United States
Environmental Protection
Agency
An Organizational Guide to
Pollution Prevention
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EPA/625/R-01/003
August 2001
An Organizational Guide to Pollution Prevention
U.S. Environmental Protection Agency
Office of Research and Development
National Risk Management Research Laboratory
Center for Environmental Research Information
Cincinnati, Ohio
80% Recycled/Recyclable
Printed with vegetable-based ink on
paper that contains a minimum of
50% post-consumer fiber content
processed chlorine free
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NOTICE
The U.S. Environmental Protection Agency through its Office of Research and Development funded
and managed the research described here under Contract #68-C7-0011, Work Assignment #3-20, to
Science Applications International Corporation. It has been subjected to the Agency's peer and adminis-
trative review and has been approved for publication as an EPA document. Mention of trade names or
commercial products does not constitute endorsement or recommendation for use.
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FOREWORD
The U.S. Environmental Protection Agency is charged by Congress with protecting the Nation's land,
air, and water resources. Under a mandate of national environmental laws, the Agency strives to formulate
and implement actions leading to a compatible balance between human activities and the ability of natural
systems to support and nurture life. To meet this mandate, EPA's research program is providing data and
technical support for solving environmental problems today and building a science knowledge base nec-
essary to manage our ecological resources wisely, understand how pollutants affect our health, and pre-
vent or reduce environmental risks in the future.
The National Risk Management Research Laboratory (NRMRL) is the Agency's center for investiga-
tion of technological and management approaches for preventing and reducing risks from pollution that
threaten human health and the environment. The focus of the Laboratory's research program is on meth-
ods and their cost-effectiveness for prevention and control of pollution to air, land, water, and subsurface
resources; protection of water quality in public water systems; remediation of contaminated sites, sedi-
ments and ground water; prevention and control of indoor air pollution; and restoration of ecosystems.
NRMRL collaborates with both public and private sector partners to foster technologies that reduce the
cost of compliance and to anticipate emerging problems. NRMRL's research provides solutions to envi-
ronmental problems by: developing and promoting technologies that protect and improve the environment;
advancing scientific and engineering information to support regulatory and policy decisions; and providing
the technical support and information transfer to ensure implementation of environmental regulations and
strategies at the national, state, and community levels.
This publication has been produced as part of the Laboratory's strategic long-term research plan. It is
published and made available by EPA's Office of Research and Development to assist the user commu-
nity and to link researchers with their clients.
E. Timothy Oppelt, Director
National Risk Management Research Laboratory
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ACKNOWLEDGMENTS
This Guide was prepared under the direction and coordination of Emma Lou George of the U.S. Envi-
ronmental Protection Agency (US EPA), Office of Research and Development, National Risk Management
Research Laboratory, Technology Transfer and Support Division, Technology Transfer Branch, Cincinnati,
Ohio.
Science Applications International Corporation (SAIC) compiled and prepared the information used for
this Guide under the management of Lisa K. Kulujian. The authors were Dr. Robert B. Pojasek, Pojasek &
Associates, and Cam Metcalf, Executive Director, Kentucky Pollution Prevention Center. Custom Editorial
Productions (CEP) of Cincinnati, Ohio, prepared the final document for publication.
The seeds for this document were planted by a Focus Group comprised of invited pollution prevention
practitioners from US EPA, Regional and State programs, industry, and academia. This Focus Group was
conducted in Cincinnati, Ohio, in conjunction with the National Pollution Prevention Roundtable in the
Spring of 1998. It was further shaped by an Engineering Conference conducted in Crested Butte, Colo-
rado, in the Fall of 1998. The final draft of this Guide was distributed to more that two hundred pollution
prevention practitioners. The following people (in alphabetical order) spent valuable time reviewing and
commenting on this publication, providing significant input that helped the authors in making it a more
complete and accurate informational Guide:
M. Gavin Adams, Pollution Prevention Program, AL Department of Environmental Management (ADEM)
Gary E. Baker, QEP, Battelle
Martine Dumais, National Office of Pollution Prevention, Environment Canada
ArtGillen, Senior Associate, First Environment, Inc.
Robert Lundquist, MOEA / MnTAP
Sandi Moser, National Office of Pollution Prevention, Environment Canada
Margaret Nover, Pollution Prevention Manager, City of Portland
Lynnann H. Paris, Chief, Technology Transfer Branch, TTSD, NRMRL, ORD, US EPA
Timothy J. Piero, Kentucky Pollution Prevention Center
Pollution Prevention Division, Office of Prevention, Pesticides and Toxic Substances, US EPA
John Shoaff, US EPA, Standards & International Affairs, Office of Prevention, Pesticides and Toxic
Substances
MarkSnyder, MOEA/MnTAP
TP3 Staff, Division of Environment and Conservation, TN Department of Environment and Conserva-
tion (Cynthia Rohrbach, David Borowski, Karen Grubbs)
Pete and Lynnann H. Paris (Chief, Technology Transfer Branch) provided the scenic picture from
Maine that has been used for the cover art of the Guide and the companion CD-ROM.
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ABSTRACT
This Pollution Prevention (P2) Guide provides information to help organizations get P2 programs
started or to re-evaluate existing P2 programs. It presents an alternative method for working on P2 projects
and four approaches to implementing a P2 program in an organization. This Guide was not written to
provide a "one-size-fits-all" formula for starting or improving a P2 Program. The intention is to spark some
ideas and provide tools that can be used to successfully complete an organization's P2 mission.
Also, the Guide is not intended to be an exhaustive review of case studies and company examples. It
does not include information on state P2 planning requirements. In order to keep this document a reason-
able length, these examples have been cited in the references section, and supplemental information is
provided on the CD-ROM that accompanies this Guide. There are many U.S. Environmental Protection
Agency (EPA) programs that support the practice of P2, including Environmental Accounting Project,
Design for Environment, P2 Resource Exchange, Environmentally Preferable Purchasing, Sustainable
Industry Project, Performance Track Program, and other initiatives across the Agency. Internet links to
these programs and other information are provided on the CD-ROM.
An Organizational Guide to Pollution Prevention is organized into three basic sections:
1. Basic P2 Concepts and Tools (Chapters 1-4)
2. P2 Program Implementation Approaches (Chapters 5-8)
3. Companion CD-ROM
Introduction to P2, Getting
Started, P2 Program Elements,
and P2 Tools
Traditional Approach, EMS
Approach, Quality Approach, and
Finding Your Own Way to
Implement P2
Supporting P2 Information
The EPA acknowledges the efforts of the principal authors of this Guide-Dr. Robert Pojasek (Presi-
dent, Pojasek& Associates) and Mr. Cam Metcalf (Executive Director, Kentucky Pollution Prevention Cen-
ter). This Guide was prepared in fulfillment of Contract Number 68-C7-0011, Work Assignment #3-20, by
Science Applications International Corporation, under the sponsorship of the EPA. Ms. Emma Lou George
was the EPA Project Officer.
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ACRONYMS
ACC = American Chemistry Council
BAT = best available technology
BMP = best management practice
CSI = Common Sense Initiative
DfE = Design for Environment
EHS = environment, health, and safety
EMAS = eco-management and audit scheme
EAR = Environmental Accounting Project
EMP = environmental management program
EMS = environmental management system
EPA = Environmental Protection Agency
EPP = Environmentally Preferable Purchasing
FDA = Food and Drug Administration
ISO = International Organization for Standardization
JIT = just-in-time
MSDS = material safety data sheet
MSWG = Multi-State Working Group
NGO = non-government organization
OSHA = Occupational Safety and Health Administration
P2 = pollution prevention
P2Rx = P2 Resource Exchange
PCB = polychlorinated biphenyl
PSM = process safety management
QA/QC = quality assurance/quality control
SGP = Strategic Goals Program
SOP = standard operating procedure
TQM = total quality management
VOC = volatile organic chemical
WBCSD = World Business Council for Sustainable Development
XL = excellence and Leadership
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CONTENTS
Executive Summary 1
Chapter 1: Introduction 9
Evolution of Pollution Prevention (P2) 9
Benefits of P2 11
Impediments to P2 Use 13
P2 in Steps 15
Organization of This Guide 18
Chapter 2: Getting Started 21
How to Define P2 21
Sustainable Development 23
Integrating the New P2 Program into Core Business Practices 24
Who Should Implement P2? 26
When Will You Begin? 27
Lessons Learned from Past P2 Programs 27
Dealing with Change 28
Chapter 3: P2 Program Elements 31
P2 Program Planning 31
Core Values 35
Selecting Program Elements 40
Lessons Learned 46
Chapter 4: P2 Tools 49
Using P2 Tools 49
Systems Approach Tools 49
Checklists 65
Lessons Learned 66
Chapter 5: Traditional Approach to P2 Implementation 69
Introduction 69
Establishing a P2 Program 70
Writing the P2 Program Plan 71
P2 Program Implementation 71
Maintaining the P2 Program 73
Combining the Traditional Approach with the Systems Approach 74
Approaches for Very Small Organizations 75
Other Implementation Approaches 77
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Chapter 6: EMS Approach to P2 Implementation 79
Introduction 79
Getting Started 80
Environmental Policy, Management Commitment, and Scope of the EMS 83
EMS Planning 85
EMS Implementation 91
EMS Monitoring and Measurement 94
Lessons Learned 96
Chapter 7: Using a Quality Model to Implement P2 103
Introduction 103
Seven Quality Model Criteria 104
The 11 Quality Model Guiding Principles 108
Five-step Process to Improve Your P2 Plan 114
Using the Quality Model to Implement P2 120
Chapter 8: Finding Your Own Way to Implement P2 123
Introduction 123
Extent of Planning 123
Leadership 126
Setting P2 Goals 128
Focus on Results 128
Information and Analysis 129
Process Management 130
Employee Participation 131
Focus on Interested Parties 132
Guiding Principles 133
P2 Program Elements 134
Now It's Your Turn 135
Index
137
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EXECUTIVE SUMMARY
An Organizational Guide to Pollution Prevention provides information to help organizations get P2
programs started or to re-evaluate existing P2 programs. It presents an alternative method for working on
P2 projects and four approaches to implementing a P2 program in an organization. This Guide was not
written to provide a "one-size-fits-all" formula for starting or improving a P2 Program. The intention is to
spark some ideas and provide tools that can be used to successfully complete an organization's P2
mission.
Also, the Guide is not intended to be an exhaustive review of case studies and company examples. It
does not include information on state P2 planning requirements. In order to keep this document a reason-
able length, these examples have been cited in the references section, and supplemental information is
provided on the CD-ROM that accompanies this Guide. There are many U.S. Environmental Protection
Agency (EPA) programs that support the practice of P2, including Environmental Accounting Project,
Design for Environment, P2 Resource Exchange, Environmentally Preferable Purchasing, Sustainable
Industry Project, Performance Track Program, and other initiatives across the Agency. Internet links to
these programs and other information are provided on the CD-ROM.
An Organizational Guide to Pollution Prevention is organized into three basic sections:
1. Basic P2 Concepts and Tools (Chapters 1-4) Introduction to P2, Getting
Started, P2 Program Elements,
and P2 Tools
2. P2 Program Implementation Approaches (Chapters 5-8) Traditional Approach, EMS
Approach, Quality Approach, and
Finding Your Own Way to
Implement P2
3. Companion CD-ROM Supporting P2 Information
The EPA acknowledges the efforts of the principal authors of this Guide-Dr. Robert Pojasek (Presi-
dent, Pojasek & Associates) and Mr. Cam Metcalf (Executive Director, Kentucky Pollution Prevention Cen-
ter). This Guide was prepared in fulfillment of Contract Number 68-C7-0011, Work Assignment #3-20, by
Science Applications International Corporation, under the sponsorship of the EPA. Ms. Emma Lou George
was the EPA Project Officer. Ms. Lisa Kulujian served as the SAIC Project Manager.
E.1 Introduction to P2
P2 has evolved substantially in its first decade. In 1988, the EPA published the Waste Minimization
Opportunity Assessment Manual (EPA/625/7-88/003). This publication was revised and reissued in 1992
as the Facility Pollution Prevention Guide (EPA/600/R-92-088). Large numbers of these publications were
distributed in the United States and internationally, and the information was well received. These publica-
tions have been included on the CD-ROM.
P2 programs provide many benefits to the organizations that use them. These include:
Executive Summary
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Reduced operating costs
Improved worker safety
Reduced compliance costs
Increased productivity
Increased environmental protection
Reduced exposure to future liability costs
Continual improvement
Resource conservation
Enhanced public image
There are a number of impediments that P2 programs must address. These include:
Capital requirements
Specifications
Regulatory issues
Product quality issues
Customers' acceptance
Immediate production concerns
Organization image concerns
Available time/technical expertise
A five-step model is presented showing an alternative approach using the P2 tools discussed later in
this Guide (Chapter 4). This is contrasted to the traditional approach to P2.
E.2 Getting Started With P2
Chapter 2 provides information on getting started with the P2 program process. First, set the bound-
aries around the program by deciding how P2 will be defined. Definitions from the EPA, United Nations
Environment Program, and the World Business Council for Sustainable Development are presented. The
user can choose to add elements from cleaner production and eco-efficiency to create a unique P2 defini-
tion that is broader than EPA's definition.
It is possible to use the P2 program to help an organization attain a goal of sustainable development.
In addition, it is possible to integrate P2 into core business practices like six sigma, zero waste, and other
company programs such as:
Qnvironmental management systems (EMS)
uality management initiatives
Preventive maintenance
Health and safety programs
Insurance/risk management
Although a commitment to the P2 program should begin with management (i.e., top-down approach),
line employees can often suggest valuable improvements in operations and procedures (i.e., bottom-up
approach). The P2 tools presented in this Guide are well suited for encouraging employee participation as
well as management recognition.
Executive Summary
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There is a substantial body of literature that describes, analyzes, and evaluates P2 efforts in the United
States and internationally. It is clear that, like quality, P2 is a mindset that needs to permeate into the culture
of the organization. Some have said that P2 is a way of life, not a new program. P2 requires many changes
in behavior that cannot be simply demanded. Empowering employee teams to fully implement the new P2
behaviors is central to successful change management.
E.3 P2 Program Elements
P2 program planning should begin with the preparation of a vision statement, a mission statement,
and a statement of goals. If your organization already has formal statements, it is important to align the P2
program with these statements. These statements and goals will help provide a good foundation for the P2
plan that your organization develops. Next, it is important to see how the P2 program aligns with the
organization's guiding principles (also known as the core values). These items will help ensure that the
program is understood and compatible with other initiatives in the organization.
The EPA has found that P2 programs often have similar program elements. They have published in
the Federal Register six important elements that would be found in many programs of this nature. These
elements include the following:
1.
2.
3.
4.
5.
6.
Provide top management support
Characterize the process
Perform periodic assessments
Maintain a cost allocation system
Encourage technology transfer
Conduct program evaluations
There may be other elements that can be included in the organization's P2 program. One good source
is the American Chemistry Council's Responsible Care® Program's P2 Code. In addition, the organization
must be certain to include the planning requirements that may be specified in its state environmental
regulations.
To be truly successful, P2 requires a systematic, integrated, consistent, and organization-wide ap-
proach. This approach can be achieved through comprehensive P2 planning. Although you can learn from
others' P2 success stories, real P2 success comes from the persistent application of the P2 philosophy
and guiding principles in each organization's specific environment. Success is measured differently in
each organization. It cannot be achieved simply by copying others.
E.4 P2 Tools
P2 teams can use a variety of specialized tools. These tools provide visual aids that are essential for
communicating P2 information to management, other workers, and other interested parties. Tools also
help P2 teams gather information and provide problem-solving and decision-making guidance. Finally, by
using the tools, the P2 team is in a better position to construct an action plan for each P2 project included
in the program. This allows for consistent tracking by the P2 oversight committee.
P2 tools are Systems Approach tools. The Systems Approach looks at the whole organization, and the
parts, and the connections among the parts. These tools help point out how things can be changed to conserve
the use of a resource or prevent the waste from occurring. This is fundamentally different from having an
external assistance provider suggesting a way to change the process without considering the system.
Executive Summary
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These P2 tools are derived from quality programs and are widely used throughout the world. The
application of the quality improvement tools used in the Systems Approach is a powerful force in eliminat-
ing environmental inefficiencies and preventing pollution.
The P2 tools are:
Process characterization with hierarchical process mapping
Resource accounting using the process maps as a template
Selection of P2 opportunities using a Pareto diagram with appropriate cost information
Analysis of the root cause of the problem using a cause-and-effect diagram
Generation of alternative solutions using brainwriting
Selection of an alternative for implementation using bubble-up/bubble-down
Implementation of the alternative using an action plan
Checklists are also useful to help the P2 teams review the process and ensure that their work is
complete.
Tools take time to master, but they help foster skills that the P2 team needs to characterize the pro-
cess, solve problems, and make decisions. Making P2 a way of life takes more than words; it requires
action. Action plans provide documentation for accomplishing the goals decided upon by using the tools.
It makes it easier to track P2 progress over time.
E.5 Traditional Approach to P2 Implementation
The P2 approach provided in the previous EPA publications is presented along with process maps
depicting each of the steps. This traditional approach has a "top-down" focus. It starts with getting man-
agement approval with pre-set program goals. This is communicated to the workforce using a policy
statement. A P2 task force is organized and conducts a preliminary P2 assessment.
From this information, a P2 program plan is prepared with clear objectives and a firm schedule. Now
a detailed P2 assessment is conducted to start the implementation phase. Checklists and worksheets
are provided to help the team collect data and information. This assessment team will review the data and
visit the sites where the P2 activity is planned to take place.
The team will derive P2 options (called alternatives in this Guide) and screen them with a criteria
matrix. A feasibility analysis is performed to make a final determination based on technical, environmental,
and economic factors. At this point, the traditional approach requires the preparation of a formal, written
P2 assessment report to present the analysis to management for a decision.
Once the work begins, it is reviewed and adjusted to make sure it meets the objectives. The final step
in the traditional program is to measure P2 progress. Data is acquired from the implementation phase and
analyzed.
Previous P2 publications provide guidance on how to maintain the P2 program. Five activities are
detailed as follows:
Integrating the P2 program into other formal corporate initiatives
Providing the proper amount of P2 education
Communicating and soliciting of suggestions
Providing for proper incentives for participating
Implementing public outreach and education
Executive Summary
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P2 practitioners found this approach to be useful for very small organizations. Another method, called
Nothing to Waste, has also been shown to be very effective with very small organizations and uses the
tools presented in Chapter 4.
E.6 EMS Approach to P2 Implementation
The international voluntary standard for environmental management systems (EMS), known as ISO
14001, is an effective tool for implementing P2 alternatives. It is the intent of this standard to establish and
maintain a systematic management plan designed to continually identify and reduce the environmental
impacts resulting from an organization's activities, products, and services. An EMS promotes important
planning and improvement elements needed in the design of multimedia source reduction and recycling
programs.
As an initial step in developing a comprehensive EMS, most organizations find it helpful to complete an
objective gap analysis of their existing environmental system. This enables the organization to compare its
systems against ISO 14001 and highlight areas that require attention under the EMS development phase.
The preparation of the EMS includes the following steps:
Environmental policy, management commitment, and scope of the
Communication of the EMS policy
EMS planning
EMS implementation
Monitoring and measurement
An EMS establishes specific objectives, targets, and time frames for implementing P2 initiatives, im-
proving environmental performance, and maintaining compliance, including compliance with state P2 plan-
ning requirements. Environmental management programs (EMP) are used to achieve the EMS objectives
and targets.
Organizations are discovering that their investment in an EMS is leading to improved environmental
performance and compliance with benefits for the environment and the community. An EMS provides a
good method for establishing and implementing a P2 program. To achieve maximum environmental bene-
fits, the EMS should embody the "plan, do, check, and act" model for continual improvement.
E.7 Using a Quality Model to Implement P2
P2 results are the outcomes of the performance of the P2 program and not a measure of the perfor-
mance itself. Furthermore, P2 results by themselves offer little diagnostic value. They do not indicate
whether an organization could have done better or if they really exceeded expectations. A model that
focuses on measuring performance has been developed in the United States and is known as the Malcolm
Baldrige National Quality Award. It measures six performance categories (i.e., leadership, strategic plan-
ning, other interested party involvement, information and analysis, employee participation, and process
management). A seventh category captures the results. The Green Zia Program (New Mexico Environ-
ment Department) has adapted this quality model to measure environmental excellence. From the per-
spective of the organizations using this model, it is a prevention-focused, performance-driven EMS. Per-
formance can be measured on a 1,000-point scale. This is a unit-less number and does not need to be
normalized like other environmental metrics. Results are measured in three parts: environmental results,
results of the interested party involvement, and financial results.
Executive Summary
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In order to increase the performance score, organizations must demonstrate how they leverage the
various performance activities with other performance criteria. The organization also needs to find a way
to integrate each of the eleven guiding principles with the proper criteria in the model. This facilitates the
integration of the P2 program into the organization.
A five-step process is offered to improve or develop a P2 plan using the quality model concepts. The
steps are as follows:
1. Plan and develop your P2 program
2. Develop your facility's P2 opportunities
3. Implement your P2 program alternatives
4. Maintain your P2 program
5. Measure your progress toward zero waste and emissions
The use of the Systems Approach and the quality model provides a means of creating a sustainable
P2 plan for your organization. Your ISO 14001, Global Reporting Initiative, CERES Principles, Responsible
Care® Program, balanced scorecard, six sigma, ISO 9000, and other environmental and quality initiatives
will help the organization score points in each of the criteria. All these programs help contribute to environ-
mental excellence. This quality model simply provides a means of providing a common thread on how they
are related and allows you to see just how effective they are at driving environmental performance in your
organization.
The P2 plan should be integrated with the core business practices. "Oh, that is something that the
environmental coordinator is doing!" - such an attitude can only limit results. By making the P2 plan more
businesslike, the possibilities for P2 within the organization are significantly enhanced.
E.8 Finding Your Own Way to Implement P2
Three approaches to implementing a P2 program have been presented in Chapters 5-7. This chapter
discusses some of the items that are covered in these approaches to provide you with some ideas for
planning and implementing a P2 program that is specific to your organization's requirements and culture.
The following categories are presented that a P2 program could choose to address:
Extent of planning
Leadership
P2 goal setting
Focus on results
Information and analysis
Process management
Employee participation
Focus on interested parties
Guiding principles or core values
P2 program elements
E-9. CD-ROM
This Guide has been issued with a companion CD-ROM. It provides supporting information on all the
topics and additional materials that may be required to plan and implement a P2 plan for your organization.
Executive Summary
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All the referenced material is accessible using the CD-ROM, including the previous EPA P2 publications
and associated checklists. Information on a large number of EPA and state P2 activities is also included.
The CD-ROM is divided into the following sections:
• P2 checklists
Links to information on the P2 tools
Information on EMS to support P2 implementation
Information on the quality (Green Zia) model to support P2 implementation
Other P2 manuals
Other sources of useful P2 information
Executive Summary
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Executive Summary
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CHAPTER 1
Introduction
EVOLUTION OF POLLUTION PREVENTION (P2)
Pollution prevention (P2) has evolved substantially in its first de-
cade. In 1988, the U.S. Environmental Protection Agency (EPA) pub-
lished the Waste Minimization Opportunity Assessment Manual (EPA/
625/7-88/003). It contained over 34 pages of checklists and worksheets
and focused on hazardous waste minimization. The first revision, Fa-
cility Pollution Prevention Guide (EPA/600/R-92/088), was released in
1992. It contained only 10 pages of checklists and worksheets, and
added new topics, including energy conservation and the design of en-
vironmentally compatible products. The EPA distributed many copies
of these publications to requestors in the United States and internation-
ally, and the information was well-received by the environmental com-
munity. The EPA prepared many successful project reports and case
studies based on this approach. Copies of these publications are avail-
able on the CD-ROM that accompanies this Guide, and the "traditional"
P2 approach that they describe is covered in Chapter 5 of this Guide.
This Guide presents an alternative approach to implementing P2 in
your organization. As you will see, it documents how P2 is moving from
a specialized environmental initiative to a mainstream business activity.
Employees can now become increasingly involved in P2 and reduce
their reliance on "outside experts" using defined checklists and data-
bases of "proven solutions" that may overlook P2 opportunities. Em-
ployees can use process mapping to better understand the
organization's main and supporting processes and widely accepted
problem-solving and decision-making tools to find new P2 opportunities
and prepare cogent, written action plans. Many business managers are
already familiar with these tools since they are already used to improve
operations. No matter what method is selected to implement P2 activi-
ties, these tools should help improve communication within an organi-
zation and communication with other interested parties. This Guide is
intended to assist any organization in developing, implementing, and
maintaining a P2 program. It should help your organization decide which
program elements to include and the general approach for sustaining
this important business practice.
During the evolution of P2, some environmental professionals have
continued to focus on regulatory compliance. This has been a reactive
focus, as compliance activity is usually undertaken in response to a
new or changed regulation at the Federal, state, or local level. Preven-
tion, on the other hand, is anticipatory. Action is taken not on the waste
or use of a regulated material, but on the circumstances and conditions
that may generate waste or a regulated material. The focus in P2 is on
Includes:
D Evolution of Pollution
Prevention (P2)
D Benefits of P2
D Impediments to P2 Use
D P2 in Steps
D Organization of This
Guide
H References
This Guide presents an alter-
native approach to implement-
ing P2 in your organization.
P2 is moving from a
specialized environmental
initiative to a mainstream
business activity.
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The focus in P2 is on the
organization's main and
supporting processes, not on
the resulting waste or use of a
regulated material.
Lean generally focuses on "the
elimination of all waste from all
business practices."
This Guide focuses on the
integration ofP2 into core
business practices.
Many advocates for
sustainability seek not merely
to reduce waste but to elimi-
nate the generation of waste
altogether.
Having a strong P2 program is
a vital aspect of any program
that is set on eliminating
wastes from the organization.
the organization's main and supporting processes, not on the resulting
waste or use of a regulated material.
Many states have enacted P2 and toxics use reduction planning
legislation. This legislation has had the unintended effect of making P2
a regulatory compliance effort and has done little to integrate P2 into
core business practices. It is important to understand the organization's
main and supporting processes and all of the individual work steps so
that when the process is changed, the regulatory requirement is not
triggered. By seeking to avoid the need for regulatory compliance (i.e.,
compliance through P2), environmental professionals become impor-
tant resources to the organization's work function; managers of orga-
nizations are beginning to recognize the value of these environmental
professionals as they reduce the costs associated with compliance
activities.
