the
Section 313 (TRI) chemicals. This
means that facilities must not only deter-
mine which TRI chemicals they use and
release at or above the thresholds estab-
lished under EPCRA but also have to
quantify the use and release of other
"extremely hazardous chemicals" in
developing their pollution prevention
plans. Facilities may choose to highlight
this TRI reporting and related reductions
in the individual facility pollution pre-
vention plans required by Section 3-
302(d) of this Executive Order.
The chemical usage and release baseline
required for TRI reporting is the first step
in developing a facility baseline. These
data are the minimum data needed for a
hazardous material usage and release
baseline. Such data, however, will not be
the only useful information for develop-
ing a facility pollution prevention plan
that addresses all environmental issues
and costs.
Developing an environmental baseline
involves building a comprehensive pic-
ture of the materials usage patterns and
environmental impacts associated with
the facility. To develop a complete base-
line, you will have to collect various
information and assimilate it into a uni-
10
Section II: Facility Pollution Prevention Plan Development Steps
-------
fied, multimedia description of your
facility's environmental impacts. The
baseline will define materials usage pat-
terns and the environmental problems
that arise from these usage patterns. To
obtain this information, you will search
and review data with the operations staff
who are tasked to support this effort.
Specifically, each waste generating oper-
ation should have one point of contact
who can provide baseline statistics that
represent that operation.
You can use the information gathered in
several ways to describe the impacts cre-
ated by onsite activities. In many cases,
you may have to calculate or estimate the
exact impacts by using a material balance
calculation. The volumes of chemical
releases are calculated by quantifying the
amounts of materials used and the known
amounts of waste generated. This
method assumes that all material used
will either be used in the product,
become a waste, or be released into the
environment. The mass balance is a sim-
ple way to account for all material that
comes into the facility.
Pollution prevention can begin when
materials enter the facility. Therefore,
the baseline development process begins
with the purchasing and supply depart-
ments. You and your pollution preven-
tion team should determine who is
responsible for purchasing and handling
raw materials. Does one person order
everything in a tightly controlled system,
or can many people order materials for
their sections' needs or their own needs?
How does the supply system track, store,
and distribute the new materials?
Developing a baseline of purchasing
information also involves quantifying the
amounts and costs of the materials pur-
chased and distributed, as well as identi-
fying the locations and processes where
they are being used.
With the materials purchasing, handling,
and usage information collected, one-half
of the puzzle is complete. The other half
focuses on identifying waste generation
and environmental releases from the
facility. What products or services are
being conducted at the facility that con-
sume materials? What wastes and pollu-
tants are being generated by the use of
the materials, what processes are generat-
ing these wastes and pollutants, and what
are the volumes and characteristics of the
wastes being generated? In addition, you
Characterize Material
Purchase and Use
Identify and Quantify
Waste Generation
Assess Environmental
impacts
Quantify waste
generation and
environmental
release
Characterize
environmental
damage
Associate damages
to activities and
process
ChawMte
standard operating
procedures for
The Baseline
Development
Process
Quantify amounts
of material
disposed of
without use
CharaltBrite
IPQ33SSSH5) tflrstt USB
mateliaWsamd
haMidous
f f**j chemicals
Document cosls by
activity and !>
process
Keys to Success in
Developing a Baseline
In developing a baseline, it is cru-
cial to involve all appropriate staff.
The baseline is the foundation of
the pollution prevention program.
Everyone who generates waste or
creates an environmental impact
must be included in the beginning.
Key personnel include:
.Environmental coordinator and the
baseline development team
.Hazardous waste collection site
personnel
. Waste generators
.Purchasing department
. Supply department
• Public works department
.Environmental program staff
. Safety program staff.
Data will be inconsistent or non-
existent. Your most difficult chal-
lenge will be collecting enough
information to prepare the baseline.
To simplify the data collection
process, be sure to:
• Educate staff on what information
is needed and why.
• Carefully document data/informa-
tion and manage it for easy
retrieval.
• Do not be shy; conduct interviews
with facility staff and ask questions.
Oftentimes, staff are the only
source of accurate data and infor-
mation.
* Be resourceful; you and your team's
observations and analysis may be
the only way to evaluate specific
operations.
-------
should understand how wastes are man-
aged following their generation, what
problems are associated with the man-
agement or mismanagement of these
wastes, and how they are disposed of.
You should also identify the costs associ-
ated with waste handling activities and
whose budget pays for these costs.
At this point, the puzzle might appear
finished, but the borders are still missing.
The borders consist of the facility's nat-
ural resources and land use. You and
your team should investigate how facility
activities affect the external environment.
What are the impacts of these activities
on the natural resources and land, not
only on the facility's property but beyond
its borders? Stormwater runoff, ground-
water contamination, and air emissions
are examples of the environmental effects
that might be characterized in your base-
line.
Remember that the reason you are devel-
oping a baseline is to assess pollution
prevention opportunities that might be
taken to reduce environmental impacts,
waste generation, and costs. When you
begin to collect baseline data, you will
observe operations and review data. As
part of this process, you may identify
pollution prevention opportunities. You
should document these opportunities and
incorporate them into your facility pollu-
tion prevention plan.
The baselining effort may require signifi-
cant effort over a long period of time.
The size of your facility, the number of
waste generating processes, and environ-
mental program staffing may make the
baselining task a timely effort. Base-
lining should be a continuous process.
You should develop an initial baseline
within your time and staff constraints and
build it over time. If you must gradually
develop a baseline, start with the process-
es that you know create your most seri-
ous environmental problems and proceed
from there. For example, you can use
your TRI reporting data as your initial
facility baseline. Over time, you can
expand these data to include other chemi-
cals and environmental impacts.
Baselining is a critical effort that should
continue from this point forward. Base-
lining is the process of documenting
environmental impacts, associating them
Material Balance for Defining Usage Patterns
with facility activities, and compiling
records into an accessible information
base. The table on pages 14 and 15 iden-
tifies many types of information that
might be useful in developing your facili-
ty environmental baseline.
Step 5: Conduct Pollution Prevention
Activities and Opportunity
Assessments
Under Section 3-302(d) of Executive
Order 12856, you are required to identify
pollution prevention activities and con-
duct opportunity assessments as part of
your pollution prevention plan, Specific-
ally, Section 3-302(d) states that "Fed-
eral agencies shall conduct assessments
of their facilities as necessary to ensure
development of such plans and of the
facilities 'pollution prevention programs. "
Using the baseline data, you can identify
potential pollution prevention activities
and opportunities. For example, the
baseline may indicate that water usage is
a critical issue for a facility. If water is a
critical issue, what activities can be initi-
ated to reduce usage, waste, and overall
cost? For every issue documented under
the baseline, the team should identify
activities that will promote pollution pre-
vention. In general, these activities will
include the following:
• Additional Analysis—The baseline
may indicate that a process or envi-
ronmental impact is not fully under-
stood and that more complete infor-
mation or data are needed. To fully
characterize the problem, the staff
will have to conduct analyses, analyti-
cal measurements, or studies. Upon
completion of these analyses, the staff
will assess pollution prevention
opportunities.
• Immediate Implementation—The
baseline may provide applications of
existing pollution prevention strate-
gies, techniques, or technologies that
can be implemented immediately to
reduce environmental impacts. In
such cases, the facility may seek to
implement pollution prevention
options immediately.
12
Section II: Facility Pollution Prevention Plan Development Steps
-------
• Pollution Prevention Opportunity
Assessments—The baseline may also
show that processes may be amenable
to pollution prevention options. To
define the best option, the staff should
conduct a thorough pollution preven-
tion opportunity assessment. Execu-
tive Order 12856 requires all Federal
facilities to conduct opportunity
assessments (as needed) to develop
their facility pollution prevention
plan. Several manuals (referenced in
Section III) can be used to conduct
pollution prevention opportunity
assessments. Page 16 provides a gen-
eral summary of the assessment
process.
Focus your initial effort on the pollution
prevention activities that affect processes
responsible for the environmental issues
or impacts of greatest concern. Setting
priorities requires weighing different
objectives, such as toxic use reduction,
cost reduction, or water use minimiza-
tion. Each facility will have its own
objectives depending on its overall pol-
lution prevention goals and site-specific
conditions (see Step 6 below).
Your facility pollution prevention plan
should include a list of all of the pollu-
tion prevention activities and opportuni-
ties identified in this step. The facility
pollution prevention plan will eventually
act as a road map that ties together all of
the additional analyses with the immedi-
ate implementation and opportunity
assessment activities. As activities are
completed or new ones identified
through pollution prevention opportunity
assessments, the list of prevention activi-
ties will change.
Step 6: Develop Criteria and
Rank Facility-Wide Pollution
Prevention Activities
By this time, you have a list that de-
scribes hundreds of pollution prevention
activities. The next step is to develop
priorities and rank the activities. That is,
develop a list of action items that you
The recognized need to prevent pollution
based upon the baseline facility
Planning and Organization
• Organize assessment program team
Assessment
organization and
commitment to
proceed
Assessment Phase
« Collect process and facility data
•Prioritize and select assessment targets
• Select people for assessment teams
. Review data and respect sile
• Generate options
• Screen and select options for further study
Assessment report
of selected options
Final report,
including
recommended
options
Select new
assessment
targets and
reevaluate
previous options
Feasibility Analysis Phase
. Technical evaluation
• Economic evaluation
• Select options for implementation
Implementation
»Justify projects and obtain funding
• Install equipment
• Implement procedure
• Evaluate performance
Successfully implemented
pollution prevention projects
Procedure for Pollution Prevention Opportunity Assessments
and facility staff will undertake to inte-
grate pollution prevention into your
facility's activities. The order in which
you choose to initiate pollution preven-
tion activities and projects depends upon
facility-specific considerations and envi-
ronmental goals. These considerations
will be used to rank all of the pollution
prevention activities identified previous-
ly. The following considerations are
commonly used to rank such activities:
.Environmental Compliance—The
project's impact on improving the
facility's overall environmental com-
pliance status. Section 3-30 l(b) of
Executive Order 12856 places special
emphasis on identifying and imple-
menting pollution prevention projects
that improve compliance.