An organization's management is always searching for the new-
est trend to enhance its value and financial viability. Many organizations
use a version of a management practice called lean manufacturing.
Lean generally focuses on "the elimination of all waste from all busi-
ness practices."Much has been written on seven types of organiza-
tional wastes: over-production, waiting time, transport, variable
process, inventory, motion, and defective goods. Environmental wastes
are rarely included in these programs because many organizations
rely on the environmental function to manage these wastes in accor-
dance with regulations. Many organizations with a strong focus on quality
have weak P2 programs because the environment and quality pro-
grams have not been sufficiently integrated. This Guide focuses on the
integration of P2 into core business practices. It will present P2 as a
necessary component of many common organizational management
programs and show you how to use the same problem-solving and
decision-making tools used in these programs.
Many advocates for sustainability have called for a shift to biologi-
cally-inspired production models. They seek not merely to reduce waste
but to eliminate the generation of waste altogether. As a result, there is
a growing trend for organizations to set goals of zero wastes and/or
zero emissions. Organizations like DuPont, Xerox, Collins Pine, and
Interface have joined these ranks. The zero-waste trend stems from a
long-standing tradition of setting zero defects, zero injuries, and zero
incidents goals. Having a strong P2 program is a vital aspect of any
program that is set on eliminating wastes from the organization. How-
ever, integrating a strong P2 program with many other programs in the
organization is still essential to realizing these goals. Some organiza-
tions are implementing programs that direct them toward a sustain-
able performance level. Elimination of wastes and conservation of
resources are important first steps in such programs.
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This Guide is not intended to be an exhaustive review of case stud-
ies and company examples. In order to keep this Guide to a reason-
able length, examples have been cited in the references section of
each chapter and links have been provided in the CD-ROM that ac-
companies this Guide. In addition, many EPA and other programs sup-
port P2 efforts; e.g., Environmentally Preferable Purchasing (EPP),
Design for Environment (DfE), Environmental Accounting Project (EAP),
P2 Resource Exchange (P2Rx) and a number of other voluntary pro-
grams. Links to these programs are provided on the CD-ROM. This
CD-ROM will also provide more detailed supporting information on many
of the concepts described in the Guide.
BENEFITS OF P2
The benefits of practicing P2 have long been noted. Despite the
clear advantages, however, some managers are still reluctant to rec-
ognize the P2 efforts that are underway in their organizations. To pro-
vide better focus on the benefits, environmental coordinators are now
showing how P2 is enhancing other management initiatives by linking
P2 to the core values of the organization. It may be best to think of the
following categories of benefits in this new light.
• Reduced operating costs
• Improved worker safety
• Reduced compliance costs
• Increased productivity
• Increased environmental protection
• Reduced exposure to future liability costs
• Continual improvement
• Resource conservation
• Enhanced public image
This Guide is not intended to
be an exhaustive review of
case studies and company
examples.
Reduced operating costs. P2 activities usually save an organization
money in the long term. Many P2 projects have good returns on invest-
ment and short payback periods. Even if an organization is not subject
to complicated regulations, P2 can still result in cost savings by reduc-
ing energy and water use while increasing materials productivity. Or-
ganizations may also save money in solid waste disposal costs, new
material costs, and improved operating efficiency. Unfortunately, too
few P2 professionals communicate the economic benefits of P2
progress to management.
Improved worker safety. Reducing the use of toxic materials in the
workplace should be a major component of P2. By reducing or elimi-
nating toxic substance use, the safety of the work environment can be
improved and the use of personal protective equipment requirements
decreased. Also, reducing the likelihood of leaks, spills, and harmful
releases can decrease worker, visitor, and contractor exposure to those
Unfortunately, too few P2
professionals communicate
the economic benefits of P2
progress to management.
By reducing or eliminating
toxic substance use, the
safety of the work environment
can be improved and the use
of personal protective equip-
ment requirements de-
creased.
-------
Undertaking P2 projects can
reduce regulatory exposure
and, in some cases, eliminate
the need for permits, manifest-
ing, monitoring, and reporting.
P2 can improve an
organization's material produc-
tivity through more efficient
use of raw materials due to
improved processes and
operations.
P2 reduces the generation of
wastes (discharges, emis-
sions, spills, and leaks) at the
source, resulting in less toxic
waste, and thus assures
improved environmental
protection.
substances. These steps will produce cost savings through material
loss prevention and may result in reduced insurance rates as medical
claims and disability leaves decrease. Better labor relations can also
result from improved worker safety. Unfortunately, there have been
cases where P2 activities have inadvertently decreased worker safety
hazards (e.g., substituting the flammable solvent isobutyl alcohol for
the halogenated solvent 1,1,1-trichloroethane which is non-flammable
but a worker health issue). It is important that P2 does not trade off
environmental improvement with workplace health and safety. Ergo-
nomics can also be influenced by P2 efforts.
Reduced compliance costs. Undertaking P2 projects can reduce regu-
latory exposure and, in some cases, eliminate the need for
permits, manifesting, monitoring, and reporting. This is referred to as
avoiding the need for regulatory compliance. Keeping up with regula-
tory requirements and submitting the required reports can be an ex-
pensive and time-consuming process that, if eliminated, saves money.
For example, the U.S. Air Force has initiated a program known as Com-
pliance Through Pollution Prevention (Reference 1-1). The Air Force is
trying to achieve and remain in compliance by using P2 instead of clas-
sical environmental engineering and regulatory compliance techniques.
Some organizations have been able to change their regulatory compli-
ance status (e.g., move from a large quantity generator of hazardous
waste to a small quantity generator) through the use of P2 activities.
Increased productivity. P2 can improve an organization's material
productivity through more efficient use of raw materials due to improved
processes and operations. For example, an organization that produces
large quantities of wastes (discharges, emissions, spills, and leaks)
might be using old technologies to produce its products, or its pro-
cesses might be poorly controlled and inefficiently operated. Some-
times small process improvements involving material substitutions and
changes in operating procedures can result in increased product yield
and better quality.
Increased environmental protection. Many waste disposal and treat-
ment methods are less protective of the environment than previously
estimated. These methods may only move environmental contaminants
from one medium to another. They may cause problems in the future
that are not yet apparent. P2 reduces the generation of wastes (dis-
charges, emissions, spills, and leaks) at the source, resulting in less
toxic waste, and thus assures improved environmental protection.
Reduced exposure to future liability costs. Reduction of potential
long-term liability from waste disposal, emissions, and discharges has
become an important concern in recent years. Some past disposal
practices, although legal, have caused environmental damage forwhich
organizations have been held liable, creating a large liability expense
and damaging their public images. P2 can help reduce long-term liabil-
ity by reducing the amount and toxicity of waste generated.
-------
Continual improvement. Successful implementation of a P2 program
can be an integral part of a company's continual improvement or quality
improvement program. Reducing wastes and improving efficiency are
goals of both P2 and continual improvement. Many organizations use
continual improvement to constantly change certain work processes in
order to improve them. To clarify the use of the term "continual im-
provement," the following distinction is made:
•
r "Continuous improvement—happening all the time, everything
noving forward at once; often used in quality programs"
ning
•ery-
"Continual improvement—happening all the time, but not every-
thing moving forward at the same time and rate; often used by auditors
of Environmental Management Systems and in other environmental
programs."
The term continual improvement is used throughout this text.
Resource conservation. P2 will lead to the use of less energy and
water. All resources, materials use, and waste reduction can be moni-
tored in the same program. Traditionally, most organizations had sepa-
rate programs (e.g., water conservation or energy efficiency) for re-
source conservation and P2. However, these programs are related in
many ways; both are necessary to improve efficiency and to meet the
organization's goal of sustainability.
Enhanced public image. P2 can help an organization gain a favorable
image with the community by showing that they are willing to make
changes to improve the environment and move towards sustainability.
Some organizations have used their "green" image to successfully dis-
tinguish themselves in the marketplace, thus adding to their intangible
goodwill market value.
IMPEDIMENTS TO P2 USE
A number of impediments commonly hinder successful implemen-
tation of a P2 program. It is important to recognize these impediments
and address each of them during implementation. Management's com-
mitment to addressing these issues is a key element of the success of
the P2 program.
Capital requirements
Specifications
Regulatory issues
Product quality issues
Customers' acceptance
Immediate production concerns
Organization image concerns
Available time/technical expertise
Inertia
Successful implementation of
a P2 program can be an
integral part of a company's
continual improvement or
quality improvement program.
P2 will lead to the use of less
energy and water.
-------
Capital justification protocols
may not recognize the "hidden"
costs that are avoided and the
reduction in the organization's
financial overhead burden
resulting from P2 measures.
Unfortunately, P2 changes
may occur faster than the
government can respond.
Some P2 projects may affect
product quality, even when
properly implemented, and
thus may be regarded with
skepticism.
Some large organizations have
encouraged their supply
chains to adopt P2 behaviors
to further the competitive
advantage of the entire value
chain.
Implementation of P2 projects
are often viewed byproduct/on
as requiring time, money, and
personnel, all of which are
usually in short supply.
Capital requirements. Implementation of P2 measures might require
capital investment. Such projects may need to be justified
economically and are subject to the availability of capital in the organi-
zation. Capital justification protocols may not recognize the "hidden"
costs that are avoided and the reduction in the organization's financial
overhead burden resulting from P2 measures.
Specifications. Specifications can be both an incentive and an im-
pediment. For instance, specifications may stipulate certain materials
be used in the manufacture of a product, or that virgin materials be
used rather than recycled. This can lead to the use of materials that
are damaging to the environment, or the unnecessary use of virgin
materials where recycled would suffice.
Regulatory issues. It may be necessary to obtain a new or modified
permit or other governmental approval before implementing a process
change or material substitution. This can be time-consuming and costly.
For example, if a process is regulated by the Food and Drug Adminis-
tration (FDA), all process changes require submittal of an
application for approval, and new equipment must be inspected and
approved by the FDA. In some cases, clinical trials of a substance,
such as a drug, must be repeated to demonstrate efficacy. Unfortu-
nately, P2 changes may occur faster than the government can respond.
Many permit changes can take long periods of time to attain in even the
most efficient governmental agencies.
Product quality issues. Organizations have great concern for the
quality of the products and services they offer. Some P2 projects may
affect product quality, even when properly implemented, and thus may
be regarded with skepticism. For example, the use of mineral oils in-
stead of mineral spirits (that have high volatile organic chemical [VOC]
emissions) to carry dyes to fabrics may mean that some of the oils will
remain on the fabric once it is dried, thereby changing the "feel" of the
fabric and possibly the value of the finished product.
Customers' acceptance. The customer ultimately defines product
quality; anything that affects the quality, or even the perception of qual-
ity, may affect acceptance by the customer. Customers often have a
greater influence on how an organization operates than other outside
parties. Some large organizations have encouraged their supply chains
to adopt P2 behaviors to further the competitive advantage of the entire
value chain.
Immediate production concerns. Implementation of P2 projects are
often viewed by production as requiring time, money, and personnel, all
of which are usually in short supply. Production quotas must be met as
a first priority. After all, meeting the customers' demands is what pays
the bills. However, production often finds the means to improve pro-
ductivity, and P2 needs to be seen in this same light.
-------
Organization image concerns. Organizations may be hesitant to ad-
mit that the "old way" may not be the best way. Once easy-to-imple-
ment P2 practices such as improved operations are underway, for ex-
ample, some organizations may resist publicly acknowledging the
changes out of concern that such acknowledgment might expose pre-
vious, less environmentally sound practices. However, the implemen-
tation of P2 practices provides managers with an opportunity to lead
the organization through changes that will benefit everyone.
Available time/technical expertise. Some organizations may lack
sufficient time or technical expertise to develop and implement P2 prac-
tices. Even though many state and federal technical assistance pro-
grams (References 1-2,1-3,1-4) are available at little or no cost, some
organizations simply fail to take advantage of them.
Inertia. Whenever a production system is in place and working with
some degree of success, there is a tendency to leave well enough
alone. The old adage "if it ain't broke, don't fix it" still prevails in most
organizations. Overcoming resistance to change is a major challenge
for P2.
Even though many state and
federal technical assistance
programs are available at little
or no cost, some organiza-
tions simply fail to take advan-
tage of them.
Overcoming resistance to
change is a major challenge
forP2.
P2 IN STEPS
Previous editions of this Guide have defined a path (adapted from
Figure 3 in EPA/600/R-92/088) depicting how P2 should be implemented
(see Figure 1-1).
r
r
ESTABLISH P2
PROGRAM
1
DO DETAILED
ASSESSMENT
5
>
k
ORGANIZE P2 CONDUCT WRITE P2
PROGRAM k, PRFI IMINARY k, PROGRAM
*" ASSESSMENT *" PLAN
234
|
DEFINE P2 DO WRITE IMPLEMEN
OPTIONS ^ FEASIBILITY k, ASSESSMENT w THE P2 PU
^ ANALYSES W REPORT W
678
MEASURE P2
k PROGRESS
10
MAINTAIN P2
k PROGRAM
11
Figure 1-1. Process Map of a Traditional P2 Program.
Following is an alternative view of P2. The primary difference lies in
the fact that the P2 Program is established after much of the informa-
tion has been gathered rather than in the first step of the program. It
also uses quality tools that have been adapted to P2 programs and
published in the literature. This view of P2 consists of five simple steps
(see Figure 1-2):
The primary difference lies in
the fact that the P2 Program is
established after much of the
information has been gathered
rather than in the first step of
the program.
-------
LOOK FOR P2
OPPORTUNITIES
1
fc
SELECT P2
OPPORTUNITIES
2
CONDUCT P2
PROBLEM SOLVING
3
fc
k
CONDUCT P2
DECISION-MAKING
4
k
MANAGE P2
PROGRAM
5
Figure 1-2. An Alternative Approach to a P2 Program.
While these steps will be discussed in more detail in Chapter 4 of this
Guide, it is important to highlight some of the differences between the
methods described here and the methods contained in the traditional
approach to P2.
Step 1. Looking for P2 Opportunities
• Process mapping
• Main process/supporting
processes
• Maps as information tem-
plates
The process maps become
templates for maintaining
information about the process.
• Rank ordering
• 80/20 rule
• Pareto chart
• Monetary metrics
Every process in every
organization will produce P2
opportunities.
All of the organization's processes are characterized in detail us-
ing a tool known as process mapping. This tool allows the information
to be aggregated to a higher level when necessary. All supporting op-
erations (ancillary and intermittent) are examined and linked to the main
processes. Nothing is missed using this visual tool. All resources (e.g.,
energy, water, and materials) are accounted for at the work-step level
(i.e., at the lowest level in the process maps as they define the actual
work task that is being performed). The process maps become tem-
plates for maintaining information about the process. The costs of us-
ing and losing resources can also be collected by work-step using the
process maps as templates. Traditional P2 methods have relied on a
walk-through process assessment to gather information on P2 oppor-
tunities.
Step 2. Selecting P2 Opportunities
Every use of a resource in a process represents an opportunity to
conserve the use of that resource. Every loss of a resource in a pro-
cess represents an opportunity not to lose that resource. Every pro-
cess in every organization will produce P2 opportunities. It is possible
to rank P2 opportunities using monetary units and also to construct a
Pareto chart. This chart will show that 20% of the P2 opportunities
represent 80% of the true costs of environmental management of the
uses and losses. No matter how the P2 opportunities are selected, it is
important to have the organization keep its collective eye on the most
important ones. Many organizations select a manageable number of
P2 opportunities to work on each year. Ideally, P2 opportunities should
be selected from every department in the organization to ensure that
everyone stays involved.
-------
Step 3. P2 Problem Solving
Once the P2 opportunities are selected, the use and loss of re-
sources are seen as "problems." Worker teams are assembled to ad-
dress these problems using root cause analysis to first ask why each
is a problem. A simple cause and effect (fishbone) diagram can help
the team examine how materials, machines (technology), methods,
and labor contribute to the problem. This visual tool can communicate
the causes of the problem to all levels of the organization. In fact, the
cause-and-effect diagram is the most widely used problem-solving tool
in the world.
With this important information gathered and analyzed, the team
can now search for alternatives to solve the problem using tools like
brainstorming and brainwriting. It is important to remember the adage
that "the only way to find a good P2 alternative is to find many alterna-
tives." In the past, many P2 problem-solving efforts centered on finding
the "right answers" instead of searching for alternatives. Previous P2
success stories should be used only to provide ideas to the team using
this problem-solving method. Because workers often wish to be in-
volved in solving problems associated with their work, home-grown
solutions are often more readily implemented than expert-generated
solutions from the outside.
A simple cause-and-effect
(fishbone) diagram can help
the team examine how materi-
als, machines (technology),
methods, and labor contribute
to the problem.
• Root cause analysis
• Cause and effect diagrams
• Fishbone diagrams
• Brainstorming
• Brainwriting
Step 4. P2 Decision-Making
Now the team must select an alternative to implement. A good tool
for doing this is known as bubble-up/bubble-down. It is a forced-pair
comparison of all the alternatives. Some teams prefer to use a criteria
matrix or selection grid for rating each alternative against a predeter-
mined set of criteria. Alternatives that are inexpensive and easy to imple-
ment go to the top of the list using the bubble-up/bubble-down tool.
These "low hanging fruit" or "quick win" alternatives can often be imple-
mented without much further study. More effective alternatives may
require additional study. In some cases, a detailed feasibility study must
be prepared. It is always beneficial from a team development perspec-
tive to have the "quick wins" precede these more complex programs.
To implement the alternatives, a written action plan should be pre-
pared and submitted to management for review and approval. The key
component of the P2 plan at the facility will be the action plans that are
being implemented during the current year.
Step 5. P2 Program Management
Now the team must select an
alternative to implement.
• Bubble-up/bubble-down
• Criteria matrix
• Action plan
To implement the alternatives,
a written action plan should be
prepared and submitted to
management for review and
approval.
This Guide suggests ways an organization can establish, imple-
ment, and manage its P2 program. The activities described in Steps 1
-------
P2 program management
must be designed to fit the
culture of the organization
using P2.
through 4 will take place within that program. While Steps 1 through 4
apply to many organizations, P2 program management (Step 5) must
be designed to fit the culture of the organization using P2. The organi-
zation must provide training for the people participating in the program.
There must be understandable policies and a management commit-
ment. Relationships to other organizational programs must be clearly
defined. Oversight for the P2 program can be provided in the form of
program audits, by both internal and third parties. Finally, there must be
a way to measure progress and evaluate the effectiveness of the P2
program. Some information that enables organizations to adapt the
program management to their own culture is provided in Chapters 5
through 7.
ORGANIZATION OF THIS GUIDE
This Guide will provide information to help organizations get their
P2 programs started or to help re-evaluate existing P2 programs. Chap-
ter 2 provides some advice on how to get started with the P2 program
process. The planning of the P2 program is covered in Chapter 3 and
is discussed along with some planning elements that should be ad-
dressed. Most P2 programs can use tools (discussed in Chapter 4) to
facilitate communication within the organization and between organi-
zations. Tools that support the five-step model described previously
are presented in Chapter 4. These tools can also be used in all of the
implementation models covered in this Guide. Several models are pre-
sented to help in implementing the P2 program. A traditional P2 imple-
mentation model is presented in Chapter 5. It can be used with or
without the tools presented in this Guide. Also presented is a version
of this model called "Nothing to Waste" that is particularly useful to
small organizations. Chapter 6 shows how an environmental man-
agement system (EMS) may be used to implement a P2 program.
Chapter 7 presents a quality model that can be used to implement a
P2 program. Chapter 8, the final chapter, examines how individuals
can design and implement their own P2 programs from the materials
presented in this Guide.
A companion CD-ROM is included to provide supporting informa-
tion on all of these topics and additional information that may be re-
quired to plan and implement a P2 program for your organization. All of
the referenced material is accessible through the CD-ROM. The fol-
lowing information is provided on the CD-ROM:
:
P2 Checklists
Links to Information on the P2 Tools
Information on EMS to Support P2 Implementation
Information on Quality Model to Support P2 Implementation
Other P2 Manuals
Other Sources of Useful P2 Information
-------
The CD-ROM should be useful as your organization develops the
P2 Program.
REFERENCES
1-1. Compliance Through Pollution Prevention (CTP2):
Implementation Guide. U.S. Air Force Material Command,
Wright-Patterson AFB, December 2000.
1-2. National Pollution Prevention Roundtable (NPPR) Web Site
http://www.p2.org/
1-3. National Institute for Science and Technology Manufacturing
Extension Program (NIST MEP) Web Site
http://www.mep.nist.gov/
1-4. Small Business Development Centers (SBDC) Web Site
http://www.sbaonline.sba.gov/SBDC/
Other Sources of P2 Information
EPA Environmentally Preferable Purchasing (EPP) Program
http://www.epa.gov/opptintr/epp/
EPA Environmental Accounting Project
http://www.epa.gov/opptintr/acctg/
EPA Design for Environment
http://www.epa.gov/dfe/
EPA P2 Programs and Initiatives
http://www.epa.gov/opptintr/p2home/programs/index.htm
EPA P2 Resource Exchange (P2Rx)
http://www.p2rx.org/
EPA Sustainable Industry
http://www.epa.gov/sustainableindustry/
State P2 Programs
http://www.epa.gov/opptintr/p2home/resources/statep2.htm
-------
-------
CHAPTER 2
Getting Started
So you have decided to move from conducting specific P2 projects
to having a formal P2 program. Maybe you are just trying to revive an
older P2 program in your organization. In either case, this section of the
Guide will provide you with information to consider before beginning
your P2 program planning process.
HOW TO DEFINE P2
It is important to decide how you will define P2. In order to know
what you can include in your P2 program, it helps to know what is pos-
sible. There are many definitions available to choose from and many
programs that are closely related to P2. We will present a few P2 con-
cepts to help you determine where you wish to focus your efforts. First,
the definition of pollution prevention adopted by the U.S. Environmental
Protection Agency (EPA) is provided in Box 2-1.
Box 2-1. Pollution Prevention Definition
Pollution prevention means "source reduction" (as defined under the
Pollution Prevention Act) and other practices that reduce or eliminate the
creation of pollutants through:
• increased efficiency in the use of raw materials, energy, water, or
other resources, or
• protection of natural resources by conservation.
The Pollution Prevention Act defines source reduction to mean any prac-
tice that:
• reduces the amount of any hazardous substance, pollutant, or con-
taminant entering any waste stream or otherwise released into the
environment (including fugitive emissions) priorto recycling, treatment,
ordisposal
• reduces the hazards to public health and the environment associated
with the release of such substances, pollutants, or contaminants.
Under the Pollution Prevention Act, recycling, energy recovery, treat-
ment, and disposal are not included within the definition of pollution preven-
tion. Some practices commonly described as "in-process recycling" may
qualify as pollution prevention.
From Hank Habicht's EPA memorandum of May 28, 1992 (Reference 2-1)
The EPA definition stresses the importance of placing source re-
duction at the top of a "waste management hierarchy." Recycling, proper
treatment, and safe disposal of the residues are farther down the hier-
archy. There are other similar P2-like concepts that some feel com-
pete with the EPA definition.
Includes:
D How to Define P2
D Sustainable Development
D Integrating the New P2
Program into Core
Business Practices
D Who Should Implement
P2?
D When Will You Begin?
D Lessons Learned from
Past P2 Programs
D Dealing with Change
D References
In order to know what you can
include in your P2 program, it
helps to know what is possible.
The EPA definition stresses the
importance of placing source
reduction at the top of a "waste
management hierarchy."
Getting Started
-------
Cleaner production is the
continuous application of
an integrated preventative
environmental strategy ap-
plied to processes, products,
and services.
The international community has adopted the term cleaner pro-
duction. As you can see from the definition of cleaner production in Box
2-2, it has a broader meaning than the one we give to the term P2. The
final term eco-efficiency is used extensively in the sustainable devel-
opment arena and is defined in Box 2-3.
Box 2-2. Cleaner Production Definition
Cleaner production is the continuous application of an integrated pre-
ventative environmental strategy applied to processes, products, and ser-
vices. It embodies the more efficient use of natural resources and thereby
minimizes waste and pollution as well as risks to human health and safety.
It tackles these problems at their source rather than at the end of the pro-
duction process; in other words, it avoids the 'end-of-pipe' approach.
i
For processes, cleaner production includes conserving raw materials
and energy, eliminating the use of toxic raw materials, and reducing the
quantity and toxicity of all emissions and wastes.
For products, it involves reducing the negative effects of the product
throughout its life-cycle, from the extraction of the raw materials through to
the product's ultimate disposal.
Forservices, the strategy focuses on incorporating environmental con-
cerns into designing and delivering services.
United Nations Environment Program (Reference 2-2)
Box 2-3. Eco-efficiency Definition
Eco-efficiency is the efficiency with which ecological resources are used
to meet human needs. It is expressed as the ratio of an output—the value of
products and services produced by a firm, a sector, or the economy as a
whole—to the "input"—the sum of environmental pressures generated by
the firm, sector, or economy. Measuring eco-efficiency depends on identify-
ing indicators of both input and output.
The World Business Council for Sustainable Development (WBCSD)
(Reference 2-3) considers that eco-efficiency places seven demands on a
firm:
1. Reducing material intensity of goods and services
2. Reducing energy intensity of goods and services
3. Reducing toxic emissions
4. Enhancing material recyclability
5. Maximizing sustainable use of renewable resources
6. Extending product durability
7. Increasing the service intensity of goods and services
Chapter 2
-------
All three of these terms—pollution prevention, cleaner production,
and eco-efficiency—address:
'
2.
Elimination of process losses at the source without resorting
to end-of-pipe pollution control devices.
Conservation of resources (including energy, materials,
and water) that are used in the process or operation.
There are also some differences between these terms. For ex-
ample, eco-efficiency looks at maximizing the sustainable use of re-
newable resources while cleaner production focuses on the more
efficient use of natural resources. P2 looks at the protection of natural
resources by conservation. All of the definitions address hazards to
public health and the environment and seek to reduce toxic emissions
and the use of toxic raw materials. However, only cleaner production
addresses the need to consider whether there is a shift in risk from the
environment to worker safety as a result of changes made in the pro-
cess.
Eco-efficiency and cleaner production address processes, prod-
ucts, services, and life cycle issues. P2 considers "in-process recy-
cling" while eco-efficiency considers "enhancing material recyclability."
The authors use the term P2 throughout this Guide. However, you
can choose to add elements of cleaner production and/or eco-efficiency
to your program if you wish to do so. The definitions of these terms are
provided to help you see what is possible. There are organizations al-
ready incorporating many of these additional items into their P2 pro-
grams. P2 can be defined more broadly than EPA originally intended.
SUSTAINABLE DEVELOPMENT
P2 plays an important role where the goal is sustainable develop-
ment. There are many definitions of sustainable development. The fol-
lowing definitions provide broad and operational perspectives to cover
the range of components that are commonly included under the
sustainability umbrella. According to the World Commission on Envi-
ronment and Development, "sustainable development is a process of
change in which the exploitation of resources, the direction of invest-
ments, the orientation of technological development, and institutional
change are all in harmony and enhance both current and future poten-
tial to meet human needs and aspirations." An operational definition of
sustainable development is "Good stewardship of natural resources
such that long-term productivity may be maintained or improved with
minimal, if any, adverse impacts on the environment and worker health
and safety."
If your organization is interested in a sustainable development goal,
it is important to consider setting a goal of zero waste or zero emis-
Consider whether there is a
shift in risk from the environ-
ment to worker safety as a
result of changes made in the
process.
The authors use the term P2
throughout this Guide. However,
you can choose to add ele-
ments of cleaner production
and/or eco-efficiency to your
program if you wish to do so.
P2 can be defined more
broadly than EPA originally
intended.
P2 plays an important role
where the goal is sustainable
development.
Consider setting a goal of zero
waste or zero emissions.
Getting Started
-------
When getting started with a P2
program, look around to see
what other types of "preven-
tion" programs already exist in
the organization.
This Guide will provide some
methods you can use to
emphasize P2 within an EMS.
sions (Reference 2-4). For some organizations, this goal may seem
unrealistic. However, many organizations reach these goals by con-
verting previously unused wastes into other products and driving their
programs to near zero waste. This zero concept is very popular in the
quality movement and more particularly with a program referred to as
"six sigma" (i.e., attaining the goal of only 3.4 defects per million opera-
tions instead of the 35,000 to 60,000 defects per million operations that
most very competitive organizations now tolerate). This number of de-
fects is very close to zero. Some organizations have extended the six
sigma approach to regulatory compliance issues where they consider
a "notice of violation" a defect. However, more progressive organiza-
tions use six sigma to prevent regulatory compliance issues.
INTEGRATING THE NEW P2 PROGRAM INTO CORE
BUSINESS PRACTICES
Organizations considering a P2 program may already have com-
patible programs in place. When getting started with a P2 program,
look around to see what other types of "prevention" programs already
exist in the organization. Box 2-4 lists some prevention-oriented pro-
grams that currently exist in many organizations. Can the P2 program
be tied to any of these or similar programs? The integration of the P2
program into existing core business practices can help small organi-
zations find resources to start a new P2 program and large organiza-
tions consolidate existing programs, allowing each to remain competi-
tive in the global marketplace as they implement P2.
'
ox 2-4. Typical Prevention Programs in Industry
Environmental management systems
Quality management initiatives
Preventive maintenance
Health and safety programs
Insurance/risk management
Environmental Management Systems
One program that may be compatible with a new or revised P2
program is an environmental management system (EMS). One popu-
lar EMS format, known as ISO 14001, has been issued by the Interna-
tional Organization for Standardization (Geneva, Switzerland). ISO
14001 is a management system standard, not a performance stan-
dard, providing a general framework for organizing the tasks neces-
sary for effective environmental management. This approach may prove
effective in encouraging the organization to take an active, preventive,
and systematic approach to managing its environmental impacts. This
Guide will provide some methods you can use to emphasize P2 within
an EMS (see Chapter 6). An EMS protocol requires the organization to
Chapter 2
-------
consider the prevention of pollution, compliance with all legal re-
quirements, and continual improvement. Like P2, an EMS seeks to in-
tegrate environmental concerns into core business practices.
Quality Initiatives
Quality initiatives focus on preventing defects in processes, prod-
ucts, and services. These initiatives often declare a "war on waste."
However, too few also consider air emissions, water discharges, solid
and hazardous wastes, and spills and leaks to be a waste. Organiza-
tions develop ISO 9000 programs to deal with quality. ISO 9000 pro-
grams are prepared in the same format as the ISO 14001 program.
Quality initiatives have evolved just as P2 has been defined and re-
fined. Many people have less than fond memories of certain manage-
ment fads like "Total Quality Management (TQM)." Despite the ap-
proaches and fads that cycle in and out, most organizations would agree
that quality refers to everything an organization does to provide goods
and services that meet customer requirements, the way that
organization's employees interact together, and the organization's ex-
pectations of its suppliers and other interested parties. Developers of
P2 programs should become familiar with the quality improvement ini-
tiatives in the organization.
Some organizations use the Baldrige criteria to judge their overall
operating performance. The Malcolm Baldrige National Quality Program
is the Presidential Award program in the United States (Reference 2-
5). These performance-based criteria are currently used in approxi-
mately 50 countries and 44 of the 50 states to help improve competi-
tiveness in both manufacturing and service businesses. An environ-
mental excellence program has been developed in New Mexico using
the Baldrige model. This Green Zia Program is used to rate organiza-
tional environmental programs that "go beyond mere compliance." This
program (Reference 2-6) helps an organization establish core values
for its program and demonstrates how quality and P2 can be effectively
integrated. A set of criteria and a rigorous scoring system allow any
organization to track and search for trends in its continual improve-
ment using a unit-less score. This eliminates the need to "normalize"
for production. These concepts are covered in Chapter 7.
Preventive/Predictive Maintenance
Preventive and/or predictive maintenance is designed to keep ma-
chinery from breaking down. Unscheduled equipment downtime often
leads to the generation of wastes in organizations. There are a number
of Internet sites dedicated to the topic of preventive/predictive mainte-
nance (Reference 2-7). The principles from this field are applicable to
P2 programs.
Quality initiatives focus
on preventing defects in
processes, products, and
services.
The Baldrige criteria are
currently used in approxi-
mately 50 countries and 44 of
the 50 states to help improve
competitiveness in both
manufacturing and service
businesses.
Unscheduled equipment
downtime often leads to the
generation of wastes in organi-
zations.
Getting Started
-------
Safety
Safety has always had its
focus on preventing incidents
and exposures.
Many states have legislatively
mandated programs that
require P2 planning while
others have programs that
encourage voluntary P2
planning.
For maximum effectiveness,
workers need to be directly
involved in P2 program devel-
opment.
Many environmental managers are gaining some oversight of the
safety function in their organizations. Organizations track safety closely
because it impacts worker compensation rates and related insurance
costs. P2 training and safety training are often combined in organiza-
tions to stress the prevention message. Safety has always had its fo-
cus on preventing incidents and exposures. There is information on
safety available on the Internet (Reference 2-8).
Insurance/Risk Management
Insurance companies and organization risk management profes-
sionals frequently audit organization processes and facilities to pre-
vent property loss and other forms of insurable risk. P2 programs should
collaborate with risk management personnel, whether in the company
or sent by the insurance company.
WHO SHOULD IMPLEMENT P2?
Many states have legislatively mandated programs that require P2
planning (Reference 2-9) while others have programs that encourage
voluntary P2 planning (see the CD-ROM for further information on these
statutes). The focus of most state P2 planning programs is the envi-
ronmental manager. However, it is becoming clear that operational
changes not commonly controlled by the environmental manager are
needed to make P2 work. Recognizing this point, many organizations
are establishing multi-functional teams to provide oversight of their
waste-elimination efforts. These teams often include environment, op-
erations, accounting, and a variety of other internal service providers
and functions. Representatives from upper management are often es-
sential members of such P2 oversight teams.
Although a commitment to the P2 program should begin with man-
agement (i.e., top-down approach), line employees can often suggest
valuable improvements in operations and procedures (i.e., bottom-up
approach). For maximum effectiveness, workers need to be directly
involved in P2 program development. The Quality model (Chapter 7)
stresses this need by dedicating one of its seven performance criteria
categories to worker involvement. Many organizations use P2 tools to
give everyone a common frame of reference and to enhance problem-
solving and decision-making skills. Management can authorize and give
responsibility to worker teams to implement the P2 program. Manage-
ment should also monitor all P2 efforts periodically. Whether an organi-
zation runs a service business or operates in a manufacturing setting,
it can implement a successful P2 program.
Chapter 2
-------
WHEN WILL YOU BEGIN?
As mentioned previously, you may have already started your P2
efforts. Perhaps you have had some P2 successes and are now seek-
ing ways to formalize and sustain the program. Maybe this is the first
time you have formally looked at eliminating waste from the organiza-
tion. If so, you might wish to start by preparing a list of all the projects
you have implemented in the past two or three years that would fit un-
der the heading of P2. Make sure that representatives of all parts of the
organization participate in the creation of this list. As you begin to focus
on P2, many organizations are able to double or triple the number of P2
projects appearing on their listing of past accomplishments. As more
people get involved in P2, they may begin to recognize that they have
most likely been doing some of this all along. Resolve to keep this list
current and share it with regulators, customers, suppliers, community
organizations, and all other interested parties. Then prepare to start
your new P2 program.
LESSONS LEARNED FROM PAST P2 PROGRAMS
There is a substantial body of literature on P2 efforts in the United
States and internationally. References to much of this P2 literature is
included on the companion CD-ROM. Some of the lessons learned
during those efforts specific to the preplanning phase are described in
the following paragraphs.
The implementation of P2 projects can yield some modest, imme-
diate benefits. However, the big payoff from P2 often requires a pro-
gram that is integrated into the operations of the organization and sup-
ported for a minimum of two to three years. Like quality, P2 is a mindset
that needs to permeate into the culture of the organization. One of the
greatest P2 myths is that a P2 program is a "quick fix" used to turn
around organizations. Many P2 programs do not offer instant financial
success. P2 is a long-term effort with both long- and potential short-
term bottom-line benefits.
P2 success requires full financial support as well as management
commitment. Resources that will be needed include funds, people, train-
ing, facilities, support structure, and, in some cases, the adoption of
new technology. Often projects that are already funded can be turned
into P2 projects by emphasizing different aspects. Other financial com-
mitment concerns will be covered in Chapter 4.
Some have said that P2 is a way of life, not a new program. P2
requires many changes in behavior that cannot be demanded. The goal
of P2 is to institutionalize the philosophy and guiding principles as part
of the organization. This can only be accomplished by continual ac-
tions that reinforce P2 behaviors. Since people resist change, a move
to new prevention methods involves a campaign for their hearts as well
as their minds.
As more people get involved
in P2, they may begin to
recognize that they have most
likely been doing some of this
all along.
Like quality, P2 is a mindset
that needs to permeate into
the culture of the organization.
P2 is a long-term effort with
both long- and potential short-
term bottom-line benefits.
P2 success requires full
financial support as well as
management commitment.
P2 is a way of life, not a new
program.
The goal ofP2 is to institution-
alize the philosophy and
guiding principles as part of
the organization.
Getting Started
-------
Change management is a
fundamental and critical
element of P2 program imple-
mentation.
Empowering teams to fully
implement the new P2 behav-
iors is central to successful
change management.
The business case needs to
be made for all P2 projects.
Instituting a P2 program can
facilitate change in an organi-
zation.
Everyone in the organization
must change to make P2
work.
The very reasons that organi-
zations are trying to become
"lean" are the same reasons
that P2 should be an integral
part of that program.
Change occurs because people as a group accept it. Approach
such change deliberately. Involve the organization's members and lis-
ten to them. Be responsive to their needs and ideas. When change
represents a new work style for people, allow time to adjust to it and
experiment with it. An idea approached as a pilot project may be ac-
cepted more readily than one imposed as a permanent change. You
can combat resistance by surrounding the organization's members
with a network of familiar activities, support, and guidance. Encourage
them to feel anchored to the direction and mainstream activities of the
organization.
Change management is a fundamental and critical element of P2
program implementation. Failure to develop bureaucracy-elimination
initiatives, communication improvement, and training programs sends
mixed signals to the employees. Empowering teams to fully implement
the new P2 behaviors is central to successful change management.
Many P2 consultants and P2 technical assistance providers have
tried to sell P2 as an environmental program. Your organization will
probably find greater success by linking P2 to its strategic needs. Ad-
dress the true scope and impact of P2 as part of managing your busi-
ness needs. To increase your effectiveness, integrate the P2 program
into the organization's core business practices. The business case
needs to be made for all P2 projects. Success needs to be measured
economically, as well as in volume and weight.
DEALING WITH CHANGE
Instituting a P2 program can facilitate change in an organization.
Technical savvy and operational knowledge are not sufficient by them-
selves. Everyone in the organization must change to make P2 work.
This will not be easy. There are seven things you should consider when
you start a P2 program in your organization:
Present reason for change. If you want people to change,
persuade them of the need for change. This might be ac-
complished as part of a "war on waste" or related to issues
surrounding competitive advantage. The very reasons that
organizations are trying to become "lean" are the same rea-
sons that P2 should be an integral part of that program.
What is management pointing to when it seeks change?
How is P2 related to that change? Moving more money to
the bottom line is important in a private organization. Main-
taining the same mission with fewer funds is a common
cause for many not-for-profit and government organizations.
Many times money has something to do with the need for
change. This should make P2 very attractive.
Chapter 2
-------
Offer a compelling vision. The concept of having a P2
vision will be covered in the next chapter. Everyone will be
asking, "How will things be better with the change?" All P2
projects must fit the vision and must be related to the rea-
son for change previously stated. Finding the right vision
will be challenging. However, once found, it will provide the
rallying call that is often missing in a P2 program.
Show results quickly! Many successful P2 programs gain
momentum when economic benefits are demonstrated. P2
programs should pay for themselves. Do not measure
progress by the number of activities (i.e., P2 opportunity as-
sessments, P2 teams in action, opportunities identified, etc.)
or pounds or volume of waste avoided. P2 goals are best
measured in dollars—enough dollars to provide an incen-
tive to keep the P2 program going from year to year. It could
even be treated as a profit center in a private sector organi-
zation. All organizations can support value-added programs.
Communicate, then communicate some more. You can
never do enough to get the P2 message across to all inter-
ested parties—workers, suppliers, regulators, customers,
the community, and all other interested parties. Keep the
communication simple so everyone can understand what
is going on. "Walk the talk" at all levels of the firm, even top
management. Provide incentives for suppliers to join the pro-
gram. Show the customers how the program can benefit
them. Join in the regulators' voluntary programs that encour-
age waste reduction.
Build a strong, committed management P2 guiding
team. This high-level oversight team should sponsor all P2
efforts while articulating the P2 vision, fostering communi-
cation, eliminating obstacles, coaxing the short-term wins,
serving as mentors to the worker P2 teams, and embed-
ding new approaches into the organization's culture. Gen-
erally, whenever such a team is present, the P2 program
has a much higher level of success. Implementation of P2
through the intervention of only vendors, consultants, and
technical assistance providers reduces the chance of suc-
cess. The P2 program must be internalized, continuously
reinforced, and rewarded by management in order to yield
long-term results.
Add some level of complexity to the P2 program. This
may sound counter-intuitive, but breakthrough complex
change may be easier to accomplish than incremental
change. Integrating P2 into core business practices instead
of relegating it to environmental personnel is one way to ac-
complish this goal. To maximize integration, change every-
i
Finding the right vision will be
challenging. However, once
found, it will provide the rallying
call that is often missing in a
P2 program.
You can never do enough to
get the P2 message across to
all interested parties—work-
ers, suppliers, regulators,
customers, the community,
and all other interested parties.
The P2 program must be
internalized, continuously
reinforced, and rewarded by
management in order to yield
long-term results.
To maximize integration,
change everything at the same
time.
Getting Started
-------
thing at the same time. P2 should be a collaborative effort
with operations department efforts to increase productivity.
As stated previously, people do not resist their own
ideas. Involve the organization's members in the change.
Rely on outside expertise and technical assistance only to
facilitate internal change. Provide the needed resources re-
quired to initiate the P2 program. People who participate in
deciding what P2 changes are needed and how they will
occur are more likely to support the changes and advance
the program. Provide training and lessons learned to in-
crease the success of the P2 program.
Chapter 3 will describe some of the elements that will help make
the P2 program work and thrive.
REFERENCES
2-1. EPA Web Page http://www.epa.gov/rgytgrnj/programs/artd/
air/nsr/nsrmemos/pollprev.pdf
2-2. United Nations Web Page
http://www.unepie.org/Cp2/home.html
2-3. World Council for Sustainable Development Web Page
http://www.wbcsd.ch/aboutus.htm
2-4. "Focusing your P2 program on zero waste." Pojasek, R.B.
(1998). Pollution Prevention Review 8(3): 97-105.
2-5. NIST Baldrige Web Site http://www.quality.nist.gov/
2-6. "New Mexico's Green Zia Environmental Excellence Program:
Using a Quality Model for a Statewide P2 Program."
Gallagher, Patricia; Kowalski, Judy; Pojasek, R.B.; and
Weinrach, Jeff. (1999). Pollution Prevention Review 9(1):
1-14.
2-7. Maintenance Technology Web Site http://www.mt-online.com/
2-8. OSHA Internet Site http://www.osha.gov
2-9. EPA Listing of State P2 Programs
http://www.epa.gov/opptintr/p2home/resources/statep2.htm
Chapter 2
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CHAPTER 3
P2 Program Elements
P2 PROGRAM PLANNING
Before planning begins, the team seeking to implement the P2 pro-
gram should consider preparing a vision statement, a mission state-
ment, and a statement of goals. If similar statements already exist for
the organization, you should see how P2 fits into these existing state-
ments. If the organization has no formal statements, the P2 program
team may wish to draft these statements to help provide some focus to
their efforts. It is important not to get side tracked on trying to differenti-
ate between vision statements, objectives, values, purpose, guidelines,
covenants, standard of performance, mission statements, core values
and guiding principles. For the purposes of talking about P2 planning,
we will adopt some simple definitions that can be modified as you see
fit.
A vision statement represents what the organization wants in terms
of P2. A mission statement identifies what the organization needs to
accomplish, in the future, in the key areas that affect P2 and its busi-
ness. A mission statement specifies an organization's purpose or "rea-
son for being." It is the primary objective toward which the organization's
plans should be aimed. The mission is something to be accomplished,
while a vision is something to be pursued. Goals establish the metrics
that will be used to measure progress. Indicators are used to measure
progress along the way. These statements and measures will help pro-
vide a good foundation for the P2 plan that your organization develops.
Some of these statements may already have been formulated in an
IS014001 effort or other EMS initiative. Planning provides an organiza-
tion with a time frame in which to ask questions related to the enact-
ment of P2 programs (see Box 3-1). Considering these questions will
encourage the proper thought and analysis for your planning effort.
Box 3-1. Questions to Consider During the P2 Planning
Process
Where are we right now?
Where do we want to go?
How do we get there?
When do we want to arrive?
Who will get us there?
What will it cost?
How do we measure results?
Who will help accomplish the plan?
When will each goal be completed?
What are the expected results?
Includes:
D P2 Program Planning
D Core Values
D Selecting Program
Elements
D Lessons Learned
D References
Before planning begins, the
team seeking to implement
the P2 program should con-
sider preparing a vision
statement, a mission state-
ment, and a statement of
goals.
A vision statement represents
what the organization wants in
terms of P2. A mission state-
ment identifies what the orga-
nization needs to accomplish,
in the future, in the key areas
that affect P2 and its busi-
ness.
Goals establish the metrics
that will be used to measure
progress. Indicators are used
to measure progress along the
way.
P2 Program Elements
-------
A key component of a P2 Plan
is the vision statement. It
provides a way of seeing or
conceiving what the organiza-
tion wants to achieve in the P2
program. The vision of the
organization usually provides a
concise word picture of the
organization at some future
time.
Vision Statement
A key component of a P2 Plan is the vision statement. It provides
a way of seeing or conceiving what the organization wants to achieve
in the P2 program. The vision of the organization usually provides a
concise word picture of the organization at some future time. This helps
set the overall direction of the organization. The vision statement de-
fines what the organization strives to be. (If you are seeking environ-
mental excellence, the criteria described in Chapter 7 may be helpful in
defining what you want to achieve.)
Sustainable development programs, like "The Natural Step," have
successfully posed a vision of the future framed by four system condi-
tions. Reviewing a vision statement from a sustainable development
program such as this can help you develop a general direction, image,
and philosophy to guide your organization in its P2 program.
It is difficult to find a perfect example of a vision statement. Several
samples are provided so you can see how others have addressed this
issue. Does your organization already have a vision statement? How
would the statement change if some element of P2 or sustainable de-
velopment were added to it?
Sample Vision Statements
At Olin, we sum up our commitment to achieving excellence in the
realms of workplace health and safety with one phrase: The Goal is Zero.
As this phrase indicates, our health and safety programs begin with the
premise that no amount of workplace injuries or illnesses is acceptable.
These initiatives not only make good ethical and moral sense, but they
respond to what our customers demand and our communities expect.
This includes operating in a safe and environmentally sound manner,
practicing good product stewardship in teaching others how to safely
and properly handle our products, and providing our employees with the
training and resources to do the right thing.
Reference: http://www.olin.com/environment/default.asp
We are dedicated to transforming DuPont into a sustainable growth
company. We will hold onto the core values that define "who we are" but
reshape our portfolio as needed to achieve growth in the new global
economy. We will intensify our efforts to reduce our environmental foot-
print by beginning the transition to renewable feedstocks and energy.
We will expand our market focus and begin to understand how we can
deliverthe miracles of science to a much greater percentage of the world's
population than we do today. And, we will strive to increase shareholder
value in a way that is less "materials and energy" intensive and more
"knowledge and service" intensive.
Reference: http://www.dupont.com/corp/environment/comment.html
The National Park Service strives to facilitate a culture of environ-
mental stewardship and sustainable development.
Reference: http://es.epa.gov/oeca/fedfac/complian/emsrcemp.pdf
Chapters
-------
The DSPS is committed to conducting all of its activities in a way
that protects human health and the environment.
In establishing environmental policies and practices the DSPS will,
as appropriate, promote the sustainable use of natural resources and
protection of the environment through conservation, recycling, and reuse
of material in its own operations.
The DSPS encourages the use of non-polluting technologies and
waste minimization in the development of equipment, products, and op-
erations. Awareness of environmental responsibilities and adherence to
sound environmental practices is encouraged.
Reference: http://www.usps.gov/environ/textmirr/webpages/envco.htmSINTRO
Mission Statement
The second component of a P2 plan is the mission statement.
This statement needs to "send forth" the people in an organization to
take P2 actions that will accomplish the vision statement. A good mis-
sion statement should include all of the essential components of an
organization's future thrust and communicate a positive feeling that will
guide others to action. Think of the mission statement as providing the
overriding purpose of P2 in the organization. An effective statement
should explain how P2 could be integrated into other business initia-
tives.
As with the vision statements above, there are many ways to ex-
press an organization's mission. Some examples are provided here to
help your organization begin the task of preparing a mission statement.
If your organization already has a mission statement, how would it
change with some P2 or sustainable development clauses added to it?
Does the P2 program 's mission reflect the mission of the organization
as a whole?
Sample Mission Statements
The Environment, Health, and Safety Program will be implemented
and maintained and will provide reasonable assurance that the corpora-
tion
• complies with all applicable governmental and internal health, safety,
and environmental requirements.
• operates plants and facilities in a manner that protects the environ-
ment and the health and safety of its employees and the public.
• develops and produces products that can be manufactured, trans-
ported, used, and disposed of safely.
• recognizes and responds to community concerns about chemicals
and our operations.
• makes health, safety, and environmental considerations a priority in
planning for all existing and new products and processes.
• reports promptly to officials, employees, customers, and the public
information on health or environmental hazards, and recommends
protective measures.
The second component of a
P2 plan is the mission state-
ment. This statement needs
to "send forth" the people in an
organization to take P2 actions
that will accomplish the vision
statement.
Think of the mission state-
ment as providing the overrid-
ing purpose ofP2 in the
organization. An effective
statement should explain how
P2 could be integrated into
other business initiatives.
P2 Program Elements
-------
Goals can be defined in action
plans prepared to help imple-
ment the P2 program.
counsels customers on the safe use, transportation, and disposal
of chemical products.
• extends knowledge by conducting or supporting research on the
health, safety, and environmental effects of products, processes,
and waste materials.
• works with others to resolve problems created by past handling and
disposal of hazardous substances.
• participates with government and others to create responsible laws,
regulations, and standards to safeguard the community, workplace,
and environment.
• promotes the principles and practices of Responsible Care by shar-
ing experiences and offering assistance to others who produce,
handle, use, transport, or dispose of chemicals.
Reference: http://www.unioncarbide.com/respcare/1998/whoweare.html
We affirm to all our stakeholders, including our employees, custom-
ers, shareholders and the public, that we will conduct our business with
respect and care for the environment. We will implement those strate-
gies that build successful businesses and achieve the greatest benefit
for all our stakeholders without compromising the ability of future genera-
tions to meet their needs.
We will continuously improve our practices in light of advances in
technology and new understandings in safety, health and environmental
science. We will make consistent, measurable progress in implement-
ing this Commitment throughout our worldwide operations. DuPont sup-
ports the chemical industry's Responsible Care® and the oil industry's
Strategies for Today's Environmental Partnership as key programs to
achieve this Commitment.
Reference: http://www.dupont.com/corp/environment/commitment.html
Statement of Goals
The third basic component of a P2 plan is the statement of goals.
Goals are specific statements that express where the organization
wishes to go within a specific time period (e.g., this financial quarter).
The quantitative measures used are absolute. Goals can be defined in
action plans prepared to help implement the P2 program. Action plans
are discussed in Chapter 4. Setting goals and objectives in a P2 pro-
gram are also addressed in Chapter 6.
Many P2 programs state quantitative and specific goals of both a
short-term and long-term nature. Sometimes the goals are set during
the initial planning period of the P2 program. In other cases, the goals
are to be set after much more information has been gathered and ana-
lyzed. Once the goals are set, it is important to measure their progress
overtime.
Some quality experts feel that goals actually tend to hold an organi-
zation back because no one ever tries to exceed the goals by a signifi-
cant amount. These people have suggested that organizations con-
stantly measure their continual improvement effort in specific areas.
Chapters
-------
Indicators
During the planning stage, many organizations start considering the
use of indicators. An indicator is a metric that helps you understand where
you are, which way you are going, and how far you are from where you
want to be. Indicators can be based at the organizational level (e.g., envi-
ronmental training hours per worker, conservation of resources, reduction
in emissions, good housekeeping, operational and maintenance practices)
or at the government level (e.g., area-wide greenhouse gas concentra-
tions, biodiversity in major rivers, acres of trees impacted by acid rain).