Mission Impact—The project's
potential impact on the facility's mis-
sion and the ability of the staff to
accomplish their mission.
Environmental Benefits-The pro-
ject's environmental benefits (e.g., air
emission reduction, hazardous waste
minimization).
Ease of Implementation—Complex
changes that require additional staff
effort may not be accepted as easily
as simpler changes.
Cost Savings—The potential cost
savings associated with project im-
plementation. Pollution prevention
techniques that result in improved
efficiency and cost savings are usual-
ly accepted more readily than options
that result in increased costs.
13
-------
Types of Information for Developing an Environmental Baseline
Information Type
Material Usage for Hazardous and
Nonhazardous Materials of Concern
Components of Materials Used at the
Facility
Power Usage and Water Consumption/
Disposal Statistics for Each Activity at
the Facility
Facility Designs
Uses
Identifying and quantifying use of target
materials at the facility
Defining the usage patterns of the activi-
ties resident to the facility
Performing mass balance estimations of
environmental releases facility-wide and
activity-specific
Determining whether or not the facility
meets Toxic Release Inventory reporting
thresholds for chemicals of concern
Developing a list of materials and prod-
ucts used at the facility that must be eval-
uated to identify which contain hazardous
components, including the EPA 17 chemi-
cals of concern
Identifying the use of specific hazardous
components, such as the EPA 17 chemi-
cals of concern or extremely toxic materi-
als
Determining where chemical substitute
analyses may be needed
Documenting how utilities are used to
identify opportunities to reduce usage
Identifying greatest contributors to sew-
ered, aqueous wastes
Verifying the location of storm sewer and
sanitary sewer inlets and outfalls
Verifying the location of and drainage to
all oil/water separators
Understanding the flow of stormwater and
surface water to determine potential
impacts
Locating underground and above ground
storage tanks
Locating washracks and suitable sites for
washing activities
Documenting the sewer system and
design of the wastewater treatment facili-
ties (if present)
Sources
Supply function files and/or data
systems; material purchasing, requisi-.
tion, and manifesting records often
important
Activity requisition records (if kept or
complete)
Warehouse material inventory records
Facility material inventory records
Direct observation of use patterns and
practices through onsite facility
assessments
TRI (Form R) report
Materials Safety Data Sheets (MSDS)
kept at each of the activities and by the
Health and Safety Office; on-line MSDS
systems maybe useful in cases where
materials identified but sheets are not
available
Equipment specifications
Utility usage statistics
Building meters
Onsite observation and estimation of
non-metered uses based on rough
measurement (flow over time)
Engineering facility records and maps
Facility master planning documents
Construction records
Corps of Engineers maps and records
if facility built or modified by the Corps
Onsite characterization of facilities and
processes
14
Section II: Facility Pollution Prevention Plan Development Steps
-------
Types of Information for Developing an Environmental Baseline (continued)
Information Type
Hazardous Materials and Waste Handling
Procedures
Solid Waste Management Procedures
Solid and Hazardous Waste Generation
and Disposal Statistics
Regulatory Operating Parameters
Environmental Impacts
Uses
identifying materials management
practices that result in wastes
Identifying waste management prac-
tices that result in releases of chemi-
cals to the environment
Defining practices that inhibit segrega-
tion and recycling of wastes
Identifying practices that result in com-
pliance problems
Identifying opportunities for recycling
Creating plans for comprehensive recy-
cling projects
Developing the waste generation base-
line that will be used to measure suc-
cess in attaining prevention goals
Developing priorities for conducting
initial facility and process-specific facil-
ity assessments
Quantifying the costs associated with
hazardous waste management to help
create cost justifications for prevention
projects
Quantifying the costs associated with
solid waste generation and disposal to
develop programs that are more cost
effective and comprehensive
Identifying the potential for alternative
waste management practices, including
comporting and waste exchange/sale
Defining release rates of regulated
materials to the air, water, and soils
Identifying wastes associated with
facility activities
Identifying compliance issues that are
often the highest priority considera-
tions for the facility managers and
environmental staff
Providing a summary of environmental
impacts caused by the facility
Identifying and quantifying the impacts
that may arise from land management
activities
Sources
Standard operating procedures for haz-
ardous materials and waste handling and
management activities
Mission statements
Equipment specifications
Spill prevention and management plans
Onsite observation of hazardous material
and waste management practices
Permits
Waste management contracts
Recycling program statements or plans
Onsite observation of solid waste man-
agement practices as implemented by
residents and staff
Facility and process flow diagrams
Waste management contracts and billing
statements
Hazardous materials shipping manifests
Existing hazardous waste tracking sys-
tems
Facility records and files on waste gener-
ation
Facility-wide waste estimation surveys
Supply system records as input to mass
balance estimations
TRI (Form R) reports
Water discharge permits
City sanitary discharge permits
Air permits
Hazardous waste storage permits
Environmental compliance audit reports
Land and facility management plans
Environmental assessments and impact
studies (National Environmental Policy
Act documents)
15
-------
Key Information About Pollution Prevention Opportunity Assessments
Pollution Prevention Opportunity
Assessments
The pollution prevention opportunity
assessment is one of the most important
activities that you will perform in the plan-
ning and implementation of your facility
pollution prevention program. The oppor-
tunity assessment is a tool used to define
the specific characteristics of a single
operation that creates environmental
impacts (e.g., wastes, releases of toxic
chemicals to the environment, power/
water usage, habitat destruction),
Specifically, the pollution prevention
opportunity assessment is a systematic
evaluation of processes and operations to:
.Characterize all aspects of the process
or operation, including process flow,
waste generation patterns, material
and power consumption, costs, man-
power, reliance on toxic chemicals
• Define the impacts that the process
and related wastes have on the air,
water, and land
.Associate impacts and wastes with
specific unit operations
.Assign related costs and liabilities with
specific wastes and management prac-
tices.
This detailed process information is used
to identify, refine, and plan the implemen-
tation of pollution prevention technologies
that will reduce the environmental impacts
associated with the process.
Pollution prevention opportunity assess-
ments are performed after the baselining
activity. An opportunity assessment can
be performed anytime after the baseline is
developed to augment baseline data.
Hence, opportunity assessments can be
performed as part of the planning process
or anytime after the planning process.
EPA recommends that detailed, process-
specific opportunity assessments be per-
formed after completion of the facility pol-
lution prevention program plan so that
environmental staff can develop priorities
in conducting opportunity assessments
for all candidate operations. Complete the
facility plan before initiating the detailed
pollution prevention opportunity assess-
ments.
Common Pollution Prevention
Opportunities
When conducting an opportunity assess-
ment, it is important to consider all types
of activities. While it may be easier to
focus on source reducing technologies,
you may be ignoring inexpensive and easy
fixes that can result in significant reduc-
tions that arise from procedures or policy
modifications. Training and awareness
may also yield significant reductions.
Training an equipment operator to proper-
ly operate a machine or increasing worker
awareness about a particular procedure
may eliminate an environmental or cost
concern. All of the following types of
activities may reduce environmental
impacts:
• Policy changes
• Procedural changes
• Equipment modifications
• Material substitution
• Training
• Efficiency improvements
• Waste stream segregation
• Housekeeping practices
• Inventory control
• Reuse of materials.
A pollution prevention opportunity
assessment should consider any of these
options as a potential approaches to
meeting environmental goals.
Keys to Success in Conducting
Opportunity Assessments
The following approaches will facilitate
your opportunity assessment:
• Solicit assistance and input from staff
who operate the process. They are the
experts.
• Build consensus among staff on the
best pollution prevention options for
their processes. If they do not agree,
they will not implement changes.
• Explain what you are doing. The staff
you are helping with an assessment
will have to implement the opportuni-
ties identified.
• Explain why the assessment is impor-
tant to all staff involved.
• Do not rule out any options until you
have actually considered the merits
and potentials (see Steps 5 and 6).
• Do not rush. If you have to go back for
more information, do so.
• Use information sources, data sys-
tems, and technical assistance services
to generate ideas (see Section III).
The most common problem arises when
process staff do not understand why you
are asking so many questions. You need
their help, so solicit their participation by:
.Explaining what you are doing and why
.Asking for their input
.Building consensus
• Being considerate of their other duties
• Giving examples of how pollution pre-
vention will make their jobs easier.
Rememberjou cannot do this alone. The
staff who generate the waste will ultimately
have to reduce it. They must be involved
from the very beginning. To assist you in
conducting opportunity assessments, EPA
has published several manuals that describe
assessment techniques. Section III provides
references for these documents.
16
Section II: Facility Pollution Prevention Plan Development Steps
-------
Other criteria that you may consider
include the availability of disposal
capacity, community concerns, environ-
mental justice goals, worker safety/expo-
sure, anticipation of future regulations,
and resource consumption.
After you have identified ranking crite-
ria, you should rank all pollution preven-
tion activities identified on a numerical
scale by assigning a value that reflects
how the activity matches each criterion.
The highest ranking activity (i.e., the
opportunity with the highest total score)
should be considered first for implemen-
tation. Often, one criterion is considered
to be more important than the others. In
such a case, a weighting factor can be
used. Further information on ranking
schemes is presented in the guidance
documents listed in Section III.
Example of a Ranking Matrix Used at a U.S.
Postal Service Facility
Criteria Water-Borne High-Volume Low- Gun Washer
Coating Pressure Spray
_
Reduction in Occupational Hazard
Reduction in a RCRA-Regulated Waste
Reduction of a 33/50 Program Chemical
Reduction of Environmental Impact
Capital Cost
Ease of Implementation
TOTAL
_ .
5
5
5
4
3
2
24
Gun
5
5
5
4
4
2
25
Station
5 -
4
4
2
2
3
20
5 = very positive, 4 = positive, 3= neutral, 2= negative, 1 = very negative
Step 7: Conduct a Management
Review
Once the pollution prevention team has
developed a ranked list of pollution pre-
vention activities, you should obtain
upper management and senior staff sup-
port. This is an important opportunity
for upper management to reaffirm its
support for the pollution prevention pro-
gram. To do this, you should convene a
management review committee to
review your facility pollution prevention
plan. The management review commit-
tee should include representatives from
all of the organizations that will be
affected by the pollution prevention
program.