Indicators are used to express the outcomes of the performance improve-
ments that are made in the P2 program and are further covered in the
"results" section of the quality model presented in Chapter?. These envi-
ronmental results actually link the performance indicators with the cost to
and benefits for the organization.
Sustainable development programs use indicators that link
economy, environment, and the community. The element of commu-
nity represents both workers and the other interested parties associ-
ated with the organization. Examples of indicators are given in Box 3-2
(Reference 3-1).
Box 3-2. Examples of Indicators
• Number of people going to clinics for respiratory problems
• Ratio of renewable to non-renewable energy consumption
• Public awareness of hazardous materials/waste issues as mea-
sured by annual survey
• Tons of waste landfilled annually
• Recycling rate as a percentage of material generated
• Percentage of residents, businesses, and institutions that partici-
pate in recycling programs
• Recycled water use
• Mass of pollutants in wastewater
• Number of enterprises adopting IS014001 standards
• Number of hazardous materials incidents
• Numberof schools that integrate and progressively update environ-
mental education in their curricula
• Numberof organizations with formal pollution prevention plans
An indicator is a metric that
helps you understand where
you are, which way you are
going, and how far you are
from where you want to be.
Sustainable development
programs use indicators that
link economy, environment,
and the community.
These components of the P2 plan help determine the strategy of
the organization's P2 program. The strategy or actions decided upon
reflect the way the organization plans to achieve its objectives and goals.
Organizations should develop strategies for every goal that it plans to
implement. A good way to develop these strategies is by preparing an
action plan. This tool and other tools useful in implementing P2 pro-
grams are discussed in Chapters 6 and 7.
CORE VALUES
Because the P2 program deals with change in the organization, it
is essential that you express the core values that must be achieved as
Organizations should develop
strategies for every goal that it
plans to implement. A good
way to develop these strate-
gies is by preparing an action
plan.
P2 Program Elements
-------
Each element of the
organization's P2 program
should link itself with the
organization's core values.
This core value recognizes
what various interested parties
would like to gain from a P2
program and ensures to it that
they get what they want.
By comparing your program
with other P2 programs, your
organization's commitment to
P2 and sustainability can be
differentiated from that of the
competition.
you integrate key business requirements within a results-orientated P2
framework. These core values are also referred to as guiding prin-
ciples. They will help bridge the gap between the various components
discussed previously by identifying the fundamental, underlying beliefs
that guide the actions within the organization. All organizations have a
set of core values, although in some cases they do not exist in written
form.
Each element of the organization's P2 program should link itself
with the organization's core values. Certainly, there are no prescriptive
ways to do this. Each organization must approach these core values in
a manner that fits the local organizational culture.
Following are examples of several core values that could be re-
flected in a P2 program. Paying particular attention to how these core
values relate to the organization's core values is a very important com-
ponent of a P2 program (References 3-2, 3-3).
Interested-Party-Driven P2
This core value recognizes what various interested parties would
like to gain from a P2 program and ensures that they get what they
want. If P2 saves money, managers and shareholders will support it. If
P2 helps an organization stay in compliance, regulators will support it.
If P2 helps improve working conditions, employees will support it.
A P2 program should work to build trust, confidence, and loyalty by
not just meeting interested party requirements, but going the extra dis-
tance to reduce waste and conserve resources.
By comparing your program with other P2 programs, your
organization's commitment to P2 and sustainability can be differenti-
ated from that of the competition. This unique focus, which probably
fits well within your organization's culture, should leave the interested
parties delighted—not just satisfied—by the P2 program.
Interested Parties Include:
•••
Customers
Employees
Suppliers
• Regulators
• Public groups and non-government organizations (NGOs)
• Community Groups
Leadership
All senior leaders in the organization must create an interested-
party orientation. They must set clear and visible P2 values and have
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high expectations. These values and expectations are reinforced by a
substantial personal commitment to the P2 program. Leaders should
serve as role models throughout the organization, thus reinforcing the
P2 core values at all levels. In other words, they should "walk the talk."
Management must have active, visible leadership roles in the ongoing
strategic planning process to incorporate P2 into all business func-
tions. Leadership's commitment to environmental performance is dem-
onstrated through consistent decisions on resource allocations such
as money and employees for P2 program implementation and evalua-
tion. If the P2 program is perceived as just another environmental initia-
tive, this leadership core value cannot be realized.
Continual Improvement
Every organization must strive for continual improvement. The or-
ganization should also have a commitment to the continual elimination
and reduction of waste. These goals can be accomplished by encour-
aging creativity, maintaining a continual improvement environment, and
recognizing and rewarding employees for doing a good job. Employ-
ees at all levels and in all areas of the organization should be actively
involved and contribute ideas for P2 and P2 program improvement.
The P2 program cannot be oriented to simply completing individual
P2 projects. It must take the knowledge gained and use it to address
other P2 opportunities. This use of "lessons learned" fosters continual
improvement. The P2 program must always strive for zero waste, zero
emissions, and conservation of all resources. Zero is where continual
improvement should strive to be.
Valuing Employees
An organization's P2 success depends increasingly on the knowl-
edge, skills, innovative creativity, and motivation of its workforce. Em-
ployee success depends increasingly on being given opportunities to
learn and practice new skills. Organizations need to invest in the devel-
opment of their workforces through education, training, and opportuni-
ties for continuing growth. Such opportunities include enhanced P2
awareness and rewards for demonstrated P2 knowledge and skills.
On-the-job training offers a cost-effective way to train and better link P2
training to work processes. Education and training programs may need
to utilize advanced technologies, such as computer-based learning and
satellite broadcasts. Increasingly, training, development, and work units
need to be tailored to a diverse workforce and to more flexible, high
performance P2 work practices. These items will prepare employees
and the organization for success.
All senior leaders must set
clear and visible P2 values
and have high expectations.
These values and expecta-
tions are reinforced by a
substantial personal commit-
ment to the P2 program.
The organization should also
have a commitment to the
continual elimination and
reduction of waste.
An organization's P2 success
depends increasingly on the
knowledge, skills, innovative
creativity, and motivation of its
workforce.
Employee success depends
increasingly on being given
opportunities to learn and
practice new skills.
P2 Program Elements
-------
Designing Quality and Prevention Together
A P2 program provides an
effective process for evaluat-
ing, planning, and controlling
changes to existing products
and the design of new products
that would generate less waste
in the production process and
at the end of their useful life.
Successful organizations
charge their P2 multifunction
teams with the responsibility
for creating high-quality prod-
ucts that are inexpensive to
manufacture while using fewer
toxic materials and generating
less waste.
The P2 feedback system
must be built on objective data
and analysis, all of which are
quantitative and can be
charted over time.
The information needs to be
comprehensive and timely
enough for all levels of workers
to understand the current
performance of the P2 pro-
gram.
By building quality into products and services in the production pro-
cess, an organization reduces the need to correct problems down-
stream. This mind-set leads to prevention rather than detection. A P2
program provides an effective process for evaluating, planning, and
controlling changes to existing products and the design of new prod-
ucts that would generate less waste in the production process and at
the end of their useful life.
For years, P2 technical assistance providers have recognized the
importance of design as a means of P2 progress through a concept
called "Design for Environment." However, instead of handling this as a
separate initiative, the need for design changes must infuse all P2 ac-
tivities as a core value. Successful organizations charge their P2 mul-
tifunction teams with the responsibility for creating high-quality prod-
ucts that are inexpensive to manufacture while using fewer toxic mate-
rials and generating less waste. Whenever possible, these organiza-
tions involve key suppliers at an early stage of the new product devel-
opment in order to determine the types and constituents of wastes,
and to address potential health and safety issues. Many quality phi-
losophies work very well in P2 programs.
Long-Range Outlook
To achieve P2 goals, organizations must make long-term commit-
ments to all interested parties—customers, employees, suppliers, regu-
lators, shareholders, the public, and the community. To develop a long-
range outlook, an organization must anticipate many types of change,
including:
i
Strategic moves by competitors
Evolving regulatory requirements
Technological developments
Stakeholder expectations
Community expectations
Management by Fact
Many organizations rely on anecdotal information to indicate their
progress. In the P2 field, mountains of case histories feed this ten-
dency.
By contrast, management relies on specific, measurable data. The
P2 feedback system must be built on objective data and analysis, all of
which are quantitative and can be charted over time. Most of this infor-
mation can be gathered quite easily, with no need for sophisticated
statistical techniques. The information needs to be comprehensive and
timely enough for all levels of workers to understand the current perfor-
mance of the P2 program.
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When an organization has this information, it has positioned itself
to monitor its progress efficiently. It can then compare its performance
to that of competitive or benchmarked organizations and evaluate its
P2 action.
Partnership Development
Successful organizations build internal and external partnerships
to help them accomplish their overall P2 goals. Examples of internal
partnerships include better labor-management cooperation, employee
development, cross-training, and the creation of worker P2 teams. Some
organizations have concerted training programs and active employee
involvement. This engenders good communication between manage-
ment and workers. Employee involvement needs should be assessed
often to ensure that sufficient resources are provided to assist these
programs in their P2 efforts.
External partnerships include cooperation with customers, sup-
pliers, regulators, and other outside organizations and interested
parties. For example, hotels and hospitals can create partnerships
to improve their similar work processes and benchmark their gains
with each other. Many trade associations have created partnerships
for P2 best practices. Strong partnerships with key suppliers that
are mutually beneficial can improve cost competitiveness, quality,
and overall responsiveness, as well as minimize toxics use and
waste. Key suppliers can participate in the development and design
of shipping and packaging materials that incorporate good ergonom-
ics and reduce or eliminate other wastes. It is helpful for the exter-
nal partners to have a financial or other stake in the achievement of
the organization's goals for the P2 program.
Corporate Responsibility and Citizenship
Successful organizations always address their corporate and
citizenship responsibilities. Corporate responsibility refers to the
basic expectations of the organization and includes business eth-
ics and the protection of public health, safety, and the environment.
Corporate citizenship refers to the leadership and support of pub-
licly important purposes, such as education, environmental excel-
lence, improved industry and business practices, and the sharing
of nonproprietary P2-related information. Leadership as a corpo-
rate citizen also entails influencing other organizations, private and
public, to partner for these purposes.
Fast Response
Permits and regulatory compliance often add significant time to
organizational decision-making. Success in globally competitive mar-
kets demands ever-shorter cycles for introductions of new or improved
Successful organizations build
internal and external partner-
ships to help them accomplish
their overall P2 goals.
External partnerships include
cooperation with customers,
suppliers, regulators, and
other outside organizations
and interested parties.
Corporate citizenship refers to
the leadership and support of
publicly important purposes,
such as education, environ-
mental excellence, improved
industry and business prac-
tices, and the sharing of
nonproprietary P2-related
information.
P2 Program Elements
-------
P2 programs are composed of
a number of program ele-
ments. Different organizations
often mix and match these
elements to construct a
program that meets the intent
of their P2 vision.
products and services. Also, a faster and more flexible response to
interested parties is now a more critical requirement. Major improve-
ments in response time often require simplification of work units and
processes together with timely incorporation of P2 into the design phase
(e.g., design for environment). To accomplish this, the P2 performance
of work processes should be among the key process measures. Other
important benefits can be derived from this focus on time. Time im-
provements often drive simultaneous improvements in organization,
quality, P2, cost, and productivity. Hence, it is beneficial to integrate
response time, quality, P2, and productivity objectives.
SELECTING PROGRAM ELEMENTS
P2 programs are composed of a number of program elements.
Different organizations often mix and match these elements to con-
struct a program that meets the intent of their P2 vision. A number of
states have enacted P2 planning legislation. These acts contain a wide
variety of different planning components. More information can be found
on the CD-ROM that accompanies this Guide. In 1989, the EPA speci-
fied six program action elements that should be considered for organi-
zations seeking to prepare waste minimization programs as required
by the Resource Conservation and Recovery Act (RCRA). (See 54
Federal Register 25056-25057) This guidance was finalized on May
28, 1993 (58 Fee/era/Reg/ster 31114-31120). All organizations gener-
ating hazardous waste in the United States must certify on their mani-
fest forms that they have a program in place that meets these require-
ments. These six program elements are:
1. Provide top management support
2. Characterize the process
3. Perform periodic assessments
4. Maintain a cost allocation system
5. Encourage technology transfer
6. Conduct program evaluations
Top management support is
essential for ensuring that P2
becomes an organizational
goal.
Let's take a brief look at each of these elements. Keep in mind that
individual organizations may include additional elements in their P2 pro-
grams for their own purposes or to comply with state P2 planning re-
quirements. The number of elements used and the degree to which
each element is stressed should be a function of the group implement-
ing the P2 program in each organization.
1. Provide Top Management Support
Top management support is essential for ensuring that P2 becomes
an organizational goal. You will remember that leadership is consid-
ered to be an important core value. Most articles written on quality
programs list upper-level management support as the single most im-
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portant program element. Management should encourage employees
at all levels of the organization to identify opportunities to reduce waste
generation and promote energy and water conservation. Management
should also encourage employees to adopt the P2 philosophy in day-
to-day operations and identify new opportunities at meetings and other
organizational functions. P2 should be a process of continual improve-
ment when incorporated into an organization's policy. Ideally, a P2 pro-
gram should become an integral part of management's strategic plan
to increase productivity and quality.
Some techniques top management can use to demonstrate their
support are:
>
Serve on the P2 oversight committee and be active in ap-
proving strategic P2 goals.
Include P2 goals in business planning efforts that are inde-
pendent of the environmental program. Integration into core
business practice is key to the long-term viability of P2 ef-
forts.
Revise the compensation/merit system to recognize P2 con-
tributions.
Ensure that P2 action plans with measurable goals be put in
writing.
Commit the organization to implementing P2 action plans.
Provide training for all employees on how resource use and
production losses result from wasteful work processes.
Publicize P2 results.
2. Characterize the Process and Assess P2 Opportunities
Some P2 assessments focus on wastes being generated by a
facility's main processes. In contrast, process characterization leads
to the identification of all P2 opportunities (including those in related
ancillary and intermittent operations), not just the ones uncovered in a
limited P2 assessment or walk-through. Both resource use and loss
are considered.
An effective way to conduct process characterization is through
the use of hierarchical process maps. These maps (see Chapter 4)
can be used to analyze all processes, including ancillary and intermit-
tent operations. An organization using this assessment method can
also examine energy and water use, landscaping, commuting, noise,
odor, and other aspects of their operations. These process maps can
also be used as templates for collecting information on resource use
and the loss of resources, with the information organized by work step.
Some organizations use process maps as a means for maintaining a
resource use and loss accounting system to track the types and
amounts of resources involved, including the rates and dates they are
used or lost.
Process characterization
leads to the identification of all
P2 opportunities (including
those in related ancillary and
intermittent operations), not
just the ones uncovered in a
limited P2 assessment or
walk-through.
P2 Program Elements
-------
Process maps can also be
used to assess the costs of
resource use by work step.
These costs can then be used
to rank order opportunities for
P2 and charge back the costs
to the processes and products
that are responsible for creat-
ing the waste—a sort of inter-
nal "polluter pays" principle.
P2 assessments are used to
verify and update process
maps. As each P2 opportunity
is examined, a P2 assess-
ment can be used to gather
new information (including cost
data) necessary to support the
use of other Systems Ap-
proach problem-solving and
decision-making tools.
True costs associated with
resource use and loss will
change over time. Periodic P2
assessments can be used to
update the cost information in
the process map templates.
Process maps can also be used to assess the costs of resource
use by work step. These costs can then be used to rank order opportu-
nities for P2 and charge back the costs to the processes and products
that are responsible for creating the waste—a sort of internal "polluter
pays" principle. It is very important to focus not on the wastes, but
rather on the processes and products that are responsible for them.
Every resource used in a process represents an opportunity to con-
serve the use of that resource, and every loss or waste from a process
represents an opportunity not to generate that loss or waste.
3. Perform Periodic P2 Assessments
In the Systems Approach, P2 assessments are used to verify and
update process maps. As each P2 opportunity is examined, a P2 as-
sessment can be used to gather new information (including cost data)
necessary to support the use of other Systems Approach problem-
solving and decision-making tools.
The organization should decide the best method to use for per-
forming P2 assessments and related data gathering. Once this is de-
cided, individual processes and procedures should be reviewed peri-
odically. In some cases, performing complete resources balances for
some work steps in the process maps can be helpful. P2 assessment
teams can revisit existing process maps or prepare new ones. Pro-
cess maps from the main process can be linked to process maps of
related ancillary and intermittent operations that support these pro-
cesses. Process maps can be prepared for different products or fami-
lies of products. The end goal may be to have a complete "book of
process maps" after a number of years of periodic P2 assessments.
True costs associated with resource use and loss will change over
time. Periodic P2 assessments can be used to update the cost infor-
mation in the process map templates. Many organizations track re-
sources used and lost by a variety of means and then normalize the
results to account for variations in production rates. Each organization
should find the best method to account for the true costs of resource
use and loss in its operations.
Analyzing the cost and benefits of each P2 opportunity is an impor-
tant process, especially when the true costs of managing environmen-
tal wastes, discharges, and emissions are considered. Organizations
should establish a good method for selecting P2 opportunities to in-
clude in the P2 program each year. Assessments should support and
invigorate a P2 program. They should not be the basis upon which the
P2 program is built.
4. Maintain a Cost Allocation System
The EPA suggests that organizations track all the costs associ-
ated with resource use and loss and charge them back to the pro-
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cesses and products responsible for these costs instead of assigning
them to facility overhead. These costs include those that flow from the
general ledger, the cost of resources lost in the waste itself, and the
activity-based costs of managing the losses. When all these catego-
ries are included, it is not uncommon for a company's waste costs to
be increased by three to five times.
Not all processes and products use and lose resources equally.
Ideally, each product should bear the burden of all the environmental,
health, and safety services that it uses. Managers are encouraged to
utilize accounting systems that generate valid product costs, reflecting
the true costs involved in producing and delivering the organization's
products and ensuring proper environmental management of resources,
wastes, emissions, and discharges. This is good business because it
will avoid putting an unfair overhead burden on cleaner products; such
products can then be sold for less money or as "premium" products.
The limitations of traditional performance measurements, particu-
larly those methods related to overhead allocation, can produce
misleading or incorrect information. Whenever possible, accounting
procedures and paperwork should be simplified, eliminating non-value
adding activities while providing accurate information for decision-making
and audit requirements. They should also be consistent. Financial per-
sonnel, for example, should be using the same source data as other
personnel. Managerial accounting methods can be used like project
management methods in most organizations. Such information can
be reconciled on a periodic basis as it is allocated to products and
families of products. Further information on environmental accounting
can be found on the CD-ROM.
5. Encourage Technology Transfer
It is important for an organization to seek or exchange technical
information on P2 from other parts of the organization, other compa-
nies, trade associations, professional associations, consultants, ven-
dors, and university or government technical assistance programs. A
considerable amount of time, effort, and taxpayer money has already
been invested by public technical assistance programs and universi-
ties to research P2 alternatives for specific industries and processes.
Although it is risky to use this information as a "silver bullet" for the P2
problems faced by any particular organization, the information does
offer some potential technology options that facilities can consider when
they generate and prioritize P2 alternatives.
Organizations are encouraged to share the nonproprietary knowl-
edge they have gained in their P2 programs through trade associations
and other information clearinghouses. Many P2 award programs re-
quire the participants to share the information that was submitted in the
application for the award.
The EPA suggests that organi-
zations track all the costs
associated with resource use
and loss and charge them
back to the processes and
products responsible for these
costs instead of assigning
them to facility overhead.
Not all processes and prod-
ucts use and lose resources
equally. Ideally, each product
should bear the burden of all
the environmental, health, and
safety services that it uses.
It is important for an organiza-
tion to seek or exchange
technical information on P2
from other parts of the organi-
zation, other companies, trade
associations, professional
associations, consultants,
vendors, and university or
government technical assis-
tance programs.
Organizations are encouraged
to share the nonproprietary
knowledge they have gained in
their P2 programs.
P2 Program Elements
-------
Organizations should imple-
ment any cost-effective
recommendations identified by
their P2 program planning
efforts. They are encouraged
to conduct periodic evaluations
of P2 program effectiveness to
provide feedback and to
identify potential areas for
improvement.
6. Conduct Program Evaluations
Organizations should implement any cost-effective recommenda-
tions identified by their P2 program planning efforts. They are encour-
aged to conduct periodic evaluations of P2 program effectiveness to
provide feedback and to identify potential areas for improvement. Dur-
ing the evaluation, it is important to determine what was learned from
each P2 activity and how that information will be utilized in constructing
P2 action plans for the coming year. P2 programs can also be
benchmarked against others. Reviews can be conducted internally or
performed with an independent third party. Many companies now ac-
cept the practice of using third-party individuals because they already
are employing them in their ISO 9000 and ISO 14001 programs. The
quality model (see Chapter 7) also offers a way to measure progress
made by a P2 program and have it scored by an independent team of
trained examiners.
Other Program Elements
There may also be other elements that can be included in the
program. For example, the American Chemistry Council's (ACC) Re-
sponsible Care® Program has a "Pollution Prevention Code of Man-
agement Practices" (Reference 3-4). One of the items required in this
program is: "Inclusion of waste and release prevention objectives in
research and in design of new or modified facilities, processes, and
products." The National Pollution Prevention Roundtable has published
a white paper on facility pollution prevention planning (Reference 3-5)
that could also be helpful in finding other P2 program elements.
The ACC's P2 Code states that each member company shall have
a P2 program that shall include the following:
1. "A clear commitment by senior management through
policy, communications, and resources to ongoing reduc-
tions at each of the company's facilities in releases to the
air, water, and land, and in the generation of wastes.
2. A quantitative inventory at each facility of wastes gener-
ated and releases to the air, water, and land, measured or
estimated at the point of generation or release.
3. Evaluation, sufficient to assist in establishing reduction
priorities, of the potential impact of releases on the envi-
ronment and the health and safety of employees and the
public.
4. Education of, and dialogue with, employees and members
of the public about the inventory, impact evaluation, and
risks to the community.
5. Establishment of priorities, goals, and plans for waste and
release reduction, taking into account both community
concerns and the potential health, safety, and environ-
mental impacts as determined under Practices 3 and 4.
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6. Ongoing reduction of wastes and releases, giving prefer-
ence first to source reduction, second to recycle/reuse,
and third to treatment. These techniques may be used
separately or in combination with one another.
7. Measurement of progress at each facility in reducing the
generation of wastes and in reducing releases to the air,
water, and land by updating the quantitative inventory at
least annually.
8. Ongoing dialogue with employees and members of the
public regarding waste and release information, progress
in achieving reductions, and future plans. This dialogue
should be at a personal, face-to-face level where possible,
and should emphasize listening to others and discussing
their concerns and ideas.
9. Inclusion of waste and release prevention objectives in
research and in design of new or modified facilities, pro-
cesses, and products.
10. An ongoing program for promotion and support of waste
and release reduction by others, which may, for example,
include:
a) sharing of technical information and experience with cus-
tomers and suppliers.
b) support of efforts to develop improved waste and release
reduction techniques.
c) assisting in establishment of regional air monitoring net-
works.
d) participation in efforts to develop consensus approaches
to the evaluation of environmental, health, and safety
impacts of releases.
e) providing educational workshops and training materials.
f) assisting local governments and others in establishment
of waste reduction programs benefiting the general pub-
lic.
11. Periodic evaluation of waste management practices
associated with operations and equipment at each mem-
ber company facility, taking into account community
concerns and health, safety, and environmental impacts
and implementation of ongoing improvements.
12. Implementation of a process for selecting, retaining, and
reviewing contractors and toll manufacturers taking into
account sound waste management practices that protect
the environment and the health and safety of employees
and the public.
13. Implementation of engineering and operating controls at
each member company facility to improve prevention and
early detection of releases that may contaminate ground-
water.
P2 Program Elements
-------
14. Implementation of an ongoing program for addressing
past operating and waste management practices and for
working with others to resolve identified problems at each
active or inactive facility owned by a member company
taking into account community concerns and health,
safety, and environmental impacts."
To be truly successful, P2
requires a systematic, inte-
grated, consistent, organiza-
tion-wide approach. This
approach can be achieved
through comprehensive P2
planning.
P2 often requires the develop-
ment of awareness to accom-
plish the improvement effort.
Although you can learn from
others' P2 success stories,
real P2 success comes from
the persistent application of the
P2 philosophy and core values
in each organization's specific
environment.
LESSONS LEARNED
The creation and maintenance of a P2 Program necessitates an
overall plan. P2 does not just happen. To be truly successful, P2 re-
quires a systematic, integrated, consistent, organization-wide approach.
This approach can be achieved through comprehensive P2 planning.
A clear and understandable vision that can be made real by the organi-
zation is of primary importance for success in the program. Without a
mission, the organization can have difficulty moving toward success.
Everyone in the organization must see how he or she can contribute to
P2 success. Top leadership must begin to understand the P2 philoso-
phy and the application of the core values. Many times P2 starts with
the individual efforts of a "champion." It may catch on with a particular
process area or product group. To have it take hold organizationally, a
P2 planning effort is required.
P2 often requires the development of awareness to accomplish
the improvement effort. The building of awareness can come from train-
ing. Such training can be accomplished in a formal setting or on the
job. Some larger organizations have trained facilitators on staff who
work with the members of a team, managers as well as workers, as
they address each specific improvement effort. Smaller companies
rely on the use of P2 technical assistance providers to facilitate these
efforts with on the job training assistance and other guidance. No mat-
ter how it is accomplished, the training, either formal or informal, must
be effective and timely, and pursued continuously.
Within an organization, informal groups have their own leaders and
"rules" that determine, for example, the pace of work or the relationship
with the top management. If the informal organization and its leaders
accept a proposed change, events will proceed more smoothly; if they
oppose it, change may be nearly impossible. Identify these informal
group leaders. Get to know them and spend time listening to their opin-
ions and perspective. When you understand their needs and concerns,
you will better understand how the P2 changes you seek can be imple-
mented more effectively.
Although you can learn from others' P2 success stories, real P2
success comes from the persistent application of the P2 philosophy
and core values in each organization's specific environment. Success
is measured differently in each organization. It cannot be achieved by
simply copying others.
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When you tailor the P2 program to your organization's vision, mis-
sion, and goals, you speed its acceptance by the members of the orga-
nization. The P2 program's overall success will be ensured.
REFERENCES
3-1. Sustainable Measures Web Site
http://www.sustainablemeasures.com
3-2. Green Zia Manual
http://www.pojasek-associates.com/Services/
2001Green_Zia_Criteria.pdf
3-3. Massachusetts environmental excellence paper
http://www.pojasek-associates.com/Reprints/baldrige.doc
3-4. American Chemistry Councils Responsible Care® Web Site
http://www.americanchemistry.com
3-5. National Pollution Prevention Roundtable (NPPR) Position
Paper on Facility Planning
http://www.p2.org/inforesources/facil-pl.html
P2 Program Elements
-------
Chapters
-------
CHAPTER 4
P2 Tools
USING P2 TOOLS
P2 teams can use a variety of specialized tools to get their work
accomplished. These tools provide visual aids that are essential in com-
municating P2 information to management, workers, and other inter-
ested parties. Tools also help P2 teams gather information and provide
problem-solving and decision-making guidance to the P2 team. Finally,
by using specialized tools, the P2 team can construct an action plan
for each project covered by the program. This plan allows for consis-
tent tracking by the P2 oversight committee.
There is an endless variety of different problem-solving and deci-
sion-making tools available. Most of these tools have been used through-
out the world in a variety of quality programs for more than 50 years.
Only in the past 10 years or so have they been applied to P2 projects.
Many small organizations have learned these tools by using the Envi-
ronmental Justice manual entitled, Nothing to Waste (Reference 4-1).
Larger organizations have often learned the tools through the various
types of quality programs that have come and gone over the years. The
problem is that environmental managers are often unfamiliar with such
tools. This is beginning to change as more organizations seek to inte-
grate environmental programs into their core business practices. This
integration effort helps align the ways problems are addressed and
solved within the organization. Keeping the P2 program independent of
mainstream operations activities may limit the program's efficiency and
effectiveness.
SYSTEMS APPROACH TOOLS
An organization acts as a system that functions as a whole through
the interaction of its parts. The Systems Approach looks at the whole
organization, and the parts, and the connections between the parts.
The functionality of the parts depend on how they are connected, rather
than what they are. The parts of a system are all connected directly or
indirectly. Therefore, a change in one part affects all the other parts.
Given this interdependence, tools that address the complexity of orga-
nizations are important. There are several reasons why the Systems
Approach tools meet this need and work so well in the planning and
implementation of your P2 program.
First, processes that use resources and generate wastes do not
always provide synoptic information clearly suited for checklist-style
presentation. Instead, these processes are more than likely intertwined
with other situations such as emotional distress or political issues that
Includes:
D Using P2 Tools
D Systems Approach Tools
D Checklists
D Lessons Learned
D References
Specialized tools provide
visual aids that are essential in
communicating P2 information
to management, workers, and
other interested parties. Tools
also help P2 teams gather
information and provide
problem-solving and decision-
making guidance to the P2
team.
The Systems Approach looks
at the whole organization, and
the parts, and the connections
between the parts.
-------
The Systems Approach tools
point out how things can be
changed to conserve the use
of that resource or prevent the
waste from occurring.
The Systems Approach
provides management with a
reasonably accurate profile of
process problems.
arise within the organization—which in turn may stem from some diffi-
culty with the way things work (or don't work). Because of these en-
tanglements, too much time and energy may be spent trying to under-
stand the situation before ever getting on to the problem-solving stage.
Systems Approach tools can help.
The Systems Approach tools cut through such situations. They
facilitate problem solving by allowing the workers to understand why a
regulated or expensive resource is being used or a waste is being
generated. These tools point out how things can be changed to con-
serve the use of that resource or prevent the waste from occurring.
This is fundamentally different from having the environmental coordi-
nator or external assistance provider suggest a way to change the
process without involving the workers in decision-making.
The Systems Approach relies on intra-organizational teams, not
individual experts, to make decisions. It requires team members to
analyze a resource or waste problem thoroughly, determine the under-
lying root cause, and generate possible alternatives. Based on this,
the problem solvers can make an objective, rational, comparative evalu-
ation. This is not to say that the team should not use the proper exper-
tise as a resource to their work. It should. However, responsibility for
decision-making should rest in the hands of team members who will
implement and evaluate the proposed measures.
Because the Systems Approach is interactive and based on work-
ers' own decision-making efforts, team members feel they "own" a
portion of the analysis. Of course, employees have preferences and
different points of view, and because the Systems Approach tools are
"team-friendly," they allow for this. This involvement is important be-
cause an answer imposed from outside is less likely to work than one
arrived at within the organization.
Another consideration is the overall management process in the
organization. It is important to identify the process-related reasons for
resource use and loss before you can convince a manager to change
the process to avoid them. In this context, the Systems Approach pro-
vides management with a reasonably accurate profile of process prob-
lems. It makes clear that, unless the problems are corrected, these
and similar problems are likely to recur. Effective planning, including
the revision of current strategies and policies, benefits from the use of
the Systems Approach.
Checklists do have a place in P2 programs. Throughout the Sys-
tems Approach, it is useful to make lists of questions and answers for
anything related to each of the tools. Such lists form an outline of the
entire problem situation and are important entries in any record of the
process. Some sample checklists can be found on the CD-ROM that
accompanies this Guide.
-------
Using the Systems Approach Tools
Many organizations are finding they have to adapt to survive in the
global economy. Managers are learning new ways to run their organi-
zations, and workers are learning how to contribute their knowledge to
improving processes. By learning how to monitor, control, and con-
stantly improve production and various supporting systems, organiza-
tions are better able to provide their customers and other interested
parties with what they want, when and how they want it. These busi-
ness practices lead to better decisions for the interested parties and
for the organization—workers and managers alike.
The principles of quality improvement can be useful tools for achiev-
ing environmental excellence. Just as defect prevention is better than
the "find and fix" approach to quality control, P2 is preferable to "end-of-
pipe" control. The application of the quality improvement tools used by
the Systems Approach is a powerful force in eliminating environmental
inefficiencies and preventing pollution.
Process Mapping
Getting to know more about the uses and losses of resources in a
process and clarifying all that you already know are the two basic tasks
of process characterization. These tasks involve information gather-
ing, listing, sorting, and comparing.
Process characterization is the step where the bulk of your learn-
ing about the process takes place. This is where your existing systems
knowledge regarding the process is revealed and organized and where
new knowledge comes easily because the process-mapping tool makes
all process relationships "visible." You will find that you no longer need
to restrict yourself to the main process. It is now possible to look at all
supporting operations—both ancillary and intermittent—to see how they
impact the main process.
Consider that every time a laboratory sample is taken to monitor a
process, the laboratory creates a waste. This waste could be prevented
if the sample were not taken in the first place. Of course, some moni-
toring is necessary and perhaps even required. This circumstance pre-
sents an opportunity to improve the efficiency of the monitoring pro-
cess. Maybe you could make an argument to the regulatory agency for
less monitoring based on your organization's compliance record. For
example, the use of sensors for continuous monitoring would offer an
alternative to traditional "grab" samples. An argument could be made
and supported by the P2 program to change the sampling, thereby
reducing the wastes produced in the laboratory.
Process characterization makes P2 opportunities visible.
Worksheets probably do not do this effectively. Diagrams are often a
better tool. Connections between all work steps help clarify the causes
The application of the quality
improvement tools used by
the Systems Approach is a
powerful force in eliminating
environmental inefficiencies
and preventing pollution.
Process characterization is
where your existing systems
knowledge regarding the
process is revealed and
organized and where new
knowledge comes easily
because the process-mapping
tool makes all process rela-
tionships "visible."
Connections between all work
steps help clarify the causes
for resource use and waste
generation.
-------
An effective means to charac-
terize processes is with a
hierarchical process map.
It has been widely recognized
that most people can only
"see" up to six objects at a
time and comprehend visually
what they mean. Hierarchical
process maps allow only three
to six objects on a page.
The assemblage process
steps constitutes a node tree
which establishes the relation-
ship and connections between
the work steps at each level.
In a Systems Approach, every
work step is connected to
every other work step in this
diagram, which depicts the
entire system.
for resource use and waste generation. Every use of a resource in a
process represents an opportunity to conserve the use of that resource.
Every loss of a resource in a process represents an opportunity to
avoid that loss. Taking advantage of these opportunities benefits every-
one in the organization. The discovery, correction, and prevention of
waste generation should be the responsibility of everyone in the organi-
zation.
An effective means to characterize processes is with a hierarchi-
cal process map (Figure 4-1). In most organizations, process docu-
mentation is typically organized into categories such as company,
facility, product line, and department. Much process documentation is
then carefully filed away in reports or databases that most people do
not review on a regular basis. This information may take the form of
process flow diagrams, flow charts, value stream maps, process and
instrumentation diagrams, machine configurations, arrow diagrams,
box diagrams, floor plans, or other schematic depictions. All of these
process characterizations suffer from complexity—too many objects
on a single page.
It has been widely recognized that most people can only "see" up
to six objects at a time and comprehend visually what they mean. Hier-
archical process maps (Reference 4-2) allow only three to six objects
on a page. The entire process must be depicted in three to six boxes.
Sub-processes can be used to provide detail at the next level but are
also restricted to the three-to-six-box rule. The assemblage process
steps constitutes a node tree which establishes the relationship and
connections between the work steps at each level. In a Systems Ap-
proach, every work step is connected to every other work step in this
diagram, which depicts the entire system. There are two very impor-
tant rules associated with process mapping:
1. The process maps must help the P2 team understand the
process better than they could through other means.
2. These same process maps must help the P2 team commu-
nicate what they plan to accomplish to management and other
interested parties.
Figure 4-2 shows examples of process maps. You can find other
examples of process maps on the CD-ROM accompanying this Guide.
Using Maps as a Template
Some organizations think of a process as a single box with its
inputs and outputs. Using this model, it is difficult to change an entire
process to make P2 happen. By using the process map as a template,
process documentation can be organized by, and linked to, individual
work steps in the process at the lowest level. All standard operating
procedures (SOPs), best management practices (BMPs), regulations,
-------
Top Level
1
^
2
3
1.1
1.2
1.3
Second Level
Node Tree Structure
1.2.1
1.2.2
1.2.3
1.2.4
Third Level
1.2.2.2
1.2.2.3
Fourth Level
Figure 4-1. Hierarchical Process Map Structure.
maintenance requirements, glossaries of terms, and material safety
data sheets (MSDSs) can be filed by work step using the process maps.
What you may find when using the process maps is that many prob-
lems are associated with a single work step. It may then be easier to
focus the P2 activity on that work step. This focus is necessary to help
P2 activities succeed in the day-to-day operation of the organization.
While many process map designers simply use pencil and paper,
hierarchical process maps can also be computerized using inexpen-
sive, off-the-shelf software commonly used to prepare organizational
charts (e.g., VISIO®). If the organization decides to computerize the
process information, everyone involved in a particular work step can
have access to all the information on that work step using an Intranet or
other electronic or hard copy means. Using process maps as a tem-
plate helps an organization keep track of resource use and loss by
each work step in a main process, or in supporting ancillary and inter-
mittent processes.
All resources (e.g., energy, water, and materials) can also be tracked
(Reference 4-3) on the same process map (Figure 4-3). The term non-
product use means that the resource does not become part of the
interim or final product. The term non-product loss means that the re-
source is lost in that work step as a waste, discharge, or emission.
Process losses can be classified by medium (air, water, solid waste,
spills/leaks, and accidental losses). Costs can also be tracked by pro-
Using process maps as a
template helps an organization
keep track of resource use
and loss by each work step in
a main process, or in support-
ing ancillary and intermittent
processes.
-------
Prepress
1
Press
2
kh
Postpress
3
Art/Copy Assembly
and Design Production
1.1
Graphic Arts
Photography/Image
Processing
1.2
Planographic
Platemaking
1.3
Press Make-Ready
(Preparation)
2.1
Printing
(Non-heat
Sheet-fed)
2.2
Cutting/Folding
3.1
Binding/Finishing
3.2
Glue
Paper Spray
4
Cleaning Solution,
Chemical Storage
Film Containers
Wash Developer
Water Fixer
,
i
Plates Water
Developer,
Gum Arabic
Art/Copy Assembly
and Design
1
4
Waste
Paper
Production
1
Graphic Arts Photograghy/
Image Processing
1.2
1 1 I 4 1
VOCs Used Film, ^ Dirty Used
Rinse Spent Rags, Plates
Water Developer Empty
Planographic
Platemaking
1.3
4
Rinse
Water
4
Spent
Developer
and Fixer, Containers
Silver, VOCs
Figure 4-2. Hierarchical Process Maps.
-------
Gloves 1
1 Water
III
Mixing Solutions
(fixer and developer)
1-1-a1
Solution t.
Aprons
1
Filling Solution
Barrels
1-1 -a2
Wastewater
Dirty Spilled
Aprons, Solution
Gloves
rr
Spilled Dirty
Solution Aprons
Glass
Cleaner
Rags
I Lubricant I
Camera/Processor
Maintenance
I
Waste Dirty Rags
Cleaner
Dirty
Washwater
Washwater
Recycling Unit
Clean
Washwater
Spent Fixer
Containing
Silver/Mercury
^
Silver Recovery
Unit
1-1-d
Silver,
Mercury
T Sludge T
Silver Wastewater
Spent
Fixer
Figure 4-2. Hierarchical Process Maps (continued).
Non-product Resource Use
1
Throughput In
WORK STEP
Interim/Final Product
Non-product Resource Loss
Figure 4-3. Using the Process Map as a Resource Accounting Template.
-------
Gathering accurate cost
information is important for
justifying investment in P2
alternatives.
cess work step. Spreadsheets can be linked to the objects in a com-
puterized process map, as well as to word processing files. Keeping
track of this information is useful for helping rank-order P2 opportuni-
ties by cost. This can all be accomplished using your organization's
charting software.
Determining the Cost of the Loss
Gathering accurate cost information is important for justifying in-
vestment in P2 alternatives. This cost typically needs to be collected
by work step because this is where the P2 will be applied. There are
three types of costs that should be tracked:
1. General ledger costs
2. Cost of the lost resources
3. Activity-based costs associated with the management of the
non-product loss
For each loss identified in the process map, the P2 team should
examine the "chart of accounts" to see if the cost is tracked by the
accounting department in the general ledger. For example, if an organi-
zation generates solid waste, there may be a cost for the disposal
contractor in the general ledger. The chart of accounts provides a ven-
dor number and/or other code for this payment category. It is important
to remember that the general ledger typically tracks only money that
goes in and out of an organization (i.e., payment for invoices and pay-
roll and revenues or financial allocations). It does not track internal trans-
actions (e.g., environmental coordinator preparing a permit). These in-
ternal transactions are activity-based costs that will be discussed in
more detail below. All cost data obtained from the general ledger is
quite accurate and does not involve estimates of any kind.
A second cost category is associated with the cost of the resources
that become non-product outputs or process losses. For example, when
a part is spray painted, some of the paint does not end up on the part.
This overspray is probably captured on a paint filter in the ventilation
system. If 60% of the paint is incorporated on the part (i.e., interim
product in throughput), 40% of the paint is lost from the work step (i.e.,
non-product loss). The cost of this lost paint should be added to the
general ledger cost associated with this loss along with the cost of the
paint filters (i.e., the intent of purchasing the filters was only to dispose
of them after they captured droplets of paint, preventing these drops
from getting into the air handling/treatment system). The plastic bags
in the wastebaskets in your office represent a similar case. Your build-
ing management firm purchased those plastic bags intending to throw
them away, thereby making the custodian's job easier. The cost of all
the bags that are purchased must be added to the cost of your solid
waste disposal bill along with the estimated cost of everything else that
you purchased and threw away in that wastebasket.
-------
To obtain the cost of the losses, it is often necessary to confer with
the purchasing department. Some of these costs are estimated since
they may be split between product and loss, such as in the paint ex-
ample. Sometimes you throw away a container included in the cost of
the product inside the container. Of course, because estimates are
less accurate than the general ledger costs, you may want to estimate
conservatively to maintain the credibility of your analysis.
A third cost category is associated with the activity-based cost of
managing the loss. If the loss is regulated (e.g., hazardous air pollut-
ant, hazardous waste, or wastewater priority pollutant), there are a num-
ber of activities that may be required by the regulations. You first must
determine all the activities that must be performed for the non-product
losses from each work step at the lowest level in the process map.
Then you must estimate the cost associated with each of these activi-
ties. The total activity-based cost associated with each loss is added to
the total cost of the loss associated with the general ledger cost and
the cost of the lost resources.
Often the cost of a non-product loss will triple when adding the cost
of the lost resource (i.e., the second cost category above). If the loss is
regulated, the activity-based cost of managing the loss may increase
this composite cost to five times the original general ledger cost. Obvi-
ously, there are large variations in the true cost of the non-product losses.
However, capturing all the cost components is necessary because if
the loss can be prevented, all of this money is saved, not just the gen-
eral ledger cost of the loss.
Selecting P2 Opportunities
Information gathered in the process-mapping phase of the P2 pro-
gram can be used to select P2 opportunities on which to focus for
problem solving and decision-making. This is generally more useful
than relying solely on a walk-through or other P2 assessment. How-
ever, walk-throughs using process maps are essential to the proper
verification of the information in the maps. Some P2 programs target
opportunities by trying to eliminate costly compliance issues associ-
ated with the use or loss of regulated materials. Other P2 programs
seek to address targets that have been pre-selected by management
or environmental personnel. Each organization has its own means for
selecting P2 opportunities. However, there is a tool that can be used to
help the P2 team through this process.
If all the P2 opportunities identified in the process maps were ar-
ranged in order of their true cost to the organization, you would find that
20% of the P2 opportunities provide approximately 80% of the cost ben-
efits. Conversely, the remaining 80% of the P2 opportunities provide
20% of the true cost benefits. In most cases, you will find the 80/20 rule
(also called the Pareto Principle) to be a great guide for selecting P2
opportunities (Figure 4-4). Most organizations use Pareto analysis in
Often the cost of a non-
product loss will triple when
adding the cost of the lost
resource (i.e., the second cost
category above). If the loss is
regulated, the activity-based
cost of managing the loss may
increase this composite cost
to five times the original
general ledger cost.
Capturing all the cost compo-
nents is necessary because if
the loss can be prevented, all
of this money is saved, not
just the general ledger cost of
the loss.
If all the P2 opportunities
identified in the process maps
were arranged in order of their
true cost to the organization,
you would find that 20% of the
P2 opportunities provide
approximately 80% of the cost
benefits.
-------
10t
9
8
$
5
4
3
2
1
J1L
_rn_
B
C D E F
Non-Product Losses
H
Figure 4-4. Pareto Diagram Showing True Cost Versus
Waste Type.
Pareto analysis helps identify
the most obvious opportunities
for improvement in present
operations.
some aspect of their work (Reference 4-4) to help focus their efforts.
This tool dates back to 1897 and has the greatest staying power of any
of the tools presented in this Guide.
Quality improvement experts advise concentration on the "vital
few" sources of problems and avoiding distraction by those of lesser
importance. The term for this process is called rank ordering. Pareto
analysis is a rank-ordering tool. However, the fact that you have
rank ordered your P2 opportunities does not mean you shouldn't
address the easier opportunities early on. Early in a P2 program,
projects must be carefully selected to ensure the greatest chance
of success. P2 teams may be tempted to immediately tackle
projects that are too large or too diffuse for them to handle. Too
often, these projects may seem necessary to gain and maintain
management approval for the P2 program. The resulting frustration
only dampens enthusiasm for the prevention effort. Avoid bogging
down in P2 opportunities that offer minimal cost benefits. Instead,
focus your long-term efforts on the 20% where the true cost sav-
ings may be found. This approach maximizes the value of the P2
program to the organization. Pareto analysis helps identify the most
obvious opportunities for improvement in present operations.
It is interesting to note that focusing on wastes by volume or weight
may cause the P2 team to overlook some important wastes. In some
cases, small volume wastes may be responsible for the highest costs.
An example of this involves laptop computers that become contami-
nated when used in radiologically controlled areas. Contaminated laptops
represented only a very small volume of the mixed radioactive waste
-------
from a National Laboratory in the United States. However, the cost of
disposal was the highest of all the items considered in the analysis.
Other examples of the use of Pareto analysis are presented on the
CD-ROM that accompanies this Guide.
Analyzing Root Causes
"Root cause" is the basic reason that a resource is being used or a
process loss is occurring. If this cause can be eliminated, the resource
use or loss would be prevented. This approach is the very basis of P2.
Root cause analysis refers to the process of identifying causal fac-
tors. Most people involved in P2 are ardent problem solvers, but in their
haste to get to a solution, some may skip over this very important prob-
lem-solving activity. P2 teams which skip this important step may sim-
ply take the most obvious action, rather than the one that would best
solve the problem.
For example, when faced with environmental problems caused by a
toxic chemical, P2 "problem solvers" might initially assume that the best
way to address the issue is to find a "safe" substitute. In fact, the problem
may be caused by /?owthe company is using the chemical, rather than by
the chemical itself. Changing work procedures or equipment or training
employees more effectively might offer a better and/or less costly solu-
tion. Root cause analysis teaches organizations to look at all potential
causes: materials, technology, work practices, and people.
Root cause analysis can be an effective management tool for de-
termining the true or actual cause of resource use or loss in a process,
facilitating effective corrective action, and preventing recurrence of the
problem. It also provides obvious opportunities for improvement since
it identifies both the underlying reasons for problems and the obstacles
to correcting them.
The cause and effect diagram (also known as a fishbone diagram)
provides an effective tool for conducting root cause analysis (Reference
4-5). Studies have found that this tool is the most widely used problem-
solving tool in the world. However, it takes a little training and experience to
use this important tool effectively. This tool is to be used by the P2 team,
not by individuals. It provides a useful graphic to explain to management
and other interested parties exactly what may be causing a problem. Once
the diagram has been completed, the P2 team can count the number of
causes found. The 80/20 rule can be used to help focus on the most
probable causes by drawing circles around the 20% of the causes that
may account for 80% of the problem. The P2 team will be more effective if
it has this understanding and focus before attempting to generate P2 alter-
natives. An example of a cause and effect diagram can be found in Figure
4-5. Other cause and effect diagrams are included on the CD-ROM that
accompanies this Guide.
Root cause analysis teaches
organizations to look at all
potential causes: materials,
technology, work practices,
and people.
The cause and effect diagram
(also known as a fishbone
diagram) provides an effective
tool for conducting root cause
analysis.
-------
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-------
Generating Alternative Solutions
Every P2 approach has some method of deriving alternatives for
solving the P2 problem. Some P2 practitioners restrict themselves to
only a small number of P2 alternatives for a given problem because
they have not performed root cause analysis (and thus may lack key
information) or because the P2 team members are not adequately in-
volved in the process of deriving alternatives. P2 literature (i.e., case
studies and success stories) provides only some ways to address each
problem. An expert may offer limited tried-and-true solutions. Your
organization's P2 team should feel confident that it may develop equally
effective alternative ways to address the situation.
The Systems Approach operates on the theory that "the only way
to find a good P2 alternative is to have many P2 alternatives." A good
method for generating alternatives is "brainwriting," a technique similar
to brainstorming, but tends to be less restrictive (Reference 4-6).
Brainwriting is a written form of brainstorming that uses forms like that
shown in Figure 4-6. It takes advantage of the fact that many people are
much more likely to write down their ideas than say them. This
brainwriting technique allows resource people (i.e., those not on the P2
team, vendors, or technical assistance personnel) to lend their exper-
tise in generating alternatives. Brainstorming is a very widely used tool
for generating alternatives. Some organizations use a tool known as an
affinity diagram. No matter what your preference, the quantity of alter-
natives is what counts. Experience has shown that brainwriting is often
The Systems Approach
operates on the theory that
"the only way to find a good P2
alternative is to have many P2
alternatives."
10
Figure 4-6. Form Used for Brainwriting Exercise.
-------
Employing worker knowledge
and a little creativity has led to
many successful P2 projects.
able to help the P2 team generate as many as 18-40+ alternatives in a
short period of time.
To help encourage P2 team members to "think outside the box," it
is important to get each team member to express the "most outra-
geous alternative that just might work." This gets everyone involved in
using a bit of creativity to address the P2 problem at hand. Even "wild"
concepts may trigger a search for alternatives that are a bit unusual
but could work in the case under consideration. This technique is called
"provocation." Employing worker knowledge and a little creativity has
led to many successful P2 projects.
See Figure 4-7 for a listing of brainwriting alternatives for a com-
mon problem. Other examples of brainwriting alternatives can be found
on the CD-ROM that accompanies this Guide.
Install a closed-loop (fully recycling) system.
Fully automate the system to control drive speed.
Use water-saving nozzles.
Wash less frequently.
Put dehumidifier in room to collect water vapor.
Use high-pressure jet spray (rinse/clean in one step).
Redesign water application.
Hand wash.
Reduce evaporation by lowering room temperature.
Try to collect evaporated water.
Use multistage washing process.
Only use undercarriage spray in winter.
Only wash vehicle once a week.
Dip vehicles in a tub-like device.
Lower temperature of water to decrease evaporation.
Use drying apparatus so vehicles do not drip dry.
Use a switch to activate/deactivate each step.
Close garage door before starting washing process.
Spit shine.
Use a squeegee to scrape off excess water.
Change soap application method.
Use alternative to city water source.
Use fewer absorbent sponges (less water trapped).
Use rental cars (rental agency will wash).
Redesign collection of water.
Drive through faster.
Figure 4-7. Brainwriting Alternatives for an Automated Vehicle
Cleaner.
The bubble-up/bubble-down
tool is an excellent means for
prioritizing and selecting an
alternative to implement from a
long list of possibilities.
Selecting an Alternative for Implementation
Selecting a P2 alternative for implementation is facilitated with de-
cision-making tools such as a criteria matrix (also known as a selec-
tion grid) or bubble-up/ bubble-down (also known as forced pair analy-
sis). These are prioritization tools. The bubble-up/bubble-down tool in
particular is an excellent means for prioritizing and selecting an alter-
native to implement from a long list of possibilities (Reference 4-7).
When using this tool, the P2 team is allowed to examine only two alter-
natives at a time. They must ask which is best and use general criteria
-------
such as the effectiveness of the alternative, the ability to implement the
technique, and the cost associated with that implementation. This
method of discussing the various alternatives is very interactive. Other
tools do not allow for a lot of verbal communication among P2 team
members. This communication leads to more information that will ulti-
mately help facilitate implementation of the selected alternative.