During management review, the pollu-
tion prevention team should present the
ranked list of activities for approval.
You should explain the process used to
develop the list and emphasize the
potential benefits of the effort. Upper
management must understand the rela-
tionship between the pollution preven-
tion program activities and their impacts
on the facility mission and existing envi-
ronmental programs. The end product of
this review should be a coherent, inte-
grated pollution prevention program that
supplements other facility programs
(e.g., health and safety, environmental
compliance, training, and development).
By providing this information, you will
allow upper management to make
informed decisions from a program-wide
perspective about prioritizing pollution
prevention projects, developing an
implementation schedule, and providing
funding. If additional resources are
needed for establishing the pollution pre-
vention program (e.g., staff positions),
they should be requested at this point.
You now have a management-approved
pollution prevention plan for your facili-
ty. The next steps focus on getting your
program started. It is important to real-
ize that the following steps may proceed
simultaneously. In addition, you may
find that the facility pollution prevention
plan changes once you start learning
more and conducting additional assess-
ments. Be flexible and willing to modify
the plan as you proceed.
PUBLIC PARTICIPATION
Executive Order 12856 requires facilities
to provide the public with access to their
pollution prevention plans and pro-
grams. Specifically, the Executive
Order requires facilities to provide pub-
lic access to their facility pollution pre-
vention plans and encourages facilities
to include public participation in the
facility planning process. Under
Section 508 of Executive Order 12856,
Federal facilities should:
• Maintain a copy of their pollution
prevention plans onsite for review by
their host agencies, EPA, and State
regulators.
• Provide their facility pollution pre-
vention plans to EPA or States upon
request but should not submit the
plans directly to EPA.
• Readily allow and encourage public
access to their facility pollution pre-
vention plans and all supporting data.
Under Section 301 of Executive Order
12856, Federal facilities should also
involve the public in developing all
facility pollution prevention plans and
programs. In doing so, Federal facilities
will foster a cooperative environmental
protection approach within their com-
munities.
17
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MEASUREMENTS OF
PROGRESS
Executive Order 12856 requires agencies
and facilities to report on their efforts to
reduce the release of hazardous and
extremely toxic materials to the environ-
ment. Specifically, the Order requires
facilities and agencies to report on their
progress in accomplishing their 50-percent
reduction in the use and release of
extremely toxic (i.e., TRI) chemicals.
Therefore, it is critical that you establish
mechanisms to measure the impacts of
pollution prevention activities on waste
generation and environmental releases of
chemicals. The impacts should be mea-
sured and reported in comparison to the
facility-wide baseline (Step 4).
Measuring progress in achieving pollution
prevention goals is part of an on-going
process that starts with the official ribbon
cutting ceremony. It can be thought of as a
self-auditing process that enables the facili-
ty to measure the program's development
as it grows. By carefully monitoring pro-
gram development, the pollution preven-
tion team can make the necessary adjust-
ments and, thus, be certain that each pollu-
tion prevention dollar is being spent wisely.
Measurement activities occur at two lev-
els—the program level and the project
level. Each level entails a slightly different
approach. Program-level measurement
involves a constant process of evaluation
and feedback that should occur after the
initial program has been established.
Milestones should be built into the project
implementation schedule, which is sub-
mitted during the initial management
review. The evaluation process may
reveal the need for further data collection
or adjustment of the scope of the pro-
gram's goals and objectives. Additional
funding and staff resources may be
required for implementation to proceed
according to schedule.
Measurement at the project level is more
specific. Each project should be evaluated
against the facility baseline data to deter-
mine how successfully it is accomplishing
its intended purpose. For instance, the
environmental coordinator needs to know
if a newly installed piece of equipment has
met expectations that it will reduce waste
generation by a certain percentage and
save on disposal costs. Regardless of
whether the waste volumes turn out to be
lower or higher than expected, the coordi-
nator should have this information. Other
parameters used for evaluating project
success are reductions in the following
areas:
.Environmental compliance violations
. Material losses
.The number of materials purchased
requiring Material Safely Data Sheets
.The number of worker sick days
resulting from occupational exposure.
The pollution prevention team should
develop a project tracking system for
monitoring projects. The complexity of
the system depends on the number and
type of projects being implemented. The
team should work closely with other staff
in the environmental department to avoid
collecting the same data twice. Informa-
tion collected as part of program monitor-
ing may be useful for complying with
environmental reporting requirements.
As a result of the evaluation process, the
pollution prevention team can apply
lessons learned to future projects and pre-
vent the same mistakes from being repeat-
ed. The team should also establish a for-
mal mechanism for reporting the results of
the pollution prevention program to man-
agement, as well as to the facility commu-
nity at large. Keeping management inter-
ested in the program's achievements
encourages continued funding for future
initiatives. Keeping the facility personnel
interested increases cooperation and
enthusiasm.
IMPLEMENTATION OF THE
PLAN
The facility planning requirements under
Executive Order 12856 were established
to encourage Federal facilities to develop
pollution prevention programs. As such,
developing a facility-wide pollution pre-
vention program plan is only a beginning.
The facility pollution prevention plan only
identifies activities that should help to
integrate pollution prevention into your
facility's mission. The real effort begins
once the plan has been finalized. At that
point, you and your co-workers must .
translate the facility pollution prevention
plan into activity. If not, the facility pollu-
tion prevention plan will become just
another study.
To get the program off to a fast start, you
should select a few low-cost, high-profile
pollution prevention projects for immedi-
ate action. To support you in conducting
cost-benefit analyses to justify projects,
EPA developed the Costing and Life Cycle
Analysis for Pollution Prevention Invest-
ments manual. This manual provides
guidelines for conducting financial evalu-
ations of pollution prevention options (see
Section III).
The results of these initial projects can
demonstrate the utility and effectiveness
of pollution prevention in meeting envi-
ronmental quality standards. Moreover,
these initial projects can be used to build
support for the pollution prevention pro-
gram. Once the pollution prevention pro-
gram demonstrates waste reductions and
cost savings, it will gain legitimacy, sup-
port, and interest. Various organizations at
your facility may want to pursue pollution
prevention alternatives once your initial
efforts demonstrate savings and reductions
in waste and pollution.
By developing a pollution prevention
plan, each Federal facility will meet
Executive Order 12856 planning require-
ments. In implementing its plan, each
Federal facility will improve its environ-
mental program and contribute to its
agency-specific reduction goals, also
required under Executive Order 12856.
Ultimately, through its pollution preven-
tion plan, each facility will have the
opportunity and mission to demonstrate
environmental stewardship that will bene-
fit the Federal government and the
nation as a whole.
18
Section II: Facility Pollution Prevention Plan Development Steps
-------
Measuring Progress and Success
Measuring the progress and success of pollution prevention activities is critical at both the programmatic and project levels. By
measuring the progress of each project, the facility can determine the success of the program as a whole. To measure the suc-
cess of projects and the program you should undertake the following initiatives:
• Establish Milestones—The pollution prevention program and each individual project should be designed to accomplish mile-
stones over a measurable amount of time. Milestones for the program maybe conducting opportunity assessments, providing
staff training, and reducing wastes. Milestones for projects might include conducting an opportunity assessment, choosing a
pollution prevention option, purchasing equipment, and reducing environmental releases of toxic chemicals by a known per-
centage overadefined period of time. Every pollution prevention activity should include defined milestones for tracking
progress and success.
• Identify Measurement Criteria—Each pollution prevention project should include measurable variables that define success.
This might include pounds of chemicals eliminated from disposal (assuming the same level of activity) or the percentage of
paper used that contains recycled content. Forevery project, specific target measurements areneeded toobjectively evaluate
the progress or success of the effort.
• Identify Data and Information Requirements—For each measurement criterion, you should define the data needed to adequately
represent thedefined standard, information requirements might include waste generation statistics, chemical release rates,
chemical loss rates, chemical use rates, production rates, costs, power and water usage statistics, and other types of informa-
tion.
• Develop a System to Compile and Track Information and Data—A computer data base or spread sheet system might be useful
in compiling data. If measurement criteria require data manipulations or calculations, a computer spread sheet program will
facilitate tracking. For example, a measurement criterion might be a ratio of waste generated to the level of production or activi-
ty. Therefore, you would collect waste generation and production data amied to calculate a simple ratio. A computerized
system may be helpful (especially if you track numerous projects and criteria).
• Evaluate Data and Information—As you compile data and perform calculations, it is critical to review the projects and pro-
grams. These data will help to define program successes and failures. The data will also help identify additional activities that
will strengthen the pollution prevention projects and the facility-wide program.
Starting a Pollution Prevention Project
Unlike compliance requirements, pollution prevention options involve changing processes and activities that create wastes and
environmental impacts. Therefore, you must have the cooperation of the shop or facility staff. The following considerations
may play a critical role in initiating pollution prevention projects:
• Obtain approval for the pollution prevention project from your management and the management of the affected facility and
involve staff on defining the pollution prevention project. Develop and implement their ideas about the best reduction
approach.
• Enlist operational staff support. The facility staff will determine how well a pollution prevention option works. The staff must
understand and embrace the concept for success.
• Determine whether training is necessary so that the personnel understand the purpose of the project, the goals, and the crite-
ria for success. Staff should clearly understand the direct benefits of the project, such as reduced exposure to toxic chemi-
cals, less paperwork, and a cleaner environment.
• Determine whether policies or standard operating practices need to be modified.
• If a project requires purchasing equipment, network with other Federal facility coordinators or technical assistance programs
to learn what does and does not work. Remember to include installation costs when preparing the request for funding.
• Work with the Public Affairs Office to advertise the project once it is initiated and is reducing pollution. Be sure to recognize
all staff who are contributing to the project.
19
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SECTION III: TECHNICAL ASSISTANCE
AND LITERATURE
As you establish your pollution prevention program plan and implement
pollution prevention projects at your Federal facility, you may want addi-
tional ideas on approaches and solutions to specific problems. To assist
you in your efforts, various Federal agencies have developed guidance doc-
uments on ways to develop and implement pollution prevention programs.