Alternatives that "bubble up" to the top are typically easy to imple-
ment and have a relatively low cost. These alternatives may be charac-
terized as the low hanging fruit or quick wins. Little or no capital is re-
quired to implement these alternatives and work can begin right away
in most cases. If good cost data is collected, these "quick wins" can
generate savings that can be reinvested by the organization to create
more prevention and value. Alternatives that currently fall below the
grouping of quick wins are generally more effective at preventing re-
source use and process losses. However, they may require more study
and capital investments. Since it will take time to test and study these
alternatives in an engineering feasibility study (See Waste Minimiza-
tion Opportunity Assessment Manual, EPA/625/7-88/003 and Facility
Pollution Prevention Guide, EPA/600/R-92/088 on the CD-ROM for more
information on conducting a feasibility study), the P2 team can be work-
ing on the problem with the higher ranked, albeit less effective, alterna-
tives. The results of the feasibility study will be useful for preparing a
capital justification request to use the more effective alternative at a
later time. Continual improvement can be maintained in a P2 program
in this way.
The alternatives, in order of priority, are as follows:
1. Simply reduce the soap input in the car wash
2. Use high-pressure water instead of soap
3. Alter the soap application step
4. Use degradable soap
5. Install a closed-loop system
6. Use alternative cleaning materials
7. Use a local, off-base car wash
8. Use rental cars instead of owning/maintaining
9. Locally treat the water before discharge to sewer
10. Drive less, walk more, use bicycles
11. Reuse dirty/soapy water
12. Install a new/improved car wash
13. Use a softening agent to take the soap out
of the water
14. Handwash the cars
15. Use ultrafiltration to filter the water
16. Dry-clean the cars
17. Ultrasonic cleaning
18. Ablative paint for cars
19. Use dirt-colored cars
20. Paint the cars with slippery paint
21. Do not clean the cars at all
22. Buy new cars constantly
Figure 4-8. Bubble-up/Bubble-down Example.
-------
A formal action plan should be
prepared for every P2 activity
that is planned for each year
of a P2 program.
Many P2 practitioners currently use prioritization tools. One limita-
tion, however, is that they begin with a finite set of potential solutions to
choose from because they have not used a method such as brainwriting
to generate sufficient alternatives. An example of the prioritization of
the alternatives generated in the previous step may be found in Figure
4-8. You may note that alternatives can be grouped in different combi-
nations during the bubble-up/bubble-down procedure. Other examples
of the use of bubble-up/bubble-down can be found on the CD-ROM.
Action Planning
Finally, a formal action plan should be prepared for every P2 activ-
ity that is planned for each year of a P2 program (Reference 4-8). In the
rush to implement, P2 practitioners should not overlook the need to
formalize their action plans. Each action plan should list the P2 alterna-
tive that will be implemented and show the sequence of steps neces-
sary to implement the alternative. The person responsible for ensuring
that each step is completed should be indicated in the action plan.
Performance of that step must have some recognizable goal that must
be reached. A metric should be devised to measure the progress to-
ward meeting that goal and to provide a time frame for reaching the
goal or completing that step. Finally, an indication of the resources re-
quired to reach the goal should be included in the formal action plan.
A sample form for use as an action plan is shown in Figure 4-7.
Some action plan examples can be found on the CD-ROM that ac-
companies this Guide.
When P2 programs are audited on an annual basis, the auditor
can select action plans and confirm that the work indicated actually
has taken place. Periodic assessments of P2 program status depend
on information like this to serve as the basis for measuring progress.
ALTERNATIVE Date:
SELECTED:
Action
1
2
3
4
Responsible
Person
Performance
Monitoring
Technique
Completion
Deadline
Resources
Needed
Figure 4-9. Example of an Action Plan.
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CHECKLISTS
Checklists are often necessary tools for P2 programs. A checklist
helps guide an organization's activities and progress. Checklists pro-
vide important steps and method information for measuring operational
performance and effectiveness and help the organization collect and
organize data for assessing its current status and how well it is operat-
ing. It is useful to make lists of questions and answers for anything
related to each of the problem-solving and decision-making tools pre-
sented in this Guide. Such lists form an outline of the entire problem
situation and are important entries in any record of the process.
Checklists also help the P2 facilitator and P2 teams by providing
guidance for further action and indicate things to do, process compo-
nents to visit, people to see, and questions to ask. By devising a series
of checklists, the P2 team provides itself with a means to review the
entire resource use or loss problem.
Checklists are a handy way to jot down ideas as they arise for
possible use at a later date. As the checklists increase in size and
number, they can be reorganized and combined to simplify dealing with
the problem as a whole and to clarify its parts. Checklists help the team
organize the tasks and provide an overall view of the situation, its re-
quirements, attributes, alternatives, and consequences.
Here are some simple steps for deriving checklists for a P2 pro-
gram.
U Determine the purpose and intended use of the checklist.
U Perform research to ensure that the checklist covers all
requirements and asks for specific data to be recorded.
U Provide space for checking off completed steps, ideas, or
data items.
U Ask the subject matter expert to review the final draft of a
checklist to ensure that nothing of importance has been
overlooked or omitted.
U Perform revision and pilot-test the checklist before placing it
into use.
Checklists also help the P2
facilitator and P2 teams by
providing guidance for further
action and indicate things to
do, process components to
visit, people to see, and
questions to ask. By devising
a series of checklists, the P2
team provides itself with a
means to review the entire
resource use or loss problem.
P2 teams should compose checklists that complement the pro-
cess they use in their P2 program. The various components of a typi-
cal P2 effort using the Systems Approach tool are listed so that a P2
team may use checklists to achieve better results in these areas:
U Keep track of the process characterization effort, including
ancillary and intermittent operations.
U Assure proper resource accounting for uses and losses at
the work-step level.
r
-------
a Gather the true costs for each work step in the process
characterization effort.
U Gather information for rank ordering of P2 opportunities.
U Select a P2 opportunity to analyze.
U Make sure that all causes in each cause category are
considered in the root cause analysis for the selected
opportunity.
U Document the search for potential solutions and alterna-
tives.
U Gather information on each alternative to be used in the
prioritization effort.
U Document the selection of the best alternative for imple-
mentation.
U Test the completion of the action plan.
U Track the implementation of the solution and evaluate
progress.
U Test the use of each of the P2 program elements in this
process.
U Test the overall P2 program effectiveness.
The periodic use of checklists
generates a consistent means
of assessing progress.
Tools take time to master, but
they help foster skills that the
P2 team needs to characterize
the process, solve problems,
and make decisions.
The periodic use of checklists generates a consistent means of
assessing progress. Checklists should be designed to provide man-
agers and P2 team members with a tool for assessing the significant
characteristics of each step in the Systems Approach, checking the
vital "how to" of each step, and analyzing in greater detail how well the
tools are being used.
A number of checklists can be found in the CD-ROM that accom-
panies this Guide. You should be able to use and customize these
electronic documents to fit the needs of your organization.
LESSONS LEARNED
Tools take time to master, but they help foster skills that the P2
team needs to characterize the process, solve problems, and make
decisions. The repeated use of the tools makes P2 team meetings
more productive. Many people avoid the use of tools because they be-
lieve that it takes too long and the benefits are not worth the effort. The
tools lead to increased focus and questioning. P2 teams that use the
root cause analysis tool usually derive a minimum of 20 P2 alternatives
for future consideration. In contrast, teams that do not use the tool
typically limit themselves to three or four alternatives.
The more methods and tools that you have time to use, the better
the P2 program will be in the long run. Limiting tool selection can impair
the development of the P2 program.
-------
Continual improvement is important to focus the organization on
P2 success. Organizations strive to improve, but few understand the
difficulty in trying for continual improvement. Frequently, organizations
initially set percentage improvement goals beyond their reach with too
little information. P2 is based on achieving many successes overtime.
Many of the problems of organizations have evolved over many years
and cannot all be solved at one time. The organization can use Sys-
tems Approach tools to generate the information effectively and use it
to set goals during the development of the action plans. Although it is
important to focus improvement efforts on critical issues (Pareto dia-
grams), improvements can be made little by little until these major is-
sues are resolved.
Incremental improvements can lead to breakthrough improvements.
This is accomplished by learning from the improvements and seeking
to make larger improvements. Incremental improvements also allow
for "quick wins." These little victories, when accompanied by cost data,
help maintain management approval for the P2 effort. Continued fund-
ing of P2 projects also provides the time for breakthrough improve-
ments to materialize.
Checklists are useful tools for gathering information and data and
tracking progress of the problem-solving and decision-making method.
However, they are relatively ineffective at communicating that informa-
tion to management and other interested parties. Each of the Systems
Approach tools has a visual output that is much more effective in this
regard.
Making P2 a way of life in order to achieve success takes more
than words; it requires action. Action plans provide documentation for
these actions and a means of tracking P2 progress over time.
REFERENCES
4-1. Nothing to Waste Manual
http://www.pojasek-associates.com/Reprints/Nothing-to-
Waste.pdf
4-2. "Understanding a process by using process mapping."
Pojasek, R.B. (1997). Pollution Prevention Review 7(3):
91-101.
4-3. "Materials accounting and P2." Pojasek, R.B. (1997). Pollution
Prevention Review 7(4): 95-103.
4-4. "Selecting P2 opportunities." Pojasek, R.B. (1998). Pollution
Prevention Review 8(2): 103-110.
4-5. "Using cause and effect diagrams in your P2 program." Pojasek,
R.B. (1996). Pollution Prevention Review6(3): 99-105.
Organizations strive to im-
prove, but few understand the
difficulty in trying for continual
improvement.
-------
4-6. "Identifying P2 alternatives with brainstorming and
brainwriting." Pojasek, R.B. (1996). Pollution Prevention
Review 6(4): 93-97.
4-7. "Prioritizing P2 alternatives." Pojasek, R.B. (1997). Pollution
Prevention Review 7(1): 105-112.
4-8. "Implementing your P2 alternatives." Pojasek, R.B. (1997).
Pollution Prevention Review 7(2): 83-88.
-------
CHAPTER 5
Traditional Approach to P2
Implementation
INTRODUCTION
A number of models are available for implementing your P2 pro-
gram. This chapter will focus on a "traditional" model based on the
previous editions of this EPA Guide (Waste Minimization Opportunity
Assessment Manual, EPA/625/7-88/003 and Facility Pollution Preven-
tion Guide, EPA/600/R-92/088). Chapters will examine an implemen-
tation model that utilizes a formal environmental management system
(EMS). Chapter 7 will evaluate the use of a quality model for P2 imple-
mentation. This Guide will not prescribe or recommend any one of these
P2 implementation models. Instead, you can mix and match compo-
nents to derive a P2 program implementation model that works best in
your organization. If you do this, your organization's P2 program is far
more likely to be implemented and maintained. This concept will be
presented in Chapter 8.
At the top level (Figure 5-1), the traditional P2 model offers a logical
path for implementing P2. First you establish the P2 program using the
information provided. Then, you prepare a written P2 plan to describe
how the program will be implemented. Next, you execute the program
implementation. Finally, you must maintain the P2 program overtime.
ESTABLISH P2
PROGRAM
1
t
WRITE P2 PROGRAM
PLAN
2
k.
P2 PROGRAM
IMPLEMENTATION
3
^
MAINTAIN P2
PROGRAM
4
Includes:
D Introduction
D Establishing a P2 Program
D Writing the P2 Program
Plan
D P2 Program
Implementation
D Maintaining the P2
Program
D Combining the Traditional
Approach with the
Systems Approach
D Approaches for Very
Small Organizations
D Other P2 Implementation
Approaches
D Reference
You can mix and match
components to derive a P2
program implementation
model that works best in your
organization. If you do this,
your organization's P2 pro-
gram is far more likely to be
implemented and maintained.
Figure 5-1. Top-level Depiction of the Traditional Approach to
Pollution Prevention Implementation.
Traditional Approach to P2 Implementation
-------
ESTABLISH P2
PROGRAM
1.1
ORGANIZE P2
PROGRAM
1.2
CONDUCT
PRELIMINARY P2
ASSESSMENT
1.3
The traditional approach has a
"top-down" focus.
The traditional approach views
the preliminary assessment as
a "walk-through" activity to be
performed by a team of em-
ployees or by an outside
service provider or process
expert.
The Systems Approach
described in Chapter 4 of this
Guide allows for some "bot-
tom-up" efforts before the
endorsement of senior man-
agement.
These ideas show how you can
organize this part of the P2
program using the tools pre-
sented in this Guide.
Figure 5-2. Establishing a P2 Program.
Let's look at the details in each of these steps to see how the infor-
mation in this Guide can ease the implementation using the traditional
approach to P2.
ESTABLISHING A P2 PROGRAM
The traditional approach has a "top-down" focus. This approach,
as presented in the earlier EPA publications (Figure 5-2), begins with
getting management approval and setting program goals before P2
information is collected. The first step is to obtain an executive-level
decision to establish the P2 program. This decision is communicated
to the workforce using a policy statement. Consensus-building efforts
will promote acceptance of this policy statement.
To organize the P2 program, management names a P2 task force
and states goals before any formal information is gathered. Goals that
are established upfront for a P2 program challenge the effort.
Under the traditional approach, the task force next conducts a prelimi-
nary P2 assessment to collect some P2 data, reviews sites for future P2
studies, and establishes the priorities for the P2 program. A preliminary
assessment is necessary to gather information for the written P2 plan
(Figure 5-2, work step 1.3). Some organizations may consider conduct-
ing this preliminary assessment prior to work steps 1.1 and 1.2 (see Fig-
ure 5-2). The traditional approach views the preliminary assessment as a
"walk-through" activity to be performed by a team of employees or by an
outside service provider or process expert.
The Systems Approach described in Chapter 4 of this Guide al-
lows for some "bottom-up" efforts before the endorsement of senior
management. Using the process-mapping tool described in Chapter 4
of this Guide gives the team a more complete understanding of the
processes (including the ancillary and intermittent processes). This
leads to a more complete listing of opportunities for P2. Pareto analy-
sis can be used to rank order the opportunities for P2. The organiza-
tional management can then propose goals based on a more com-
plete assessment of the P2 opportunities and establish clear priorities
for the program. Goals could be stated in the action plans for each year
instead of as program goals. These ideas show how you can organize
this part of the P2 program using the tools presented in this Guide.
-------
WRITING THE P2 PROGRAM PLAN
The traditional approach next addresses writing the P2 program
plan (Figure 5-3). A good planning effort makes careful note of what the
stakeholders want in the program. These are the interested parties or
external groups described in the quality-based implementation model
(see Chapter 7). Stakeholders may include the following: customers,
suppliers, employees, regulators, environmental interest groups, com-
munity organizations, stockholders, and anyone else with a stake in
the outcome of the P2 program.
The P2 plan should state clear objectives for the P2 program. It
should anticipate obstacles to program implementation and plan means
to overcome them. A good planning effort addresses these obstacles
during the preparation of the plan. Finally, the P2 plan requires a firm
schedule. It can be a challenge to set a schedule based solely on the
information gathered to this point, but a schedule is essential for man-
agement to track the plan's progress during the course of the year.
WRITE P2 PROGRAM PLAN
Consider External Groups
Define Objectives
Identify Potential Obstacles
Develop Schedule
Figure 5-3. Writing the P2 Program Plan.
Stakeholders may include the
following: customers, suppli-
ers, employees, regulators,
environmental interest groups,
community organizations,
stockholders, and anyone else
with a stake in the outcome of
the P2 program.
The P2 plan should state clear
objectives for the P2 program.
A schedule is essential for
management to track the
plan's progress during the
course of the year.
Earlier in this Guide (Chapter 4), action plans were described. The
action plan is a tool that can be used to address all the concerns that
can arise when writing a P2 program plan. Each organization should
have an action plan for each P2 project conducted in the P2 program.
The collection of these action plans (many organizations implement 8
to 11 P2 action plans in a typical year) constitutes the major portion of
the P2 plan. The other part of the P2 plan outlines the management
structure within which these plans will be used and reviewed during the
course of the year. The objectives of the program should reflect the
vision and mission statements for the P2 efforts.
Each organization should have
an action plan for each P2
project conducted in the P2
program.
P2 PROGRAM IMPLEMENTATION
In the traditional approach the detailed P2 assessment is the start-
ing point of the program implementation phase (Figure 5-4). An as-
sessment team is assembled for this task. It is not defined as a worker
team but rather as a higher-level, multidisciplinary team which may
In the traditional approach the
detailed P2 assessment is the
starting point of the program
implementation phase.
Traditional Approach to P2 Implementation
-------
PERFORM DETAILED
P2 ASSESSMENT
3.1
Name Assessment Team(s)
Review Data and Site(s)
Organize and Document
Information
WRITE P2
> ASSESSMENT
REPORT 3.4
Input of Assessment Teams
Prepare and Review Report
Present to Management
DEFINE P2
ALTERNATIVES
3.2
Propose Alternatives
Screen Alternatives
IMPLEMENT P2
PLAN
3.5
Select P2 Projects
Obtain Funding
Initiate Alternative
Review and Adjust
CONDUCT P2
FEASIBILITY
ANALYSIS 3.3
Technical Feasibility
Environmental Feasibility
Economic Feasibility
MEASURE P2
PROGRESS
3.6
Acquire Data
Analyze Data
Measure Economic Results
Figure 5-4. P2 Program Implementation.
The purpose of the detailed
assessment is to help the
team derive alternatives.
Based on the detailed assess-
ment, the assessment team
proposes a number of P2
alternatives and screens them
to help focus on the imple-
mentation that will follow.
Once the P2 projects have
been selected, the traditional
approach has the P2 team
obtain funding and initiate work
on the alternative.
include some employees. Checklists and worksheets are provided to
help the team collect data and information. This assessment team will
review the data and visit the sites where the P2 activity is planned to
occur.
The purpose of the detailed assessment is to help the team derive
alternatives (called "options" in the previous publications) for P2. The
team uses brainstorming as a tool to find potential alternatives. The
traditional approach does not formally include root cause analysis be-
fore deriving alternatives.
Based on the detailed assessment, the assessment team pro-
poses a number of P2 alternatives and screens them to help focus on
the implementation that will follow. Most of the P2 industry-specific
manuals provided a limited number of alternatives, so the screening
was fairly straightforward. The traditional approach model uses criteria
matrices for screening. Once screening is complete, it is time for a
feasibility analysis of the priority alternatives. Of course, not all P2 al-
ternatives require such formal analysis. Quick wins or "low-hanging
fruit" P2 alternatives can proceed more expediently. They do not com-
pete for capital funding. When an alternative requires some capital fund-
ing to implement, it is frequently subjected to a technical feasibility study,
a determination of its environmental feasibility, and finally a determina-
tion of the economic feasibility. At this point, the traditional approach
requires the preparation of a formal, written P2 assessment report.
This report details the analysis of the P2 assessment team and allows
that information to be presented to management in a formal manner
after a review by the P2 task force. Once the P2 projects have been
-------
selected, the traditional approach has the P2 team obtain funding and
initiate work on the alternative. The work is reviewed and adjusted dur-
ing execution to make sure it meets the objectives. There is no require-
ment in the traditional approach to prepare a formal action plan. The P2
implementation team reviews its progress on an informal basis and
makes necessary adjustments to enhance the P2 effort.
The final step in the traditional P2 program implementation is to
measure P2 progress. Data is acquired from the implementation phase
and analyzed. The traditional approach recommends the measurement
of economic results.
MAINTAINING THE P2 PROGRAM
At this stage, the traditional approach shifts to the maintenance of
the P2 program (see Figure 5-5). Five activities are detailed in this pro-
gram component.
This program maintenance begins with the integration of the P2
program into other formal corporate P2 initiatives. These programs could
include safety, quality, preventive maintenance, lean manufacturing, and
so on. Accountability for wastes are assigned to the generating pro-
cess. All wastes are carefully tracked and formally reported in the orga-
nization. The program results are evaluated annually.
Educational training for those who participate in the P2 program
needs to be specified. No tools are taught in the traditional approach;
however, the participants do become familiar with the process. Train-
ing is provided to new employees to orient them to P2. Advanced train-
ing is provided to those most involved with the P2 program. Each year,
every employee needs to be updated on knowledge of P2.
At this stage, the traditional
approach shifts to the mainte-
nance of the P2 program.
Program maintenance begins
with the integration of the P2
program into other formal
corporate P2 initiatives.
Educational training for those
who participate in the P2
program needs to be specified.
INTEGRATE P2 INTO
CORPORATE PLAN
4.1
STAFF EDUCATION
4.2
MAINTAIN INTERNAL
COMMUNICATION
4.3
Assign Accountability for Waste
Tracking and Reporting
Annual Program Evaluation
New Employee Orientation
Advanced Training
Retraining
Two-Way Communication
Solicit/Follow Up on Suggestions
EMPLOYEE REWARD
PROGRAM
4.4
PUBLIC OUTREACH
AND EDUCATION
4.5
Performance Reviews
Recognition Among Peers
Material Rewards
Figure 5-5. Maintaining the P2 Program.
Traditional Approach to P2 Implementation
-------
The traditional approach looks
at all routine communications
and finds ways to encourage
them.
The traditional approach
recommends a public out-
reach and educational pro-
gram.
The Systems Approach tools
presented in this Guide can be
used to enhance the effective-
ness of the traditional ap-
proach.
Another potential improvement
is in the use of root cause
analysis to examine why a
selected P2 opportunity has a
problem associated with the
use of a regulated material or
a regulated loss.
Communication is important to any program. The traditional ap-
proach looks at all routine communications and finds ways to encour-
age them. It also promotes the solicitation and follow-up of employee
suggestions.
As an incentive for participation in the P2 program, the traditional
approach includes an employee reward program. It features perfor-
mance reviews, recognition among peers, and material rewards. Fi-
nally the traditional approach recommends a public outreach and edu-
cational program.
More information on the traditional approach, including copies of
the previous EPA publications, can be found on the CD-ROM that ac-
companies this Guide. All the checklists and worksheets from the tra-
ditional approach are provided on that CD-ROM.
COMBINING THE TRADITIONAL APPROACH WITH THE
SYSTEMS APPROACH
Many of the readers of this Guide have been using the traditional
approach for years. The process maps provided here and in Chapter 1
should help you use this approach more effectively. You may have be-
gun to consider changes you might make to the approach that will
work well for you. It is instructive to prepare a process map of your
approach to P2 so everyone in your program can understand it clearly.
The Systems Approach tools presented in this Guide can be used
to enhance the effectiveness of the traditional approach. One area
where improvement can be made is in the process characterization. It
is easier for management and team members to "see" the process
maps. Having piles of information and checklists to review can be far
more daunting. The process maps also enable the team to focus on
certain areas that offer the best opportunities for P2.
Process mapping can be conducted by those interested in pro-
moting P2 before going to management for commitment to the pro-
gram. It may be a wise decision to let them understand what opportu-
nities await them if they approve this program. Process maps will typi-
cally find more opportunities for P2 than a walk-through or preliminary
assessment.
Another potential improvement is in the use of root cause analysis
to examine why a selected P2 opportunity has a problem associated
with the use of a regulated material or a regulated loss. Experiments
have been conducted with P2 teams to test the theory that root cause
analysis will lead to better alternative generation. A team that does not
use root cause analysis and goes directly from the selection of the P2
opportunity to the generation of alternatives typically is capable of speci-
fying two to four alternatives. In contrast, a team that uses root cause
analysis first and then tries to generate alternatives will come up with
-------
18 to 40+ alternatives. Many of the alternatives derived in the former
case may not finish in the top-10 listing after the longer list of alterna-
tives is prioritized. The cause-and-effect diagram is the most widely
used problem-solving tool in the world. It deserves consideration in the
implementation of your P2 program.
The issue of goal setting is very important in P2. The traditional
approach sets goals up front. Many state-mandated P2 programs also
set statewide goals at the start of the program. In the Systems Ap-
proach, the organization sets performance goals in the action plans
after the information on P2 has been gathered and evaluated. They are
set year-by-year and project-by-project. The sum of all the action plan
performance goals is the overall performance goal of the year. Some
quality experts believe that goal setting is rarely done properly. They
argue that one should measure continual improvement and always in-
crease the amount of P2 accomplished, no matter how small they may
be. There should also be no backsliding in areas in which improve-
ments have already been made. This sort of seemingly incremental
improvement can yield large breakthroughs as P2 program participants
learn how to master change.
The basics of the traditional approach can be integrated with the
lessons of the Systems Approach. They work well together and allow
the organization to make continual improvement in the conduct of the
traditional P2 program.
APPROACHES FOR VERY SMALL ORGANIZATIONS
One argument for retaining the traditional approach exclusively was
that it worked well for very small organizations. The tools of the Sys-
tems Approach were sometimes thought to take too long to use and to
be too difficult for very small organizations to master. Some observers
thought that these organizations would have to rely on outside P2 tech-
nical assistance providers to help them with P2 alternatives.
The following case study illustrates how the Systems Approach
could be used by small organizations to complement the use of the
traditional approach. Use of this Systems Approach does not rule out
the traditional approach, but illustrates how the tools that are presented
in this Guide might increase the effectiveness of the traditional approach.
EPA funded the development of a publication called Nothing to
Waste (Reference 5-1) for its Environmental Justice program. This pub-
lication uses the Systems Approach for dealing with very small busi-
nesses. A model for helping very small organizations succeed was
developed by a team lead by a not-for-profit group, Working Capital.
They formed groups of leaders of very small organizations who met on
a regular basis outside of working hours. A facilitator helped them work
through some modules that taught them how to write a business plan
and how to apply for a loan. Banks provided the groups with money to
The cause-and-effect diagram
is the most widely used prob-
lem-solving tool in the world.
The issue of goal setting is
very important in P2.
This sort of seemingly incre-
mental improvement can yield
large breakthroughs as P2
program participants learn how
to master change.
The basics of the traditional
approach can be integrated
with the lessons of the Sys-
tems Approach.
EPA funded the development
of a publication called Nothing
to Waste for its Environmental
Justice program. This publica-
tion uses the Systems Ap-
proach for dealing with very
small businesses.
Traditional Approach to P2 Implementation
-------
It became obvious that these
small organizations could not
afford any waste.
States that have adopted this
model have been able to
make better use of their
technical assistance providers
by having them "visit" with
many small organizations at
once instead of making many
trips to separate operations.
loan. When the group determined that a member was qualified for a
loan, the group had the power to grant that loan. The bank stipulated
that if the person missed any payments, everyone in the group was
dunned and could not get a loan for a specified period of time. This
stipulation made the members of the group work together better so
that everyone paid back loans. Banks were very happy with the results.
Previously, typical loan defaults for this segment were as high as 60%.
Using this model, loan defaults dropped to less than 10%.
It became obvious that these small organizations could not afford
any waste. Their initial loan could only be $500. If an individual borrower
wasted any of this money, the entire group would be less successful.
For example, a small furniture maker needed to know that finish
overspray led to the loss of some of the valuable finish that was pur-
chased. The furniture maker had to find out how more of that finish
could be placed on the furniture to reduce the waste.
In the Nothing to Waste program, leaders from very small organi-
zations still meet regularly in off-work hours in teams of five to seven
companies. They use the Systems Approach tools under the guidance
of a group facilitator trained in the use of the tools. They map each
other's processes, apply the tools to identify opportunities for P2, and
derive and select alternatives for dealing with the losses. The group
facilitator also helps provide the group members with P2 information
and resources that may be needed to implement the selected P2 alter-
native. States that have adopted this model (e.g., New Mexico, Maine,
and Massachusetts) have been able to make better use of their techni-
cal assistance providers by having them "visit" with many small organi-
zations at once instead of making many trips to separate operations.
Very small organizations may not have the technical capability to
follow the formal traditional approach on their own. However, they can
master the problem-solving and decision-making tools quickly and use
them to communicate effectively with one another, even though they
do not actually work together. They can learn how to communicate
better with their customers, suppliers, and lending institutions as a
result of learning how to use these tools. Action plans allow the group
to track each other's progress. These plans are reviewed at each
meeting.
Nothing to Waste has been formally adopted for use in the Green
Zia Program in New Mexico (Reference 5-1). This publication is avail-
able on the Internet and can be found on the CD-ROM. It can be used
by P2 teams in larger companies to help worker teams get an under-
standing of the use of the tools in the Systems Approach without an
expensive training program.
-------
OTHER IMPLEMENTATION APPROACHES
Chapter 6 will examine how an organization can use the environ-
mental management system (EMS) to help implement a P2 program.
This is an important implementation model since many organizations
are now considering this type of EMS (i.e., ISO 14001, EMAS, etc.).
Chapter 7 will examine how an organization can use a quality-based
program like the Baldrige approach to implement a P2 program. A pre-
vention-based approach is built into the criteria that allow an organiza-
tion to compare itself to organizations which have achieved environ-
mental excellence. An organization that scores well in the rating sys-
tem should have a significant amount of P2 in its operations.
Process maps have been prepared in each of these chapters so
you can compare them to the process maps in this chapter. By using
this tool, you will be able to select the approach that is most effective
for you and compare it to the implementation approaches provided in
this Guide. Chapter 8 will provide some tips on how to mix and match
these implementation approaches.
REFERENCE
5-1. Nothing to Waste Manual
http://www.pojasek-associates.com/Reprints/Nothing-to-
Waste.pdf
Traditional Approach to P2 Implementation
-------
-------
CHAPTER 6
EMS Approach to P2
Implementation
INTRODUCTION
The new international voluntary standard for environmental man-
agement systems (EMSs) known as ISO 14001 is proving to be an
effective tool for improving organizational environmental performance
and implementing P2 opportunities. The intent of the standard is to
establish and maintain a systematic management plan designed to
continually identify and reduce the environmental impacts resulting from
an organization's activities, products, and services. Currently, no gov-
ernment mandate requires organizations to have a comprehensive
EMS, but several states are exploring the effectiveness of having orga-
nizations use an EMS in implementing and complying with P2 planning
requirements.
Government policymakers are interested in EMSs as a possible
way to supplement the so-called "command-and-control" environmental
regulations. The EPA recognizes that an EMS can help organizations
integrate environmental considerations into day-to-day decisions and
practices (References 6-1 and 6-2). EMSs will not replace existing
regulatory systems in the United States but will work best when they
complement the existing regulatory programs including formal enforce-
ment actions. Other EMSs are emerging, but the focus of this chapter
will be on the ISO 14001 standard's elements.
For several years, the EPA has been engaged in a number of im-
portant activities designed both to promote and evaluate the effective-
ness of EMSs in a variety of settings. These activities vary widely and
include (1) a major EMS research program conducted in partnership
with states through the Multi-State Working Group (MSWG), (2) pro-
grams to promote and demonstrate the value of EMSs in various sec-
tors such as local government and metal finishing, and (3) the use of
EMSs as components of voluntary leadership programs. The EPA has
also used EMSs as important components in enforcement settlement
agreements. The MSWG has adopted a consensus policy document
to help guide states and others in designing EMSs, evaluating EMS
credibility, and participating in EMS processes (Reference 6-3). The
principles are as follow:
Includes:
D Introduction
D Getting Started
D Environmental Policy,
Management
Commitment, and Scope
D EMS Planning
D EMS Implementation
D Monitoring and
Measurement
D Lessons Learned
D References
D Supplemental Reading
EMSs should improve compliance with environmental laws,
enable organizations to achieve performance "beyond com-
pliance" with legal requirements, and reduce environmental
impacts from both regulated and unregulated activities.
The intent of the standard is to
establish and maintain a
systematic management plan
designed to continually iden-
tify and reduce the environ-
mental impacts resulting from
an organization's activities,
products, and services.
The EPA recognizes that an
EMS can help organizations
integrate environmental
considerations into day-to-day
decisions and practices.
The MSWG has adopted a
consensus policy document
to help guide states and
others in designing EMSs,
evaluating EMS credibility,
and participating in EMS
processes.
EMS Approach to P2 Implementation
-------
An EMS can serve as a supplementary tool that enables regu-
latory agencies and others to jointly achieve greater environ-
mental protection.
The quality of an EMS is linked to environmental performance
achieved.
EMS metrics can document improved environmental per-
formance, which may enable regulatory agencies to achieve
policy objectives more efficiently and improve communica-
tions with the public.
An EMS promotes important
planning and improvement
elements needed in the design
of multimedia source reduction
and recycling programs for all
forms of pollution.
The goal of the standard is to
establish a common approach
to EMSs that is internationally
recognized, leads to improved
environmental performance,
and provides an opportunity for
gaining international recogni-
tion and market share.
A growing number of organizations have pioneered new strategies
for integrating environmental management into their overall business
strategy. Although regulatory compliance remains an important driver
of environmental performance and of the adoption of advanced prac-
tices, business factors such as cost savings and improved business
performance are just as important. EMSs are motivating organizations
all over the world to reconsider their environmental performance and
effectiveness and determine how P2 strategies can help them reduce
wastes, risks, and costs. These organizations should establish and
maintain a systematic management plan that promotes P2 and is de-
signed to continually identify and reduce the environmental harm (im-
pacts) created by the organization's activities, products, and services.
The EMS fosters innovative strategies and a framework for improving
environmental performance by encouraging all the employees of the
organization to look for ways to reduce environmental impacts by first
using P2 techniques. Supporting information on EMSs can be found on
the CD-ROM that accompanies this Guide.
GETTING STARTED
Like other management systems, an EMS is a formal approach for
articulating goals, making choices, gathering information, measuring
progress, and improving performance. An EMS promotes important
planning and improvement elements needed in the design of multime-
dia source reduction and recycling programs for all forms of pollution.
Several elements of an EMS provide positive reinforcement for P2 as-
sessment and planning efforts and add an element for continual review
by management that is needed for implementation and improvement.
Figure 6-1 is a top-level process map for implementing P2 using an
EMS program.
The goal of the standard is to establish a common approach to
EMSs that is internationally recognized, leads to improved environmental
performance, and provides an opportunity for gaining international rec-
ognition and market share. ISO 14001 is a management system stan-
dard, not a performance standard. Given that ISO 14001 is a system
built for industry by industry, it uses a language that management un-
-------
GETTING STARTED:
RECOGNIZED NEED
1
POLICY AND
COMMITMENT
2
PLANNING
3
IMPLEMENTATION
4
EVALUATION AND
MANAGEMENT REVIEW
5
Figure 6-1. Implementing P2 Using an EMS Program (Top-level Process Map).
derstands, and it will keep top management's attention through involve-
ment. The EMS provides a systematic approach for integrating envi-
ronmental protection into all business functions and management strat-
egies.
One important way the EMS standard promotes integration of envi-
ronmental and organizational management is by requiring top man-
agement to define the environmental policy. However, the EMS approach
to P2 encourages several initial activities prior to setting up the policy:
Identifying current environmental compliance procedures and
management techniques
Reviewing the policies in place and environmental concerns
for the future
Ensuring that all relevant information is up to date
Generating an environmental plan for continual involvement
and improvement for the future
:
K
The EMS provides a system-
atic approach for integrating
environmental protection into
all business functions and
management strategies.
Figure 6-2 is a process map that shows these initial steps in the
EMS approach to P2.
As an initial step in developing a comprehensive EMS, most orga-
nizations find it helpful to complete an objective gap analysis of their
existing environmental system. This enables the organization to dis-
cover its current status regarding environmental performance and com-
pliance and highlight areas that require attention under an EMS. The
results of a "gap" analysis will provide a benchmark for the
organization's alignment and conformance to the ISO 14001 standard.
Many organizations are developing useful gap audit tools, including fa-
cilities, consultants, and technical assistance providers. The scope of
the gap analysis audit should include all areas of the organization re-
lated to environmental systems as well as the interfaces between a
specific facility and its corporate environmental department.
The scope of the gap analysis
audit should include all areas
of the organization related to
environmental systems as well
as the interfaces between a
specific facility and its corpo-
rate environmental depart-
ment.
EMS Approach to P2 Implementation
-------
IDENTIFY
ENVIRONMENTAL
COMPLIANCE
PROCEDURES AND
MANAGEMENT
TECHNIQUES
1.1
REVIEW POLICIES IN
PLACE AND
ENVIRONMENTAL
CONCERNS FOR THE
FUTURE
1.2
ENSURE ALL
ENVIRONMENTAL
INFORMATION IS
UP TO DATE
1.3
GENERATE AN
ENVIRONMENTAL PLAN
FOR EMPLOYEE
INVOLVEMENT AND
CONTINUAL
ENVIRONMENTAL
IMPROVEMENT
1.4
Figure 6-2. Getting Started—Recognized Need.
It is likely that top-level man-
agement will view an EMS as a
competitiveness issue rather
than as a cost center for
environmental compliance.
Command and control stan-
dards give organizations no
incentive to exceed what is
necessary for compliance.
EMSs require that organizations have a "commitment to comply
with relevant environmental legislation and regulations, and with other
requirements to which the organization subscribes." An organization's
current practices for tracking compliance are a good place to start,
and they should be compared to what an EMS entails. An EMS aligned
to ISO 14001 requirements offers the potential for delivering substan-
tial gains in production and environmental efficiency and reduced costs
in environmental compliance. It is likely that top-level management will
view an EMS as a competitiveness issue rather than as a cost center
for environmental compliance. Involvement of top management in de-
fining policy, reviewing the current plan, and maintaining EMS aware-
ness is seen as a positive outcome by many since management has
sometimes been a tough audience to reach on environmental issues.
An organization has to prove that its EMS has been implemented
effectively and leads to compliance over time. The organization must
have a procedure to identify and have access to legal and other re-
quirements to which it subscribes. Periodic compliance and EMS sys-
tem audits are required to assess procedural improvements and iden-
tify needed system improvements through corrective actions. Such a
mechanism for improvement is completely absent in command-and-
control regulations such as BAT (best available technology) standards
and emission standards. Standards such as these give organizations
no incentive to exceed what is necessary for compliance. In some
cases, they may encourage the use of control technologies over other
approaches that would result in better environmental performance.
Command and control standards give organizations no incentive to
exceed what is necessary for compliance.
Another regulatory advantage of an EMS is the requirement to con-
sider legal and other requirements when establishing objectives and
-------
targets for the significant aspects. The potential for exchange between
an EMS and state P2 facility planning requirements is generating inter-
est among environmental regulators in several states. As part of the
MSWG initiative, the state of Washington studied organizations using
ISO 14001 and concluded, "EMSs are proving to be a superior approach
for implementing P2 assessments and planning activities." They allow
the EMS to meet the organization's planning requirements if the waste
management hierarchy is followed in setting objectives and targets.
The EPA's Environmental Performance Track program has developed
a matrix of several other state programs that have modified their re-
quirements, and it can be found on their Web site (Reference 6-4).
ENVIRONMENTAL POLICY, MANAGEMENT COMMITMENT,
AND SCOPE OF THE EMS
Based on the current environmental assessment and performance,
it is management's responsibility to develop a shared vision and direc-
tion for the organization's EMS policy and to commit to its implementa-
tion (Figure 6-3, work steps 2.1, 2.2, 2.3). In the policy, management
defines its scope and ensures consistency with the organization's vi-
sion, core values, beliefs, and other goals. Management may use the
new policy to expand the organization's environmental perspective. The
environmental policy for an EMS contains the following commitments:
Commitment to "prevention of pollution"
Commitment to compliance with all applicable requirements
and other requirements to which the organization subscribes
Commitment to continual improvement of the system itself
and not specifically continued improvement of the required
environmental performance criteria.
The state of Washington
studied organizations using
ISO 14001 and concluded,
"EMSs are proving to be a
superior approach for imple-
menting P2 assessments and
planning activities."
DEVELOP
SHARED VISION
AND DIRECTION
FOR POLICY
2.1
DEVELOP SCOPE AND
ENSURE CONSISTENCY
WITH CORE VALUES AND
OTHER GOALS
2.2
COMMIT TO IMPLEMENT
THE POLICY
2.3
Prevention of Pollution
Compliance
Continual Improvement
COMMUNICATION OF
EMS POLICY
2.4
External Communication
Internal Communication
Figure 6-3. Policy and Commitment: Define Environmental Policy, Scope, and Commitment.
EMS Approach to P2 Implementation
-------
Prevention of pollution is
defined by the standard as
"use of processes, prac-
tices, materials or products
that avoid, reduce or control
pollution, which may in-
clude recycling, treatment,
process changes, control
mechanisms, efficient use of
resources and material
substitution."
The EMS standard requires
the environmental policy of the
organization be made avail-
able to the public.
The EMS requires the organi-
zation to develop and imple-
ment procedures to ensure
internal communication of the
EMS policy, responsibilities,
and results.
P2 is different from prevention of pollution as defined in the EMS
standard. Prevention of pollution is defined by the standard as "use of
processes, practices, materials or products that avoid, reduce or
control pollution, which may include recycling, treatment, process
changes, control mechanisms, efficient use of resources and ma-
terial substitution." This definition does include control and treatment
scenarios but the phrases indicated in bold in the definition provide a
clear mandate in the policy to pursue source reduction as a goal and
objective of the EMS.
The EMS policy is used as the guidance for setting and reviewing
the organization's environmental objectives and targets. The EMS stan-
dard does not require specific environmental goals. Instead, it provides
a general framework for organizing the tasks necessary for effective
environmental management and improved performance.
Communication of the EMS Policy
Once management reaches agreement on the policy, it should be
documented, kept up-to-date, and used by all employees. Most organi-
zations already have procedures in place on how they communicate
their policies internally and externally (Figure 6-3, work step 2.4). The
EMS standard requires that the environmental policy of the organiza-
tion be made available to the public. Many organizations already
provide far more environmental information through P2 plans, annual
reports, regulatory records, and participation in emergency response
planning.
An EMS addresses the process for responding to external com-
munications or requests for environmental information. The organiza-
tion documents its procedure on "how to" respond to these external
requests for information on the EMS, environmental aspects, and P2, if
and when they occur. The basic documentation an organization should
keep for external requests includes who made the contact, the date,
the nature of the request, the nature of the response, and what, if any,
materials were sent.
The EMS requires the organization to develop and implement pro-
cedures to ensure internal communication of the EMS policy, respon-
sibilities, and results. The EMS and environmental "aspects" need to
be communicated to all internal levels of the organization and job func-
tions that could impact the environment. The internal communication
procedure specifies whose responsibility it will be to communicate
changes relating to the EMS and environmental aspects. Changes may
include environmental information, such as revised objectives and tar-
gets, changes in procedures, and environmental incidents or regula-
tory changes. Another internal communication "how to" is a process
for responding to employee requests and concerns related to the EMS
and P2. Internal communication should include discussions of general
and useful P2 opportunities that apply to all wastes and losses identi-
fied in the organization.
-------
EMS PLANNING
3.1
IDENTIFY
ASPECTS AND
SIGNIFICANT
IMPACTS
3.2
fe.
IDENTIFY
OBJECTIVES
AND
TARGETS
3.3
Develop Organizational Structure
Appoint Management Representative
Practice Team Approach
Identify Resources
Use Tools to ID Aspects
Identify Legal and Other Requirements
Develop Criteria for Significant
Aspects and Impacts
Set Attainable and Measurable Goals
Ensure Goals Are Realistic
Consider Interested Party Views
EMS TRAINING
AND
RESPONSIBILITIES
3.4
ESTABLISH
ENVIRONMENTAL
MANAGEMENT
PROGRAM(S)
3.5
Consider Types of Training
Write a Plan
Provide Ownership and Responsibility
Detail How Goals Will Be Attained with Time Frames
Ensure New Products and Services Are Environmentally Friendly
Figure 6-4. Planning in the EMS.
EMS PLANNING
As an organization grows and as product lines change, planning is
necessary. Planning for P2 should go hand in hand with any business
planning effort (Figure 6-4, work step 3.1). Unfocused, ill-timed, or poorly
managed P2 efforts will lead to low performance and high cost. Con-
versely, a well-conceived and effectively implemented P2 program leads
to high performance and reduced costs. Improved environmental per-
formance is an important benefit for most organizations undertaking
EMS development and implementation. Although some organizations
have comprehensive EMSs that systematically track environmentally
relevant activities, many do not. An EMS includes organizational struc-
ture, responsibilities, practices, procedures, processes, and resources
for implementing effective environmental management.
Top management appoints a management representative or rep-
resentatives to ensure the organization accomplishes its goals when
establishing an EMS. The management representative monitors and
evaluates the system and reports to top management on the EMS's
effectiveness. The coordinator(s) works with organizational teams to
generate new ideas and modify the EMS when necessary for improve-
ment. The organization could create an environment and select a fo-
rum in which creative ideas can be heard and tried.
Most organizations choose to meet in teams to discuss production
and wastes and develop questions for needed checklists. Teams are
used to multiply the strength of the organization. The team approach
As an organization grows and
as product lines change,
planning is necessary. Plan-
ning for P2 should go hand in
hand with any business plan-
ning effort.
The management representa-
tive monitors and evaluates
the system and reports to top
management on the EMS's
effectiveness.
Teams are used to multiply
the strength of the organiza-
tion. The team approach
allows for discussion and
comparison of differences.
EMS Approach to P2 Implementation
-------
These teams can be used to
identify, evaluate, and imple-
ment P2 opportunities.
Teams are authorized to take
direct action, make decisions,
and initiate changes that result
in continual improvement.
The EMS is driven by environ-
mental impacts.
An organization's aspects may
include waste generation and
pollution, resource utilization
and depletion, energy genera-
tion and utilization, and other
ecological impacts on the
environment.
allows for discussion and comparison of differences. It may be useful
to set up self-managing P2 teams chosen from all levels of the organi-
zation. The involvement of several levels of management in these dis-
cussions, normally in several groups, improves their usefulness. Clearly
identifiable teams are the primary means of organizing the EMS work,
as opposed to individual job functions or independent work areas. These
teams can be used to identify, evaluate, and implement P2 opportuni-
ties.
Teams are authorized to take direct action, make decisions, and
initiate changes that result in continual improvement of the EMS to com-
ply with the policy and achieve the organization's objectives and tar-
gets. When the employees' roles have been formally structured to sup-
port the work team approach, members can rely on one another for
cross training, problem solving, administrative duties, and mutual sup-
port. Opportunities for waste elimination, reduction, reuse, recycling,
and energy and water conservation are addressed by a P2 team of the
most appropriate people regardless of their reporting level in the orga-
nization.
Identification of Aspects and Significant Environmental
Impacts
The EMS is driven by environmental impacts. An EMS encourages
organizations to systematically address the environmental impacts of
their activities, products, and services (Figure 6-4, work step 3.2). This
systematic approach may prove effective in encouraging organizations
to take a proactive and P2 approach to managing their environmental
impacts and programs. An organization's aspects may include waste
generation and pollution, resource utilization and depletion, energy gen-
eration and utilization, and other ecological impacts on the environ-
ment.
Aspect—element of an organization's activities, products, or
services that can interact with the environment.
The standard outlines a core set of planning activities that are used
in many organizations to assess and implement P2. This planning en-
sures a facility will:
• Identify facility activities, operations, processes, services,
and products that have environmental impacts
• Identify all legal requirements that apply to the organization's
activities, products, and services
• Evaluate which environmental impacts are significant
• Set objectives and targets for reducing negative environmental
impacts
• Select and implement activities through environmental man-
agement program(s) to achieve the identified targets
-------
Through the procedure of aspect identification and ranking, P2
should emerge as a core part of the environmental management plan(s).
The P2 assessment is a systematic, periodic survey of the
organization's operations designed to identify areas of potential waste
reduction and conservation. A well-designed EMS can go far beyond
the traditional process-driven view for characterization of wastes and
losses. In evaluating all of its environmental aspects, an organization
can take activities such as solid waste, energy and water use, land-
scaping, commuting, sound, and other impacts into consideration al-
though they are not regulated. The organization can question suppliers
about contents of materials, use and types of packaging, and methods
of delivery. Aspect identification procedures include the following:
Process mapping
• Interviews
• Questionnaires
• Checklists
• Benchmarking
• Cost/benefit, energy, and life cycle analysis
• Inspections and audits
• Review of records and emergency responses
• Material balances of inputs and outputs
Consideration of operating conditions and controls and their effect
on environmental impacts is an important part of identifying the
organization's significant aspects. The organization should select cri-
teria to determine the significance of its aspects. The criteria might
include regulated activities, costs to manage, and risks associated with
use of raw materials. What is most important is that the criteria reflect
the organization's values as stated in the policy. Several good examples
of ranking potential significant aspects/impacts can be found in US
EPA's Integrated Environmental Management Systems Implementa-
tion Guide and NSF International's Environmental Management Sys-
tems: An Implementation Guide for Small and Medium-Sized Organi-
zations (References 6-4 and 6-5). See the CD-ROM for more informa-
tion on EMSs.
Identifying operations and monitoring and measuring activities as-
sociated with significant environmental aspects leads to the develop-
ment of procedures that minimize the risk of those environmental im-
pacts. This systematic approach can help foster P2 solutions by en-
couraging an organization to identify opportunities for doing things in
new ways, for finding new products from "waste," and forgoing beyond
the traditional view that environmental issues are the responsibility of
the environmental, health, and safety managers.
Typically, organizations separate their environmental strategies by
media—land, air, and water—to address their environmental impacts
Through the procedure of
aspect identification and
ranking, P2 should emerge as
a core part of the environmen-
tal management plan(s).
In evaluating all of its environ-
mental aspects, an organiza-
tion can take activities such
as solid waste, energy and
water use, landscaping,
commuting, sound, and other
impacts into consideration
although they are not regu-
lated.
The organization should select
criteria to determine the
significance of its aspects.
The criteria might include
regulated activities, costs to
manage, and risks associated
with use of raw materials.
This systematic approach can
help foster P2 solutions by
encouraging an organization to
identify opportunities fordoing
things in new ways, for finding
new products from "waste,"
and forgoing beyond the
traditional view that environ-
mental issues are the respon-
sibility of the environmental,
health, and safety managers.
EMS Approach to P2 Implementation
-------
A multimedia EMS approach
will ensure all significant
aspects are identified that
impact the environment and
are costly for the organization.
The organization benefits by
involving suppliers and con-
tractors in the EMS proce-
dures and requirements for
certain significant environmen-
tal aspects they could impact.
The EMS's objectives and
targets are the most important
place for articulating P2 plan-
ning goals.
and compliance with various environmental regulations. This leads to
a single media dependence on reactive and end-of-pipe strategies that
are potentially inefficient and costly. Many organizations that have insti-
tuted a thorough EMS have benefited by becoming aware of inefficien-
cies that were not apparent previously. Correcting these inefficiencies
generates cost savings and reduced environmental liabilities. A multi-
media EMS approach will ensure all significant aspects are identified
that impact the environment and are costly for the organization.
The organization benefits by involving suppliers and contractors in
the EMS procedures and requirements for certain significant environ-
mental aspects they could impact. Identification of health and environ-
mental concerns associated with the raw materials used by an organi-
zation is important in assessing the significance of environmental as-
pects associated with that materials' use. It may be necessary to pro-
vide training and guidance to outside organizations whose actions onsite
may create an aspect or impact the organization's environment. This
provides a forum for the two organizations to investigate goods and
services for P2 opportunities. From improving efficiencies to changing
basic processes, design has played an important role in reducing waste.
Good supplier partnerships can result in designing for P2 and meeting
the objectives and targets established for the EMS.
An organization may choose to modify an existing assessment
tool or develop a procedure for identifying all the organization's environ-
mental aspects and their significance. Use a team approach during
this planning phase and keep the aspects' list updated. Prioritize the
significant aspects to begin addressing opportunities to improve the
organization's impact on the environment. Finally, remember to look
beyond regulatory requirements and your organization's boundary when
considering your organization's aspects and invite input from all inter-
ested parties.
EMS Objectives and Targets
The EMS sets explicit goals by establishing and maintaining objec-
tives and targets for improvement (Figure 6-4, work step 3.3). The EMS's
objectives and targets are the most important place for articulating P2
planning goals. Although an organization has discretion with regard to
its objectives and targets, they must be consistent with the
organization's environmental policy containing a commitment to pre-
vention of pollution that helps reinforce source reduction goals and com-
pliance with state P2 planning laws.
Objectives—overall environmental goals that an organization sets
out to achieve.
Targets—detailed performance requirements that are set and met
to achieve the environmental objectives.
-------
Again, P2 (source reduction) practices and techniques succeed
best when promoted as the number one strategy for improving environ-
mental performance and meeting attainable and measurable goals. In
setting the EMS's objectives and targets, the organization must con-
sider (1) significant environmental aspects, (2) legal and other require-
ments, (3) the views of external parties and societal concerns, (4) tech-
nical options and operational feasibility, (5) financial requirements for
paybacks, and (6) business requirements for marketability and profit-
ability. All of these are usually taken into consideration when P2 op-
portunities are being examined for inclusion in an organization's P2 plan.