These are identified below. In addition, some Federal and State agencies
provide direct technical assistance on pollution prevention topics and pro-
jects. Contacts for these assistance programs are listed in the pages that
follow,
FEDERAL FACILITY POLLUTION
PREVENTION PLANNING GUIDE
POLLUTION PREVENTION
PLANNING DOCUMENTS
1. Federal Facility Pollution
Prevention: Tools for Compliance
EPA/600-R-94- 154
U.S. Environmental Protection
Agency (EPA)
Office of Research and Development
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562
2. Pollution Prevention in the Federal
Government: Guide for Developing
Pollution Prevention Strategies for
Executive Order 12856 and Beyond
EPA/3 OO-B-94-007
U.S. EPA
401 M Street, SW(2261)
Washington, DC 20460
202-260-9801
3. Facility Pollution Prevention Guide
EPA/600-R-92-008
U.S. EPA
Office of Research and
Development
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562
4. Costing and Life Cycle Analysis for
Pollution Prevention Investments:
A Practical User 's Guide to
Environmental Project Financial
Analysis at Federal Facilities
U.S. EPA
401 M Street, SW
Washington, DC 20460
202-260-9801
5. Pollution Prevention Directory
EPA/742-B-94-005
U.S. EPA
401 M Street, SW
Washington, DC 20460
202-260-9801
AGENCY GUIDANCE
DOCUMENTS
6. Navy Shore Installation Pollution
Prevention Planning Guide
Dec. # OPNAV-P45- 120-10-94
Office of Chief of Naval Operations
2000 Navy Pentagon
Washington, DC 20350
703-602-5334
7. U.S. Air Force Installation Pollution
Prevention Program Manual
United States Air Force
Air Force Center for Environmental
Excellence (AFCEE)
AFCEE/ESP
8106ChennaultRoad
Building 1161
Brooks AFB, TX 78235-5318
1-800-233-4356
8. Army Pollution Prevention
Plan Manual: A Guide for
Army Installations
Army Environmental Policy Institute
430 10th Street, Suite 5105
Atlanta, GA 30318
404-875-6813
21
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9. Guidance for Preparation of Site
Waste Minimization and
Pollution Prevention Awareness Plans
Department of Energy
1000 Independence Avenue, S W
Washington, DC 20585
301-427-1570
TECHNICAL ASSISTANCE
PROGRAMS
1. Pollution Prevention Information
Clearinghouse (PPIC)
U.S. Environmental Protection Agency
PM 211-A
401 M Street, SW
Washington, DC 20460
202-260-1023
The Pollution Prevention Information
Clearinghouse (PPIC) is dedicated to
reducing or eliminating industrial pollu-
tants through technology transfer, educ-
tion, and public awareness. It is a free,
nonregulatory service of the U.S. EPA
and consists of a repository of pollution
prevention information, a telephone ref-
erence and referral service, and a com-
puterized information exchange system.
2. Pollution Prevention Information
Exchange System (PIES)
EPA Systems Development Center
200 N. Glebe Road
Arlington, VA 22203
703-506-1025 (modem)
PIES is a free, 24-hour electronic net-
work accessible by personal computer
equipped with a modem. PIES consists
of message centers, bulletins, technical
data bases, case studies, and issue-spe-
cific conference listings.
3. Federal Agency Mini-Exchange
(FAME)
EPA Systems Development Center
200 N. Glebe Road
Arlington, VA 22203
703-506-1025 (modem)
FAME is a data base on the Pollution
Prevention Information Exchange System
that provides information on pollution
prevention/recycling efforts at Federal
facilities.
4. Defense Environmental Network and
Information Exchange (DENIX)
DECIM Office
Hoffman 2, Room 12S49
200 Stovall Street
Alexandria, VA 22332
1-800-642-3332
703-325-0002
DENIX is a Department of Defense com-
munications platform for the dissemina-
tion and exchange of environmental
information across all DOD components.
5. PRO-ACT
AFCEE
8106ChennaultRoad
Building 1161
Brooks AFB, TX 78235-5318
1-800-233-4356
210-536-4214
DSN 240-4214
PRO-ACT is an environmental informa-
tion clearinghouse and hotline provided
by the Air Force Center for Environ-
mental Excellence (AFCEE). PRO-ACT
services are provided free of charge to all
Air Force personnel.
6. Center for Environmental Research
Information (CERT)
Dorothy Williams
U.S. Environmental Protection Agency
Center for Environmental Research
Information (CERI)
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562
CERI serves as the exchange of scientific
and technical environmental information
produced by EPA in brochures, capsule
and summary reports, handbooks,
newsletters, project reports, and manu-
als.
7. Center for Waste Reduction
Technologies (CWRT)
Center for Waste Reduction
Technologies
American Institute of Chemical
Engineers
345 East 47th Street
New York, NY 10017
212-705-7407
CWRT was established in 1989 by the
American Institute of Chemical
Engineers to support industry efforts
in meeting the challenges of waste
reduction through a partnership with
industry, academia, and government.
8. The National Pollution Prevention
Roundtable
David Thomas
218 D Street, SE
Washington, DC 20003
202-543-7272
The Roundtable is a group of pollution
prevention programs at the State and
local level in both the public and acade-
mic sectors. The member programs are
engaged in activities including multi-
audience training and primary to post-
secondary pollution prevention
education.
9. Northeast States Pollution
Prevention Roundtable (NE
Roundtable)
Terri Goldberg, Program Manager
Northeast States Pollution Prevention
Roundtable/Northeast Waste
Management Officials' Association
85 Merrimac Street
Boston, MA 02114
617-367-8558
The NE Roundtable was initiated in 1989
by the Northeast Waste Management
Officials 'Association to assist State
programs, industry, and the public in
implementing effective source reduction
programs.
10. Pacific Northwest Pollution
Prevention Research Center
Madeline Grulich, Director
Pacific Northwest Pollution
Prevention Research Center
411 University Street, Suite 1252
Seattle, WA 98101
206-223-1151
The Pacific Northwest Pollution
Prevention Research Center is a non-
profit public-private partnership dedicat-
ed to the goal offurthering pollution pre-
vention in the Pacific Northwest.
22
Section III: Technical Assistance and Literature
-------
11 Waste Reduction Institute for
Training and Applications
Research, Inc. (WRITAR)
Terry Foecke
Waste Reduction Institute for
Training and Applications
Research, Inc.
1313 5th Street, SE
Minneapolis, MN 55414-4502
612-379-5995
WRITAR is designed to identify waste
reduction problems, held find their solu-
tions, and facilitate the dissemination of
this information to a variety of public
and private organizations.
12. Waste Reduction Resource Center
for the Southeast (WRRC)
Gary Hunt
Waste Reduction Resource Center for
the Southeast
3825 Barrett Drive
PO Box 27687
Raleigh, NC 27611-6787
WRRC was established to provide multi-
media waste reduction support for the
States of U.S. EPA IV (Alabama, Florida,
Georgia, Kentucky, Mississippi, North
Carolina, South Carolina, and
Tennessee).
FEDERAL FACILITY
POLLUTION PREVENTION
CONTACTS
Department of Agriculture
William Opfer
Environmental Health Engineer
Department of Agriculture
PO Box 96090
Washington, DC 20090-6090
202-205-0906
Central Intelligence Agency
Larry McGinty
Chief, Environmental and Safety
Group/QMS
Central Intelligence Agency
Washington, DC 20505
703-482-4533
Department of Commerce
Jack Murphy
Environmental Compliance Officer
Office of Management Support
U.S. Department of Commerce
Room 6020
14th and Constitution Avenue
Washington, DC 20230
202-482-4115
Department of Defense
Mr. Andrew Perth
ADUSD/PP
Skyline 6, Suite310
5109 Leesburg Pike
Falls Church, VA 22041
703-756-2969
Economic Development
Administration
Dr. Frank Monteferrante
Senior Environmental Specialist
U.S. Department of Commerce
Herbert C. Hoover Building
Room 7019
Washington, DC 20230
202-482-4208
Department of Energy
Susan C. Weber
Waste Minimization Division
Office of Waste Management (EM-334)
U.S. Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585
301-903-1388
Food and Drug Administration
Dr. Naresh K. Chawla
Chief, FDA Safety Office (HFA-205)
Food and Drug Administration
7500 Standish Place
Rockville, MD 20855
301-594-1718
General Services Administration
Karone Peace
Safety and Environmental Division
Environmental Branch (PMS)
General Services Administration,
Room 4340
18th and F Streets, NW
Washington, DC 20450
202-501-3518
Department of the Interior
Connie Kurtz
Environmental Protection Specialist
Division of Hazardous Materials
Management
Department of the Interior, MS 2340-
MIB, Room 2349
Office of Environmental Affairs ,
1849 C Street, NW
Washington, DC 20240
202-208-7554
Department of Justice
Marvin Fink
Safety and Health Manager
Security and Emergency Planning Staff
U.S. Department of Justice, Room 6525
10th and Constitution Avenue, NW
Washington, DC 20530
202-514-5076
National Aeronautics and Space
Administration
Olga Dominguez
Environmental Management Division
National Aeronautics and Space
Administration
NASA Headquarters, Code JE
Washington, DC 20546
202-358-1093
National Oceanic and Atmospheric
Administration
I. Sam Higuchi, Jr.
Senior Environmental Compliance
Officer
National Oceanic and Atmospheric
Administration
SSMC-2/OA3X1 Room 4434
1325 East West Highway
Silver Spnng, MD 20910
301-713-0845
National Security Agency
Barbara Krupiarz
Project Manager, Pollution
Prevention Program
Environmental Service Division
National Security Agency, (APS- 13),
Room AT200
Department of Defense
9800 Savage Road
Fort Meade, MD 20755-6000
410-684-7305
23
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Postal Service
Bernie Denno
Environmental Specialist
U.S. Postal Service, Room 6830
475 L'Enfant Plaza, SW
Washington, DC 20260-2810
202-268-6014
Tennessee Valley Authority
Paul Schmierbach
Environmental Compliance Department
Tennessee Valley Authority
400 Summit Hill Drive
Knoxville, TN 37902
615-632-6644
Department of Transportation
Janet Krause
Environmental Engineer
Office of the Secretary
Department of Transportation
400 7th Street, SW
Washington, DC 20590
202-366-0038
Coast Guard
T. J. Granite, Environmental
Compliance and Restoration Branch
P2 and Recycling Coordinator
U.S. Coast Guard
USCG(G-ECV-IB)
2100 2nd Street, SW
Washington, DC 20593
202-267-1941
Federal Aviation Administration
Tom Halloway
Manager of Hazardous Materials
and Special Projects Staff
Federal Aviation Administration,
AEE-20
800 Independence Avenue, SW
Washington, DC 20591
202-267-8114
Department of the Treasury
William McGovem
Chief, Environmental Compliance
Division
Department of the Treasury
Treasury Annex
1500 Pennsylvania Avenue, NW
Washington, DC 20220
202-622-0043
Department of Veterans Affairs
John Staudt
Chief, Hazardous Materials
Management Division
Department of Veterans Affairs, 138C-4
810 Vermont Avenue, NW
Washington, DC 20420
202-233-7863
STATE POLLUTION
PREVENTION PROGRAMS
ALABAMA
Alabama Waste Reduction and
Technology Transfer (WRATT) Program
Daniel E. Cooper, Chief
Special Projects
Alabama Department of
Environmental Management
1751 Congressman William L.
Dickinson Drive
Montgomery, AL 36130
205-260-2779
ALASKA
Pollution Prevention Office
David Wigglesworth, Chief
Pollution Prevention Office
Alaska Department of Environmental
Conservation
PO Box O
Juneau, Alaska 99811 -1800
907-465-5275
Waste Reduction Assistance Program
(WRAP)
Kristine Benson
Alaska Health Project
1818 West Northern Lights Boulevard
Suite 103
Anchorage, AK 99517
907-276-2864
ARIZONA
Arizona Waste Minimization Program
Sandra Eberhardt, Manager
Pollution Prevention Unit
Arizona Department of
Environmental Quality
3033 North Central Avenue,
Room 558
Phoenix, AZ 85012
602-207-4210
ARKANSAS
Arkansas Pollution Prevention Program
RobertJ. Finn
Hazardous Waste Division
Arkansas Department of Pollution
Prevention and Ecology
PO Box 8913
Little Rock, AR 72219-8913
501-570-2861
CALIFORNIA
Department of Toxic Substances Control
Mr. Kim Wilheim
Department of Toxic Substances Control
Pollution Prevention, Public and
Regulatory Assistance Division
400 P Street
PO Box 806
Sacramento, CA 95812-0806
916-322-3670
Tony Eulo
Local Government Commission
909 12th Street
Suite 205
Sacramento, California 95814
916-448-1198
California Integrated Waste
Management Board
8800 Cal Center Dnve
Sacramento, California 95826
Recycling Hotline: 800-553-2962
General Public Information:
916-255-2289
COLORADO
Pollution Prevention and Waste
Reduction Program
Kate Kramer, Program Manager
Pollution Prevention Waste Reduction
Program
Colorado Department of Health
4300 Cherry Creek Drive South
Denver, CO 80220
303-692-3003
Michael Nemeck
Colorado Public Interest Research Group
(COPIRG)
1724 Gilpin Street
Denver, Colorado 80218
303-355-1861
24
Section III: Technical Assistance and Literature
-------
CONNECTICUT
Connecticut Technical Assistance
Program (CONNTAP)
Andrew Vecchio
Connecticut Technical Assistance
Program (ConnTAP)
Connecticut Hazardous Waste
Management Service
900 Asylum Avenue
Suite 360
Hartford, Connecticut 06105-1904
203-241-0777
Connecticut Department of
Environmental Protection
Liz Napier
Bureau of Waste Management
Connecticut Department of
Environmental Protection
165 Capitol Avenue
Hartford, Connecticut 06106
203-566-5217
DELAWARE
Delaware Pollution Prevention Program
Philip J. Cherry
Andrea K. Farrell
Pollution Prevention Program
Department of Natural Resources and
Environmental Control
PO BOX 1401
Kings Highway
Dover, DE 19903
302-739-5071/3822
Herb Allen
Department of Civil Engineering
University of Delaware
Newark, DE 19716
302-45 1-8522/8449
DISTRICT OF COLUMBIA
Office of Recycling
Evelyn Shields, Recycling Coordinator
D.C. Department of Public Works
65 K Street, NE
Washington, DC 20002
202-727-5887
George Nichols
Department of Environmental Programs
Council of Governments
777 North Capitol Street, NE
Suite 300
Washington, DC 20002-4201
202-962-3355
Kenneth Laden
Environmental Policy Division
D.C. Department of Public Works
2000 14th Street, NW
Washington, DC 20009
202-939-8115
Ms. Ferial Bishop, Administrator
Environmental Regulation
Administration
D.C. Department of Consumer and
Regulatory Affairs
2100 MLK Avenue, SE
Suite 203
Washington, DC 20020
202-404-1136
FLORIDA
Waste Reduction Assistance
Program (WRAP)
Janeth A. Campbell, Director
Waste Reduction Assistance Program
Florida Department of Environmental
Regulation
2600 Blair Stone Road
Tallahassee, Flonda 32399-2400
904-488-0300
GEORGIA
Georgia Multimedia Source Reduction
and Recycling Program
Susan Hendricks, Program Coordinator
Environmental Protection Division
Georgia Department of Natural
Resources
4244 International Parkway, Suite 104
Atlanta, GA 30334
404-362-2537
HAWAII
Hazardous Waste Minimization Program
Jane Dewell
Waste Minimization Coordinator
State of Hawaii Department of Health
Solid and Hazardous Waste Branch
Five Waterfront Plaza, Suite 250
500 Ala Moana Blvd.
Honolulu, HI 96813
808-586-4226
John Harder
Department of Health
Office of Solid Waste
5 Waterfront Place, Suite 250
500 Ala Moana Boulevard
Honolulu, HI 96813
808-586-4373
IDAHO
Division of Environmental Quality
Joy Palmer
Katie Sewell
Division of Environmental Quality
Idaho Department of Health and Welfare
1410 North Hilton Street
Boise, ID 83720-9000
208-334-5879
ILLINOIS
Illinois Hazardous Waste Research and
Information Center (HWRIC)
Dr. David Thomas, Director
Illinois Hazardous Waste Research
and Information Center
One East Hazelwood Drive
Champaign, IL 61820
217-333-8940
Office of Pollution Prevention
Mike Hayes
Illinois Environmental Protection Agency
Office of Pollution Prevention
2200 Churchill Road
PO Box 19276
Springfield, IL 62794-9276
217-785-0533
INDIANA
Office of Pollution Prevention and
Technical Assistance
Joanne Joice, Director
Charles Sullivan, Environmental
Manager
Office of Pollution Prevention and
Technical Assistance
Indiana Department of Environmental
Management
105 South Meridian Street
PO Box 6015
Indianapolis, IN 46225
317-232-8172
Indiana Pollution Prevention Program
Rick Bossingham, Coordinator
Jeff Burbrink, Agricultural Pollution
Prevention Coordinator
Environmental Management and
Education Program
2129 Civil Engineering Building
Purdue University
West Lafayette, IN 47907-1284
317-494-5038
25
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IOWA
Iowa Waste Reduction Center (IWRC)
John Konefes, Director
Kim Gunderson, Environmental Specialist
Iowa Waste Reduction Center
University of Northern Iowa
Cedar Falls, IA 50614-0185
319-273-2079
Waste Management Authority Division
Tom Blewett, Bureau Chief
Scott Cahail, Environmental Specialist
Waste Management Authority Division
Department of Natural Resources
Wallace State Office Building
Des Monies, IA 50319
515-281-8941
KANSAS
State Technical Action Plan (STAP)
Tom Gross, Bureau Chief
State Technical Action Plan
Kansas Department of Health and
Environment
Forbes Field, Building 740
Topeka, KS 66620
913-296-1603
Kansas State University RITTA Program
Lani Himegarner, Program Manager
Engineering Extension Programs
133 Ward Hall
Kansas State University
Manhattan, KS 66506-2508
913-532-6026
KENTUCKY
Kentucky Partners - State Waste
Reduction Center
Joyce St. Clair, Executive Director
Kentucky Partners - State Waste
Reduction Center
Ernst Hall, Room 312
University of Louisville
Louisville, KY 40292
502-588-7260
LOUISIANA
Louisiana Department of
Environmental Quality
Gary Johnson, Waste Minimization
Coordinator
Louisiana Department of
Environmental Quality
P.O. Box 82263
Baton Rouge, LA 70884-2263
504-765-0720
MAINE
Maine Waste Management Agency
Gayle Briggs
Maine Waste Management Agency
State House Station 154
Augusta, ME 04333
207-287-5300
MARYLAND
Waste Management Administration
James Francis
Hazardous Waste Program
Waste Management Administration
Maryland Department of the
Environment
2500 Broening Highway,
Building 40 .
Baltimore, MD 21224
410-631-3344
Maryland Environmental Services
George G. Perdikakis, Director
Maryland Environmental Services
2020 Industrial Drive
Annapolis, MD 21401
301-974-7281
Technical Extension Service
Travis Walton, Director
Technical Extension Service
Engineering Research Center
University of Maryland
College Park, MD 20742
301-454-1941
MASSACHUSETTS
Office of Technical Assistance for
Toxics Use Reduction
Barbara Kelley, Director
Richard Reibstein, Outreach Director
Massachusetts Department of
Environment
Office of Technical Assistance
100 Cambridge Street
Boston, MA 02202
617-727-3260
Toxics Use Reduction Institute
Jack Luskin
Director of Education and Outreach
Toxics Use Reduction Institute
University Avenue
Lowell, MA 01854
508-934-3262
MICHIGAN
Office of Waste Reduction Services
Nan Merrill, Manager
Office of Waste Reduction Services
Environmental Services Division
Michigan Departments of Commerce
and Natural Resources
116 West Allegan Street
PO Box 30004
Lansing, MI 48909-7504
517-335-1178
MINNESOTA
Minnesota Office of Waste Management
Kevin McDonald, Sr., Pollution
Prevention Planner
Minnesota Office of Waste Management
1350 Energy Lane
Suite 201
St. Paul, MN 55108-5272
612-649-5750/5744
Minnesota Pollution Control Agency
(MPCA)
Eric Kilberg, Pollution Prevention
Coordinator
Environmental Assessment Office
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155
612-296-8643
Minnesota Technical Assistance
Program (MNTAP)
Cindy McComas, Director
Minnesota Technical Assistance Program
Environmental Health School
of Public Health
University of Minnesota
1313 5th Street, SE, Suite 207
Minneapolis, MN 55414
612-627-455514646
MISSISSIPPI
Mississippi Waste Reduction/Waste
Minimization Program, Mississippi
Technical Assistance Program
(MISSTAP) and Mississippi Solid
Waste Reduction Assistance Program
(MSSWRAP)
Dr. Caroline Hill
Mississippi Technical Assistance
Program and Mississippi Solid Waste
Reduction Assistance
PO Drawer CN
26
Section III: Technical Assistance and Literature
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Mississippi State, MS 39762
601-325-8454
Thomas E. Whitten, Director
Waste Reduction/Waste Minimization
Program
Mississippi Department of
Environmental Quality
POBox 10385
Jackson, MS 39289-0385
601-961-5171
MISSOURI
Waste Management Program (WMP)
Becky Shannon, Pollution Prevention
Coordinator
Hazardous Waste Program
Division of Environmental Quality
Missouri Department of Natural
Resources
205 Jefferson Street
POBox 176
Jefferson City, MO 65102
314-751-3176
Environmental Improvement and
Energy Resources Authority
Steve Mahfood, Director
Tom Welch, Assistant for Planning
and Project Development
Environmental Improvement and
Energy Resources Authority
225 Madison Street
PO Box 744
Jefferson City, MO 65102
314-751-4919
MONTANA
Solid and Hazardous Waste Bureau
Dan Fraser
Water Quality Bureau Chief
Department of Health and
Environmental Sciences
Room A-206
Cogswell Building
Helena, MT 59620
406-444-2406
Jeff Jacobsen
Montana State University Extension
Service
807 Leon Johnson Hall
Bozeman, MT 59717-0312
406-994-5683
NEBRASKA
Hazardous Waste Section
Teri Swarts, Waste Minimization
Coordinator
Hazardous Waste Section
Nebraska Department of Environmental
Control
301 Centennial Mall South
PO Box 98922
Lincoln, NE 68509
402-471-4217
NEVADA
Business Environmental Program
Kevin Dick, Manager
Business Environmental Program
Nevada Small Business Development
Center
University of Nevada - Reno
Reno, NV 89557-0100
702-784-1717
Doug Martin
Bureau of Waste management
Division of Environmental Protection
123 West Nye Lane
Carson City, NV 89710
702-687-5872
Nevada Energy Conservation Program
Curtis Framel, Manager
Nevada Energy Conservation Program
Office of Community Services
Capitol Complex
201 South Fall Street
Carson City, NV 89710
702-885-4420
NEW JERSEY
New Jersey Pollution Prevention
Program
Jean Herb, Director
Office of Pollution Prevention
New Jersey Department of
Environmental Protection
CN-402
401 East State Street
Trenton, NJ 08625
609-777-0518
New Jersey Technical Assistance
Program (NJTAP)
Kevin Gashlin, Director
New Jersey Technical Assistance
Program
New Jersey Institute of Technology
Hazardous Substance Management
Research Center
Center for Environmental and
Engineering Sciences
323 Martin Luther King Boulevard
Newark, NJ 07102
201-596-5864
NEW YORK
Bureau of Pollution Prevention
John lanotti, Director
Bureau of Pollution Prevention
Division of Hazardous Substances
Regulation and the Division of
Solid Waste
New York State Department of
Environmental Conservation
50 Wolf Road
Albany, NY 12233-7253
518-457-7276
NORTH CAROLINA
Pollution Prevention Program
Gary Hunt, Director
Stephanie Richardson, Manager
Pollution Prevention Program
Office of Waste Reduction
North Carolina Department of
Environment, Health, and Natural
Resources
PO Box 27687
Raleigh, NC 27611-7687
919-571-4100
OHIO
Ohio Technology Transfer
Organization (OTTO)
Jeff Shick, State Coordinator
Jackie Rudolf
Ohio Technology Transfer Organization
Ohio Department of Development
77 South High Street, 26th Floor
Columbus, OH 43255-0330
614-644-4286
Ohio Environmental Protection Agency
Roger Hannahs
Michael W. Kelley
Anthony Sasson
Pollution Prevention Section
Division of Hazardous Waste
Management
Ohio Environmental Protection Agency
PO Box 1049
Columbus, OH 43266-0149
614-644-3969
27
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OKLAHOMA
Pollution Prevention Technical
Assistance Program
Chris Varga
Hazardous Waste Management
Service, 0205
Oklahoma State Department of Health
1000 Northeast 1 Oth Street
Oklahoma City,OK 73117-1299
405-271-7047
OREGON
Waste Reduction Assistance Program
(WRAP)
Roy W. Brewer, Manager
David Rozell, Pollution Prevention
Specialist
Phil Berry, Pollution Prevention
Specialist
Hazardous Waste Reduction and
Technical Assistance Program
Hazardous and Solid Waste Division
Oregon Department of Environmental
Quality
811 SW Sixth Avenue
Portland, OR 97204
503-229-6585
PENNSYLVANIA
Department of Environmental Resources
Meredith Hill
Assistant to Deputy Secretary
Office of Air and Waste Management
Pennsylvania Department of
Environmental Resources
PO Box 2063
Hamsburg, PA 17105-2063
717-772-2724
Center for Hazardous Materials Research
Roger Price
Center for Hazardous Materials Research
University of Pittsburgh Applied
Research Center
320 William Pit Way
Pittsburgh, PA 15238
412-826-5320
1-800-334-CHMR
Pennsylvania Technical Assistance
Program (PENNTAP)
Jack Gido, Director
PENNTAP
Penn State University
110 Barbara Building 11
810 North University Drive
University Park, PA 16802
814-865-0427
RHODEISLAND
Hazardous Waste Reduction Program
Richard Enander, Chief
Janet Keller
Office of Environmental Coordination
Rhode Island Department of
Environmental Management
83 Park Street
Providence, RI 02903-1037
401-277-3434
Eugene Pepper, Senior Environmental
Planner
Hazardous Waste Reduction Section
Office of Environmental Coordination
Rhode Island Department of
Environmental Management
83 Park Street
Providence, RI 02903
401-277-3434
SOUTH CAROLINA
Center for Waste Minimization
Ray Guerrein
Center for Waste Minimization
South Carolina Department of
Health and Environmental Control
2600 Bull Street
Columbia, SC 29201
802-734-4715
SOUTH DAKOTA
Waste Management Program
Wayne Houtcooper
Department of Environment and
Natural Resources
Joe Foss Building
523 E. Capitol Avenue
Pierre, SD 57501-3181
605-773-4216
TENNESSEE
Department of Health and Environment
Paul Evan Davis
Bureau of Environment
Tennessee Department of Health and
Environment
14th Floor, L & C Building
401 Church Street
Nashville, TN 37243-0455
615-741-3657
Waste Reduction Assessment and
Technology Transfer Training
Program (WRATT)
George Smelter, Director
Waste Reduction Assistance Program
CamMetcalf(Suite 606)
Center for Industrial Services
University ofTennessee
226 Capitol Boulevard Building
Nashville, TN 37219-1804
615-242-2456
Carroll Dugan, Section Manager
Waste Reduction and Management
Section
Tennessee Valley Authority
Mail Code HB 2G-C
311 Broad Street
Chattanooga, TN 37406
615-751-4574
TEXAS
Center for Hazardous and Toxic
Waste Studies
John R. Bradford, Director
Center for Hazardous and Toxic
Waste Studies
Texas Tech University
PO Box 4679
Lubbock, TX 79409-3121
806-742-1413
UTAH
Department of Environmental Quality
Sonja Wallace, Pollution Prevention
Co-Coordinator
Stephanie Bernkopf, Pollution
Prevention Co-Coordinator
Office of Executive Director
Utah Department of Environmental
Quality
168 North 1950 West Street
Salt Lake City, UT 84114-4810
801-536-4480
VERMONT
Pollution Prevention Program
Gary Gulka
Pollution Prevention Division
Vermont Department of
Environmental Conservation
103 South Main Street
Waterbury, VT 05676
802-244-8702
28
Section III: Technical Assistance and Literature
-------
Paul Maskowitz, Chief
Recycling and Resource
Conservation Section
Vermont Department of Environmental
Conservation
103 South Main Street
Waterbury, VT 05676
802-244-8702
VIRGINIA
Waste Minimization Program
Sharon Kenneally-Baxter, Director
Waste Minimization Program
Virginia Department of Waste
Management
Monroe Building, llth Floor
101N. 14th Street
Richmond, VA 23219
804-371-8716
WASHINGTON
Waste Reduction, Recycling
and Litter Control Program
Stan Springer
Joy St. Germain
Peggy Morgan
Waste Reduction, Recycling and
Litter Control Program
Washington Department of Ecology
Mail Stop PV-11
Olympia, WA 98504-8711
206-438-7541
WISCONSIN
Department of Natural Resources
Lynn Persson, Hazardous Waste
Reduction and Recycling Coordinator
Kate Cooper, Assistance Recycling
Coordinator
Bureau of Solid and Hazardous Waste
Management
Wisconsin Department of Natural
Resources
PO Box 7921 (SW/3)
Madison, WI 53707-7921
608-267-3763
WYOMING
Department of Environmental Quality
David Finley, Manager
Pat Gallagher, Senior
Environmental Analyst
Solid Waste Management Program
Wyoming Department of
Environmental Quality
122 West 25th Street
Herschler Building
Cheyenne, WY 82002
307-777-7752
WEST VIRGINIA
Pollution Prevention and Open Dump
Program (PPOD)
Richard Ferrell, Environmental Analyst
Waste Management Section
West Virginia Division of Natural
Resources
1356 Hansford Street
Charleston, WV 25301
304-558-4000
29
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ANNEX A: EXECUTIVE ORDER 12856
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EXECUTIVE ORDER
3— Executive Order 12856 of August 3, 1993
The President Federal Compliance With Right-to-Know Laws and Pollution
Prevention Requirements
WHEREAS, the Emergency Planning and Community Right-to-Know Act
of 1986 (42 U.S.C. 11001-11050) (EPCRA) established programs to provide the
public with important information on the hazardous and toxic chemicals in their
communities, and established emergency planning and notification requirements
to protect the public in the event of a release of extremely hazardous substances;
WHEREAS, the Federal Government should be a good neighbor to local communi-
ties by becoming a leader in providing information to the public concerning toxic
and hazardous chemicals and extremely hazardous substances at Federal facilities,
and in planning for and preventing harm to the public through the pianned or
unplanned releases of chemicals;
WHEREAS, the Pollution Prevention Act of 1990 (42 U.S.C. 13101-13109) (PPA)
established that it is the national policy of the United States that whenever feasible,
pollution should be prevented or reduced at the source, that pollution that cannot
be prevented should be recycled in an environmentaiiy safe manner; that pollution
that cannot be prevented or recycled should be treated in an environmentaiiy safe
manner; and that disposal or other release into the environment should be em-
ployed only as a last resort and should be conducted in an environmentaiiy safe
manner;
WHEREAS, the PPA required the Administrator of the Environmental Protection
Agency (EPA) to promote source reduction practices in other agencies;
WHEREAS, the Federal Government should become a leader in the field of pollu-
tion prevention through the management of its facilities, its acquisition practices,
and in supporting the development of innovative pollution prevention programs
and technologies;
WHEREAS, the environmental, energy, and economic benefits of energy and wa-
ter use reductions are very significant; the scope of innovative pollution prevention
programs must be broad to adequately address the highest-risk environmental
problems and to take full advantage of technological opportunities in sectors other
than industrial manufacturing; the Energy Policy Act of 1992 (Public Law 102-486
of October 24, 1992) requires the Secretary of Energy to work with other Federal
agencies to significantly reduce the use of energy and reduce the related environ-
mental Impacts by promoting use of energy efficiency and renewable energy tech-
nologies; and
WHEREAS, as the largest single consumer in the Nation, the Federal Government
has the opportunity to realize significant economic as weii as environmental ben-
efits of pollution prevention;
AND IN ORDER TO:
Ensure that all Federal agencies conduct their facility management and acquisition
activities so that, to the maximum extent practicable, the quantity of toxic chemi-
cals entering any wastestream, including any releases to the environment, is re-
duced as expeditiously as possible through source reduction; that waste that is
generated is recycled to the maximum extent practicable; and that any wastes
remaining are stored, treated or disposed of in a manner protective of public
health and the environment;
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41982 Federal Register / Vol. 58, No. 150 / Friday, August 6, 1993 / Presidential Documents
Require Federal agencies to report in a public manner toxic chemicals entering
any wastestream from their facilities, including any releases to the environment,
and to improve local emergency planning, response, and accident notification; and
Help encourage markets for clean technologies and safe alternatives to extremeiy
hazardous substances or toxic chemicals through revisions to specifications and
standards, the acquisition and procurement process, and the testing of innovative
pollution prevention technologies at Federal facilities or in acquisitions;
NOW THEREFORE, by the authority vested in me as President by the Constitu-
tion and the laws of the United Slates of America, including the EPCRA, the PPA,
and section 301 of title 5, United States Code, it is hereby ordered as follows:
Section 1. Applicability.
1-101. As delineated below, the head of each Federal agency is responsible for
ensuring that all necessary actions are taken for the prevention of pollution with
respect to that agency's activities and facilities, and for ensuring that agency's
compliance with pollution prevention and emergency planning and community
right-to-know provisions established pursuant to all implementing regulations is-
sued pursuant to EPCRA and PPA.
1 102. Except as otherwise noted, this order is applicable to all Federal agencies
that either own or operate a "facility" as that term is defined in section 329(4) of
EPCRA, if such facility meets the threshold requirements set forth in EPCRA for
compliance as modified by section 3-304(b) of this order ("covered facilities").
Except as provided in section 1-103 and section 1-104 below, each Federal agency
must apply all of the provisions of this order to each of its covered facilities,
including those facilities which are subject, independent of this order, to the
provisions of EPCRA and PPA (e.g., certain Government-owned/contractor-oper-
ated facilities (GOCO's), for chemicals meeting EPCRA thresholds). This order
does not apply to Federal agency facilities outside the customs territory of the
United States, such as United States diplomatic and consular missions abroad.
1-103. Nothing in this order alters the obligations which GOCO's and Government
corporation facilities have under EPCRA and PPA independent of this order or
subjects such facilities to EPCRA or PPA if they are otherwise excluded. However,
consistent with section 1-104 below, each Federal agency shall include the releases
and transfers from all such facilities when meeting all of the Federal agency's
responsibilities under this order.
1-104. To facilitate compliance with this order, each Federal agency shall provide,
in all future contracts between the agency and its relevant contractors, for the
contractor to supply to the Federal agency all information the Federal agency
deems necessary for it to comply with this order, in addition, to the extent that
compliance with this order is made more difficult due to lack of information from
existing contractors, Federal agencies shall take practical steps to obtain the infor-
mation needed to comply with this order from such contractors.
Sec. 2-2. Definitions.
2-201. All definitions found in EPCRA and PPA and implementing regulations are
incorporated in this order by reference, with the following exception: for the
purposes of this order, the term "person", as defined in section 329(7) of EPCRA,
also includes Federal agencies.
2-202. Federal agency means an Executive agency, as defined in 5 U.S.C. 105. For
the purpose of this order, military departments, as defined in 5 U.S.C 102, are
covered under the auspices of the Department of Defense.
2-203. Pollution Prevention means "source reduction," as defined in the PPA, and
other practices that reduce or eliminate the creation of pollutants through: (a)
increased efficiency in the use of raw materials, energy, water, or other resources;
or (b) protection of natural resources by conservation.
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Federal Register / Vol. 58, No. 150 / Friday, August 6, 1993 / Presidential Documents 41983
2-204. GOCO means a Government-owned/contractor-operated facility which is
owned by the Federal Government but all or portions of which are operated by
private contractors.
2-205. Administrator means the Administrator of the EPA.
2-206. Toxic Chemical means a substance on the list described in section 313(c) of
EPCRA.
2-207. Toxic Pollutants. For the purposes of section 3-302(a) of this order, the
term "toxic pollutants" shall include, but is not necessarily limited to, those
chemicals at a Federal facility subject to the provisions of section 313 of EPCRA
as of December 1, 1993. Federal agencies also may choose to include releases and
transfers of other chemicals, such as "extremely hazardous chemicals" as de-
fined in section 329(3) of EPCRA, hazardous wastes as defined under the Re-
source Conservation and Recovery Act of 1976 (42 U.S.C 6901-6986) (RCRA), or
hazardous air pollutants under the Clean Air Act Amendments (42 U.S.C. 7403-
7626); however, for the purposes of establishing the agency's baseline under 3-
302(c), such "other chemicals" are in addition to (not instead of) the section 313
chemicals. The term "toxic pollutants" does not include hazardous waste subject
to remedial action generated prior to the date of this order.
Sec. 3-3. Implementation.
3-301. Federal Agency Strategy. Within 12 months of the date of this order, the
head of each Federal agency must develop a written pollution prevention strat-
egy to achieve the requirements specified in sections 3-302 through 3-305 of this
order for that agency. A copy thereof shall be provided to the Administrator.
Federal agencies are encouraged to involve the public in developing the required
strategies under this order and in monitoring their subsequent progress in meet-
ing the requirements of this order. The strategy shall include, but shall not be
limited to, the following elements:
(a) A pollution prevention policy statement, developed by each Federal agency,
designating principal responsibilities for development, implementation, and evalu-
ation of the strategy. The statement shall reflect the Federal agency's commit-
ment to incorporate pollution prevention through source reduction in facility
management and acquisition, and it shall identify an individual responsible for
coordinating the Federal agency's efforts in this area.
(b) A commitment to utilize pollution prevention through source reduction,
where practicable, as the primary means of achieving and maintaining compli-
ance with all applicable Federal, State, and local environmental requirements.
3-302. Toxic Chrmical Reduction Goals, (a) The head of each Federal agency
subject to this order shall ensure that the agency develops voluntary goals to
reduce the ageno'stotal releases of toxic chemicals to the environment and off-
site transfers of>uch toxic chemicals for treatment and disposal from facilities
covered by this order by 50 percent by December 31, 1999. To the maximum
extent practicable, such reductions shall be achieved by implementation of source
reduction practlc*v
(b) The baseline for measuring reductions for purposes of achieving the 50
percent reduction goal for each Federal agency shall be the first year in which
releases of toxic chemicals to the environment and off-site transfers of such
chemicals for treatment and disposal are publicly reported. The baseline amount
as to which the 50 percent reduction goal applies shall be the aggregate amount
of toxic chemicals reported in the baseline year for all of that Federal agency's
facilities meeting the threshold applicability requirements set forth in section 1-
102 of this order. In no event shall the baseline be later than the 1994 reporting
year.
(c) Alternatively, a Federal agency may choose to achieve a 50 percent reduc-
tion goal for toxic pollutants. In such event, the Federal agency shall delineate
the scope of its reduction program in the written pollution prevention strategy
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41984 Federal Register/Vol. 58, No. 150 / Friday, August 6, 1993 / Presidential Documents
that is required by section 3-301 of this order. The baseline for measuring reduc-
tions for purposes of achieving the 50 percent reduction requirement for each
Federal agency shall be the first year in which releases of toxic pollutants to the
environment and off-site transfers of such chemicals for treatment and disposal are
publicly reported for each of that Federal agency's facilities encompassed by
section 3-301. In no event shall the baseline year be later than the 1994 reporting
year. The baseline amount as to which the 50 percent reduction goai applies shall
be the aggregate amount of toxic pollutants reported by the agency in the baseline
year. For any toxic pollutants included by the agency in determining its baseline
under this section, in addition to toxic chemicals under EPCRA, the agency shall
report on such toxic pollutants annually under the provisions of section 3-304 of
this order, if practicable, or through an agency report that is made available to the
public.
(d) The head of each Federal agency shall ensure that each of its covered facilities
develops a written pollution prevention plan no later than the end of 1995, which
sets forth the facility 's contribution to the goal established in section 3-302(a) of
this order. Federal agencies shall conduct assessments of their facilities as neces-
sary to ensure development of such plans and of the facilities' pollution prevention
programs.
3-303. Acquisition and Procurement Goals, (a) Each Federal agency shall establish a
plan and goals for eliminating or reducing the unnecessary acquisition by that
agency of products containing extremeiy hazardous substances or toxic chemicals.
Similarly, each Federal agency shall establish a plan and goal for voluntarily
reducing its' own manufacturing, processing, and use of extremely hazardous
substances and toxic chemicals. Priorities shall be developed by Federal agencies,
in coordination with EPA, for implementing this section.
(b) Within 24 months of the date of this order, the Department of Defense (DOD)
and the General Services Administration (GSA), and other agencies, as appropri-
ate, shall review their agency's standardized documents, including specifications
and standards, and identify opportunities to eliminate or reduce the use by their
agency of extremely hazardous substances and toxic chemicals, consistent with the
safety and reliability requirements of their agency mission. The EPA shall assist
agencies in meeting the requirements of this section, including identifying substi-
tutes and setting priorities for these reviews. By 1999, DOD, GSA and other
affected agencies shall make all appropriate revisions to these specifications and
standards.
(c) Any revisions to the Federal Acquisition Regulation (FAR) necessary to
implement this order shall be made within 24 months of the date of this order.
(d) Federal agencies are encouraged to develop and test innovative pollution
prevention technologies at their facilities in order to encourage the development of
strong markets for such technologies. Partnerships should be encouraged between
industry, Federal agencies, Government laboratories, academia, and others to
assess and deploy innovative environmental technologies for domestic use and for
markets abroad.
3-304. Toxics Release Inventory/Pollution Prevention Act Reporting, (a) The head of
each Federal agency shall comply with the provisions set forth in section 313 of
EPCRA, section 6607 of PPA, all implementing regulations, and future amend-
ments to these authorities, in light of applicable guidance as provided by EPA.
(b) The head of each Federal agency shall comply with these provisions without
regard to the Standard industrial Classification (SIC) delineations that apply to
the Federal agency's facilities, and such reports shall be for all releases, transfers,
and wastes at such Federal agency's facility without regard to the SIC code of the
activity leading to the release, transfer, or waste. All other existing statutory or
regulatory imitations or exemptions on the application of EPCRA section 313 shall
apply to the reporting requirements set forth in section 3-304(a) of this order.
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Federal Register / Vol. 58, No. 150 / Friday, August 6, 1993 / Presidential Documents 41985
(c) The first year of compliance shall be no later than for the 1994 calendar year
with reports due on or before July 1,1995
3-305. Emergency Planning and Community Right-to-Know Reporting Responsibilities.
The head of each Federal agency shall comply with the provisions set forth in sections
301 through 312 of EPCRA, all implementing regulations, and future amendments to
these authorities in light of any applicable guidance as provided by EPA. Effective
dates for compliance shall be: (a) With respect to the provisions of section 302 of
EPCRA emergency planning notification shall be made no later than 7 months after
the date of this order.
(b) With respect to the provisions of section 303 of EPCRA all information neces-
sary for the applicable Local Emergency Planning Committee (LEPC's) to prepare or
revise local Emergency Response Plans shall be provided no later than 1 year after the
date of this order.
(c) To the extent that a facility is required to maintain Material Safety Data Sheets
under any provisions of law or Executive order, information required under section
311 of EPCRA shall be submitted no later than 1 year after the date of this order, and
the first year of compliance with section 312 shall be no later than the 1994 calendar
year, with reports due on or before March 1, 1995.
(d) The provisions of section 304 of EPCRA shall be effective beginning January 1,
1994.
(e) These compliance dates are not intended to delay implementation of earlier
timetables already agreed to by Federal agencies and are inapplicable to the extent
they interfere with those timetables.
Sec. 4-4. Agency Coordination.
4-401. By February 1, 1994, the Administrator shall convene an interagency Task
Force composed of the Administrator, the Secretaries of Commerce, Defense, and
Energy, the Administrator of General Services, the Administrator of the Office of
Procurement Policy in the Office of Management and Budget, and such other agency
officials as deemed appropriate based upon lists of potential participants submitted to
the Administrator pursuant to this section by the agency head. Each agency head may
designate other senior agency officials to act in his/her stead, where appropriate. The
Task Force will assist the agency heads in the implementation of the activities re-
quired under this order.
4-402. Federal agencies subject to the requirements of this order shall submit annual
progress reports to the Administrator beginning on October 1, 1995. These reports all
include a description of the progress that the agency has made in complying with all
aspects of this order, including the pollution reductions requirements. This reporting
requirement shall expire after the report due on October 1, 2001.
4-403. Technical Advice. Upon request and to the extent practicable, the Administra-
tor shall provide technical advice and assistance to Federal agencies in order to foster
full compliance with this order. In addition, to the extent practicable, all Federal
agencies subject to this order shall provide technical assistance, if requested, to
LEPC's in their development of emergency response plans and in fulfillment of their
community right-to-know and risk reduction responsibilities.
4-404. Federal agencies shall place high priority on obtaining funding and resources
needed for implementing all aspects of this order, including the pollution prevention
strategies, plans, and assessments required by this order, by identifying, requesting,
and allocating funds through line-item or direct funding requests. Federal agencies
shall make such requests as required in the Federal Agency Pollution Prevention and
Abatement Planning Process and through agency budget requests as outlined in
Office of Management and Budget (OMB) Circulars A-106 and A-n, respectively.
Federal agencies should apply to the maximum extent practicable, a life cycle analysis
and total cost accounting principles to all projects needed to meet the requirements of
this order.
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41986 Federal Register / Vol. 58, No. 150 / Friday, August 6, 1993 / Presidential Documents
4-405. Federal Government Environmental/Challenge Program. The Adminis-
trator shall establish a "Federal Government Environmental Challenge Pro-
gram" to recognize outstanding environmental management performance in
Federal agencies and facilities. The program shall consist of two components
that challenge Federal agencies; (a) to agree to a code of environmental prin-
ciples to be developed by EPA, in cooperation with other agencies, that empha-
sizes pollution prevention, sustainable development and state of-the-art environ-
mental management programs, and (b) to submit applications to EPA for indi-
vidual Federal agency facilities for recognition as "Modei Installations." The
program shall aiso include a means for recognizing individual Federal employ -
ees who demonstrate outstanding leadership in pollution prevention.
Sec 5-5. Compliance.
5-501. By December 31,1993, the head of each Federal agency shall provide the
Administrator with a preliminary list of facilities that potentially meet the
requirements for reporting under the threshold provisions of EPCRA, PPA, and
this order.
5-502. The head of each Federal agency is responsible for ensuring that such
agency take all necessary actions to prevent pollution in accordance with this
order, and for that agency's compliance with the provisions of EPCRA and PPA.
Compliance with EPCRA and PPA means compliance with the same substantive,
procedural, and other statutory and regulatory requirements that would apply
to a private person. Nothing in this order shall be construed as making the
provisions of sections 325 and 326 of EPCRA applicable to any Federal agency
or facility, except to the extent that such Federal agency or facility would
independently be subject to such provisions. EPA shall consult with Federal
agencies, if requested, to determine the applicability of this order to particular
agency facilities.
5-503. Each Federal agency subject to this order shall conduct internal reviews
and audits, and take such other steps, as may be necessary to monitor compli-
ance with sections 3-304 and 3-305 of this order.
5-504. The Administrator, in consultation with the heads of Federal agencies,
may conduct such reviews and inspections as may be necessary to monitor
compliance with sections 3-304 and 3-305 of this order. Except as excluded
under section 6-601 of this order, all Federal agencies are encouraged to cooper-
ate fully with the efforts of the Administrator to ensure compliance with sections
3-304 and 3-305 of this order.
5-505. Federal agencies are further encouraged to comply with all state and local
right-to-know and pollution prevention requirements to the extent that compli-
ance with such laws and requirements is not otherwise already mandated.
5-506. Whenever the Administrator notifies a Federal agency that it is not in
compliance with an applicable provision of this order, the Federal agency shall
achieve compliance as promptly as is practicable.
5-507. The EPA shall report annually to tho President on Federal agency compli-
ance with the provisions of section 3-304 of this order.
5-508. To the extent permitted by law and unless such documentation is withheld
pursuant to section 6-601 of this order, the public shall be afforded ready access
to all strategies, plans, and reports required to be prepared by Federal agencies
under this order by the agency preparing the strategy, plan, or report. When the
reports are submitted to EPA, EPA shall compile the strategies, plans, and
reports and make them publicly available as well. Federal agencies are encour-
aged to provide such strategies, plans, and reports to the State and local authori-
ties where their facilities are located for an additional point of access to the
public.
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Federal Register / VoK 58, No. 150 / Friday, August 6, 1993 / Presidential Documents 41987
Sec. 6-6. Exemption.
6-601. In the interest of national security, the head of a Federal agency may request
from the President an exemption from complying with the provisions of any or all
aspects of this order for particular Federal agency facilities, provided that the proce-
dures set forth in section 1200(1) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended (42 U.S.C. 9620(])(1)), are
followed. To the maximum extent practicable, and without compromising national
security, all Federal agencies shall strive to comply with the purposes, goals, and
implementation steps set forth in this order.
Sec. 7-7. Genera! Provisions.
7-701. Nothing in this order shall create any right or benefit, substantive or proce-
dural, enforceable by a party against the United States, its agencies or instrumentali-
ties, its officers or employees, or any other person.
[FR Doc/ 93-19069
Filed 8-4-93; 4:37 pm]
Billing code 3195 -01-P
THE WHITE HOUSE,
August 3, 1993.
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