An EMS encourages innovative P2 solutions to waste and loss prob-
lems at all levels of the organization. Documented objectives and tar-
gets of the EMS must be provided for all relevant levels and functions of
the organization that impact the environment. The objectives and tar-
gets may be different for various levels of the organization such as
management, plant engineer, and line supervisors and operators. The
keys are consistency with the environmental policy and the inclusion of
P2. The EMS standard requires organizations to set objectives and
targets for reducing their environmental impacts, select activities to
achieve the identified targets, and then use a continual improvement
cycle to evaluate and correct the system.
EMS Training and Responsibility
The EMS requires that all employees be made aware of their envi-
ronmental responsibilities and trained to exercise care when perform-
ing duties with environmental consequences (Figure 6-4, work step 3.4).
Consider what type of EMS training is needed to achieve the
organization's objectives and targets and integrate this training into ex-
isting environmental, health and safety, and emergency preparedness
training programs. This training requirement provides the opportunity to
involve all employees in P2. If the absence of correct procedures could
lead to deviations from your EMS policy, objectives, or targets, the pro-
cedure or work instruction should be documented and used in training.
This is an extremely important part of a successful EMS.
Employees will need to be trained in the procedures relevant to
their roles and responsibilities for meeting the objectives and targets
and in the potential results of departure from specified operating proce-
dures. It is important to ensure that EMS internal auditors are trained
and familiar with the waste management hierarchy and P2 strategies.
Training will ensure that EMS objectives and targets are assessed and
are being met using source reduction methods.
One company created a bulletin board displaying the company's
policy, significant aspects and impacts, and objectives and targets of
the EMS. During morning line meetings, the line supervisors went with
the line team to the bulletin board and reviewed this information all the
In setting the EMS's objec-
tives and targets, the organi-
zation must consider (1)
significant environmental
aspects, (2) legal and other
requirements, (3) the views of
external parties and societal
concerns, (4) technical op-
tions and operational feasibil-
ity, (5) financial requirements
for paybacks, and (6) busi-
ness requirements for market-
ability and profitability.
The EMS requires that all
employees be made aware of
their environmental responsi-
bilities and trained to exercise
care when performing duties
with environmental conse-
quences.
It is important to ensure that
EMS internal auditors are
trained and familiar with the
waste management hierarchy
and P2 strategies.
EMS Approach to P2 Implementation
-------
Often, it is the employees
most familiar with the
organization's production
processes who are in the best
position to identify P2 projects
for improving environmental
program performance.
The EMS is designed to
continually improve system
and environmental perfor-
mance through creation of an
environmental management
program (EMP).
way up to the week of the ISO 14001 registration audit. This approach
was excellent for several reasons: (1) it built on a system already in
place, (2) the regular meeting established and reinforced the impor-
tance of knowing this information, and (3) the employees knew where
to go when the auditors asked them questions about these areas of the
EMS.
By providing environmental awareness training for all employees,
an organization can count on the technical know-how of employees on
the production floor to help find creative P2 strategies to reduce their
environmental impacts. With respect to training competency, the EMS
standard asks that the organization determine what qualifications (edu-
cation, training, and/or experience) are necessary and to ensure that
each employee completes these requirements for his/her job. Often, it
is the employees most familiar with the organization's production pro-
cesses who are in the best position to identify P2 projects for improv-
ing environmental program performance. Just as an organization uses
incentives to boost employee productivity, management should pro-
vide incentives for developing useful ideas to reduce waste.
Environmental Management Programs (EMPs)
The EMS is designed to continually improve system and environ-
mental performance through creation of an environmental manage-
ment program (EMP). The EMP is the last element of the EMS plan-
ning phase (Figure 6-4, work step 3.5). It sets up action items, assigns
responsibilities at all levels of the organization for plan execution, sets
specific time lines, and determines the resources needed for imple-
mentation to achieve the objectives and targets. With the goals estab-
lished, the subset of activities defined, and the accountabilities in place,
each person with specific responsibilities must now develop EMPs for
implementation. One person or several people are assigned the ac-
countability for meeting the goals and objectives in the planned time
frame for each task in the action plan and for maintaining the current
level of performance on each of these items.
Although setting objectives and targets is treated as a separate
function from EMPs in the planning phase, they are related. You have
to have an idea of how you will accomplish an objective and target
before you set it up as a program in your system. This is the process
many organizations now use in their P2 planning effort to accomplish
specific projects. After P2 assessment and planning, projects are initi-
ated to implement technically and economically feasible P2 opportuni-
ties. Wthout the continual improvement component of the EMS, how-
ever, P2 planning and implementation may be an end point instead of
the ongoing process of setting new objectives and targets for other
aspects that impact the environment.
The number of EMPs that an organization sets up can vary. One
company uses one EMP to address all of its objectives and targets.
-------
Another company set up four EMPs for dealing with (1) all regulated
aspects, (2) solid waste, (3) energy usage, and (4) PCB elimination.
Finally, one company's EMPs were developed largely at the depart-
mental level. The EMP(s) and objectives are reviewed by the team when
changes occur in the organization's operations. When objectives and
targets are not met, corrective actions are identified and taken.
As progress is made, it should be recorded against the EMPs cre-
ated. Some questions and progress can be measured quantitatively.
Other questions are more subjective, but progress can still be mea-
sured. The purpose is to monitor progress on currently active EMPs
and watch for slippage on implemented activities. As with any imple-
mentation review, the questions to ask are the following:
:
Have the milestones been achieved?
If not, what can be done to bring this stage of implementa-
tion back on schedule?
What issues need to be resolved to continue our
progress?
EMS IMPLEMENTATION
At present, there is a clear need for careful evaluation of how an
EMS will influence an organization's environmental effectiveness. This
evaluation will facilitate more informed decision-making about how best
to incorporate an EMS approach into existing environmental regulatory
programs and P2 planning. At this point, many organizations already
have sophisticated EMSs in place and perceive little customer demand
or regulatory advantage to seek full registration. Many are aligning with
the standard, however, and are aware that third-party auditing may be-
come necessary in the future.
Most organizations already have regulatory and P2 procedures in-
cluding work instructions, batch sheets, training records, testing and
monitoring results, controls to meet permit operating limits, and cali-
bration instructions (Figure 6-5, work step 4.1). Build on your existing
documentation whenever you can if it is appropriate. The working docu-
ments provide the detailed "how to" and step-by-step instructions
needed to perform tasks. Document the system requirements to meet
your business needs and keep it simple.
If instructions and documentation do not add value to operational
control, question whether they are needed. Not every department in the
organization will need the same amount or detail in documentation.
Factors that can affect the need to document procedures include the
risk and complexity of the activity and the frequency and degree of su-
pervision needed to perform the activity. Organizational teams should
identify gaps in the existing documentation and initiate new procedures
to ensure continual improvement.
The number of EMPs that an
organization sets up can vary.
One company uses one EMP
to address all of its objectives
and targets. Another company
set up four EMPs for dealing
with (1) all regulated aspects,
(2) solid waste, (3) energy
usage, and (4) PCB elimina-
tion. Finally, one company's
EMPs were developed largely
at the departmental level.
Build on your existing docu-
mentation whenever you can if
it is appropriate.
If instructions and documenta-
tion do not add value to opera-
tional control, question whether
they are needed.
Factors that can affect the
need to document procedures
include the risk and complex-
ity of the activity and the
frequency and degree of
supervision needed to perform
the activity.
EMS Approach to P2 Implementation
-------
Records document that the organization is doing what it said it
would, and they include forms, labels, tags, logbooks, and correspon-
dences. Important record system questions are the following:
• How will records be collected?
• Where will records be filed?
• How will records be filed?
• How will records be disposed (recycled)?
EMS
IMPLEMENTATION
4.1
Documentation
Document Control
OPERATIONAL
CONTROL
4.2
ft
Develop Procedures for Activities
Stipulate Operating Criteria
Preventive and Corrective Maintenance
CHECKING AND
CORRECTIVE
ACTION
4.3
Investigate Nonconformances
Determine Root Causes
Implement and Review Correcth
Actions
Figure 6-5. Implementation of the EMS.
Implementation of operational
controls is the "do" part of the
EMS cycle of "plan, do, check,
review."
The important step for opera-
tional control is identifying
activities and employee job
functions that can have a
potential or actual impact on
the environment.
Good operational control for
P2 is defined as a procedure
or process within an organiza-
tion that reduces multimedia
wastes and conserves natural
resources.
Operational Control
Implementation of operational controls is the "do" part of the EMS
cycle of "plan, do, check, review" (Figure 6-5, work step 4.2). Proce-
dures are instructions used by the organization for environmental sys-
tem activities such as P2. They define the details of who, what, when,
where, and why in the EMS activities and include some generic "how
to's." This is where most organizations expend the most effort while
implementing an EMS. Because procedures are extremely important,
the organization will benefit from determining which procedures to docu-
ment and how to best write them for guidance and training. Written
procedures are an essential element of operational control if the ab-
sence of these procedures could lead to deviations from the environ-
mental policy, objectives, and targets.
The important step for operational control is identifying activities
and employee job functions that can have a potential or actual impact
on the environment. Operational controls established for significant en-
vironmental impacts help the organization determine the roles, respon-
sibilities, and authorities needed to ensure performance. You stipulate
operating criteria for employees in these improved standard procedures.
Large amounts of waste may be generated through improper storage
practices, inefficient production start-up or shutdown, scheduling prob-
lems, lack of preventive maintenance, or poorly calibrated devices for
pollution control. Good operational control for P2 is defined as a proce-
dure or process within an organization that reduces multimedia wastes
and conserves natural resources.
-------
Process changes can result in new operational controls that re-
duce waste at the source, primarily during production. Good operating
procedures and improved housekeeping are the simplest P2 practices.
Improved housekeeping relies on using good common sense and is
often the most effective first step toward waste reduction. By properly
labeling materials and wastes, an organization can reduce the risk of
misuse or disposal of the wrong substance. By properly separating
wastes, an organization can assess the potential for reuse, recycling,
or exchange of the materials. Inventory control and handling materials
properly, including storage, will reduce loss of input materials and re-
duce expired shelf life of time-sensitive materials.
Substituting less toxic raw materials may be difficult in certain situ-
ations, but it can be an efficient part of P2 operational control to reduce
multimedia wastes. Changes may include equipment, layout, piping
changes, use of automation, waste concentration or volume reduction,
and energy conservation. Operational control ensures that equipment
is working properly and avoids faulty valves or pipes leaking materials
that become contaminated and a waste. Preventive maintenance pro-
cedures are designed to reduce incidents of equipment breakdowns,
inefficiency, or process fluid leakage. Another important operational
control is corrective maintenance, such as resetting control valves or
adjusting process temperatures to increase efficiency and prevent raw
material loss and waste generation.
The basic steps to success in P2 through operational control in-
clude building on existing systems, establishing procedures, assigning
responsibility, determining access, communicating and training, and
auditing procedures and records. These procedures are the core of a
P2 program's operational phase and are often the "low-hanging fruit"
that are within easy reach. Without a Systems Approach, much of the
P2 "low-hanging fruit" will be lying on the ground.
Checking and Corrective Action
The checking and corrective action element in the EMS is the main
focus for continual improvement (Figure 6-5, work step 4.3). Manage-
ment involvement and commitment to reducing waste needs to deal
successfully with checking and corrective action. P2 may benefit from
closer supervision to improve production efficiency and reduce inad-
vertent waste generation through early detection of mistakes. EMSs
ensure that nonconformances to procedures are investigated, that root
causes of the nonconformity are identified, and that corrective and pre-
ventive actions are implemented, documented, and reviewed. This type
of analysis leads to increased efficiency of the EMS and P2 through
improved performance.
As systems are put in place, it makes sense to establish measur-
ing processes on how well the system is working, identify actual or
Good operating procedures
and improved housekeeping
are the simplest P2 practices.
Substituting less toxic raw
materials may be difficult in
certain situations, but it can be
an efficient part ofP2 opera-
tional control to reduce multi-
media wastes.
The checking and corrective
action element in the EMS is
the main focus for continual
improvement.
EMS Approach to P2 Implementation
-------
The EMS standard requires
procedures to monitor and
measure your environmental
performance, to record infor-
mation that allows perfor-
mance tracking of operational
controls and conformance with
the objectives and targets, and
to evaluate compliance with
environmental regulations.
Determining what to monitor
and measure and what infor-
mation to record is critical.
potential problems, and act to eliminate them. This element of the EMS
establishes measures of environmental performance and identifies
where corrective actions are needed, if any. Organizations that have
implemented an EMS have realized internal efficiency gains. Internal
efficiency gains may be realized by the identification of root causes of
waste and by easier access to environmental reporting information,
records, and permits.
EMS MONITORING AND MEASUREMENT
The EMS standard requires procedures to monitor and measure
your environmental performance, to record information that allows per-
formance tracking of operational controls and conformance with the
objectives and targets, and to evaluate compliance with environmental
regulations (Figure 6-6, work step 5.1). This element leads to success
in determining real measurements that can be communicated inter-
nally or externally.
Determining what to monitor and measure and what information to
record is critical. The objectives and especially the targets of the EMS
are quantifiable and measurable so that progress toward achieving them
can be tracked. EMS measures are used as environmental performance
indicators. Legal and other requirements were considered in setting
objectives and targets so monitoring of effluents and air emissions are
measured and tracked. Key operational characteristics and param-
eters associated with significant environmental aspects are tracked
and can serve as measures. Choose the number of indicators care-
fully—too many create information overload and an ineffective system,
but too few mean you won't have enough information to make good
business decisions. To ensure good measurement, the key questions
to answer are the following:
MONITORING AND
MEASUREMENT
WITH CORRECTIVE
AND PREVENTIVE
ACTIONS
5.1
PERIODIC REVIEW
BY MANAGEMENT
OF
IMPLEMENTATION
AND EFFECTIVENESS
5.2
IMPROVE
EMERGENCY
PREPAREDNESS AND
SPILL PREVENTION
5.3
Measure Environmental Performance
Track Operational Controls
Track Conformance with Objectives
and Targets
Evaluate Compliance with
Environmental Regulations
Detect Overall EMS Trends
Review Corrective Actions
for Continual Improvement
Provide Commitment and Support
Review and Update Procedures and
Training After Accidents
Figure 6-6. Evaluation and Management Review.
-------
Who is responsible for tracking, analyzing, compiling, and
reporting data?
What is the frequency of measurement for data?
How will data be analyzed/compiled?
How will data be reported?
nd
Although the organization may be monitoring data on a hourly or
daily basis for compliance purposes, the data will be used more strate-
gically for the EMS. Monitoring will be used to detect overall trends and
the possible need for corrective and preventive action. In this way, the
organization may identify gradually declining performance and will be
able to reverse it before a nonconformance, noncompliance, or other
incident occurs.
Many companies are already evaluating their compliance in at least
one of two ways: through compliance audits or through monitoring of
regulatory permits. An environmental compliance audit compares an
organization's performance with a set of environmental requirements
relying largely on following a paper trail of permits, sampling data, and
reports. Auditing the EMS's actual performance is different because it
focuses on employees from various levels and job functions within the
organization and their actions. A compliance audit compares an
organization's performance to environmental requirements while an
EMS audit focuses on employees and their actions.
There are two types of environmental solutions: short term to fix
the immediate problem and long term to prevent the problem from re-
curring. The focus of the EMS and P2 is on the long-term solutions that
eliminate or reduce the organization's environmental aspects and im-
pacts. The first step to implementing a long-term solution is to develop
plans that assign responsibility, determine progress dates, and desig-
nate needed resources to complete the corrective actions. If at some
point the initial solution does not work, it may mean the true root cause
was not correctly identified. At this point, generate new solutions and
record the reason for the change.
Management Review and Continual Improvement
An EMS encourages a systematic approach to improving environ-
mental procedures and performance through continual improvement.
Top management periodically reviews EMS implementation and effec-
tiveness (Figure 6-6, work step 5.2). Experience has shown that the
effectiveness of management directly affects the chances of a suc-
cessful EMS. EMSs are business systems that allow organizations to
manage their environmental issues in a systematic, organized fashion
based on continual improvement—just like any other area of business
such as quality, purchasing and inventory control, accounting and
payroll, and cash flow. Like these other areas, EMSs focus on top man-
agement support and commitment, accountability, employee involve-
ment, responsibility and training, documentation, operational controls,
A compliance audit compares
an organization's performance
to environmental requirements
while an EMS audit focuses on
employees and their actions.
The focus of the EMS and P2
is on the long-term solutions
that eliminate or reduce the
organization's environmental
aspects and impacts.
An EMS encourages a sys-
tematic approach to improving
environmental procedures and
performance through continual
improvement.
EMS Approach to P2 Implementation
-------
EMSs focus on top manage-
ment support and commit-
ment, accountability, employee
involvement, responsibility and
training, documentation,
operational controls, preven-
tive actions, and periodic
checking and review with
corrective action.
The EMS must include pre-
ventive actions and how to
mitigate environmental im-
pacts. Improving emergency
preparedness procedures
reduces accidental and mate-
rial losses while maintaining or
increasing productivity.
When it comes to developing
solutions, the EMS stipulates
that the corrective and preven-
tive actions be appropriate to
the magnitude of the problem
and commensurate with the
environmental impact encoun-
tered.
preventive actions, and periodic checking and review with corrective
action.
If a nonconformance has occurred, the responsible employees
determine how to correct it and prevent it from recurring. Management
review provides a broader, strategic look at the EMS and may be a
source of direction on preventing nonconformance. There are many
tools for developing solutions that have been discussed previously. The
next step is to prioritize the solutions for possible implementation. Use
of traditional business tools for prioritizing solutions can be used, such
as cost-benefit analysis.
Emergency Preparedness and Spill Prevention
Accidents and emergency situations can create environmental
impacts. Large amounts of waste may be generated through spills and
lack of emergency response procedures. The EMS must include pre-
ventive actions and how to mitigate environmental impacts. Improving
emergency preparedness procedures reduces accidental and mate-
rial losses while maintaining or increasing productivity (Figure 6-6, work
step 5.3).
Studies to implement preventive and corrective maintenance,
emergency response, spill prevention, and P2 programs should be
undertaken and theirfindings incorporated into the operational control
procedures. Improved procedures can range from a change in man-
agement approach to a change in waste handling practices and must
be a part of the overall emergency plan for the organization.
Preventive procedures should be reviewed and updated when nec-
essary after accidents and emergency situations. When it comes to
developing solutions, the EMS stipulates that the corrective and pre-
ventive actions be appropriate to the magnitude of the problem and
commensurate with the environmental impact encountered. P2 can be
implemented by changing existing procedures to reduce waste result-
ing from the cleanup of spills or leaks. Emergency plans already devel-
oped can be referenced in the overall emergency preparedness and
response procedure of the EMS.
LESSONS LEARNED
The EMS is based on a documented and clearly communicated
policy that includes three distinct guiding principles: compliance with
applicable environmental requirements, prevention of pollution, and a
commitment to continual improvement in environmental performance.
In some cases, organizations' environmental policies, especially cor-
porate policies, may have become too long and broad to be under-
stood easily by employees and the public. An organization's EMS policy
needs only to focus on the three guiding principles and to drive the
accomplishment of the EMS's objectives and targets through training
and involvement.
-------
An EMS identifies, translates, and communicates applicable envi-
ronmental and voluntary requirements to affected employees, suppli-
ers, and contractors. Voluntary requirements may include those ad-
dressing P2, company or corporate initiatives, health, process safety
management (PSM), and sustainable development. Health and PSM
tend to be mandatory requirements of the Occupational Safety and
Health Administration (OSHA). EPA's Green Lights, Climate Wise,
Project XL, Design for the Environment (DfE), Environmentally Prefer-
able Purchasing Program (Reference 6-9), and the American Chemis-
try Council's (ACC) Responsible Care® are examples of voluntary ini-
tiatives. Refer to the CD-ROM for more information on these programs.
Standard operating procedures ensure that the employees, suppliers,
and contractors can meet the EMS's requirements.
Compliance with Environmental Regulation
The EMS specifies procedures for how compliance will be achieved
and maintained organizationally. For example, it defines the compli-
ance roles and responsibilities of environmental managers, establishes
how they and management will be held accountable for achieving and
maintaining compliance, and describes how environmental performance
and compliance information will be communicated to relevant employ-
ees, suppliers, and contractors. The EMS establishes a mechanism
for receiving and addressing environmental and compliance concerns
raised by individuals, organizations, or other interested parties.
The EMS includes procedures for identifying changes to applicable
environmental requirements—including new ones that may
apply as a result of process or material changes—and addressing these
changes through the EMS process. For those organizations that are
already performing environmentally, the EMS should establish objec-
tives and targets that promote leadership and ensure continued achieve-
ment of compliance.
Prevention of Pollution
Identifying all aspects and determining their significance is usually
the largest gap in most organizations' current environmental systems.
The EMS establishes and maintains a procedure to identify all of the
environmental aspects of the organization's activities, products, and
services that it controls and influences. Current procedures to identify
existing process waste streams and review new customer work re-
quests can be used as starting points for identifying all aspects. Also, a
procedure to identify which of these aspects have significant impact on
the environment is needed, and significant impacts must be consid-
ered in setting objectives.
Many organizations focus almost exclusively on negative environ-
mental impacts. Positive environmental impacts are also important.
These might include company-sponsored community recycling pro-
An organization's EMS policy
needs only to focus on the
three guiding principles and to
drive the accomplishment of
the EMS's objectives and
targets through training and
involvement.
Standard operating proce-
dures ensure that the employ-
ees, suppliers, and contrac-
tors can meet the EMS's
requirements.
The EMS establishes a
mechanism for receiving and
addressing environmental and
compliance concerns raised
by individuals, organizations,
or other interested parties.
The EMS should establish
objectives and targets that
promote a leadership and
ensure continued achieve-
ment of compliance.
EMS Approach to P2 Implementation
-------
An EMS establishes specific
objectives, targets, and time
frames for implementing P2
initiatives, improving environ-
mental performance, and
maintaining compliance.
EMP requirements specifically
include designation of respon-
sibility for actions and the
means and time frame by
which the objectives are to be
achieved.
The EMS identifies and pro-
vides for the planning and
management of all the
organization's operations and
activities, including facility
maintenance, in order to
achieve operational control
and maintain compliance.
The EMS also establishes
documented procedures for
mitigating any adverse im-
pacts on the environment that
may be associated with acci-
dents or emergencies.
grams and household hazardous waste collection days. An EMS can
develop approaches to procurement, processing, and delivery that re-
duce or minimize significant environmental impacts for organizations,
customers, and interested parties.
An EMS establishes specific objectives, targets, and time frames
for implementing P2 initiatives, improving environmental performance,
and maintaining compliance. These should be documented and up-
dated. An EMS ensures that the organization has skilled employees
and financial and technical resources to achieve its objectives and tar-
gets and maintain compliance. In setting objectives and targets for each
relevant job within the organization, it is important to consider pollution
prevention goals; any additional significant impacts; legal and other re-
quirements; technological options; financial, operational, and business
requirements; and views of interested parties. These considerations
are important in EMS planning and are used for capital improvement
decisions, product and process design, training programs, and main-
tenance activities.
The organization establishes environmental management programs
(EMPs) to achieve its EMS objectives and targets. EMP requirements
specifically include designation of responsibility for actions and the
means and time frame by which the objectives are to be achieved. The
EMP must review new activities, products, equipment, or services and
address environmental changes through the EMS. For measuring per-
formance-based improvement, targets must be quantifiable and use
metrics that are related to the organization's overall goals. Most organi-
zations have set some quantitative goals for various process waste
streams, for example, reducing sludge production 10% by 2002 based
on amount of wastewater treated. The EMP establishes the frequency
at which the objectives and targets will be reviewed.
Continual Improvement
In many organizations, operational controls have been implemented
for achieving waste reduction goals, although responsibility for achiev-
ing these goals has not always been designated. The EMS identifies
and provides for the planning and management of all the organization's
operations and activities, including facility maintenance, in order to
achieve operational control and maintain compliance.
The EMS establishes documented procedures for preventing, de-
tecting, investigating, promptly correcting, and reporting (both internally
and externally) actual and potential accidents, emergency situations,
and environmental violations. The EMS includes procedures for track-
ing any preventive and corrective actions that are taken. If an environ-
mental violation or accident resulted from a weakness in the system,
the EMS is updated and refined, ensuring that similar situations are
avoided. The EMS also establishes documented procedures for miti-
gating any adverse impacts on the environment that may be associ-
-------
ated with accidents or emergencies. An EMS provides for the testing of
emergency procedures when it is practicable.
EMS training programs ensure that all employees, suppliers, and
contractors whose job roles may impact objectives, targets, and com-
pliance are trained and capable of carrying out their responsibilities.
The organization should evaluate competency for employees whose
work may create significant environmental impacts. The organization
must date and retain training records, training materials, and documents
demonstrating evaluation of employee awareness and competency.
EMS documentation describes how all of the system elements will
be integrated into the organization's overall decision-making and busi-
ness planning process and provide direction to all relevant environmental
procedures. An EMS document control system includes procedures
for maintaining and protecting documents and other records as objec-
tive evidence of compliance and effectiveness. The EMS specifies re-
tention times for environmental records in accordance with relevant
laws.
Management must appoint a representative to ensure implemen-
tation and review of the EMS. The EMS requires periodic and objective
auditing and review of the organization's environmental system effec-
tiveness and compliance. Without top management review, visible
involvement, and support, the EMS will not generate significant envi-
ronmental improvement or better results over the current management
system. This is the most important element of the EMS because man-
agement becomes a source of direction and oversees development of
action items for sustainable improvement and long-term value creation.
Management review promotes organizational leadership by demon-
strating a commitment to environmental responsibility. The scope and
frequency of the review will depend on the size and complexity of the
organization's environmental impacts.
Organizations are discovering that their investments in EMSs are
leading to improved environmental performance and compliance with
benefits for the environment and community. An EMS provides a good
method for establishing and implementing a P2 program. To achieve
maximum environmental benefits, the EMS should embody the "plan,
do, check, and act" model for continual improvement. This model
ensures that environmental impacts are systematically identified, con-
trolled, and monitored. The EMS helps ensure more consistency by
organizations in achieving and maintaining compliance, promoting
results-oriented efforts, and attaining more reliable data on environ-
mental performance. Effective use of an EMS can be viewed as a
demonstration of environmental responsibility and leadership by orga-
nizations. An EMS provides the basis for collaborating with regulatory
agencies to enhance suitability and effectiveness and promote a lead-
ership, performance-based system.
An EMS document control
system includes procedures
for maintaining and protecting
documents and other records
as objective evidence of
compliance and effectiveness.
Management review promotes
organizational leadership by
demonstrating a commitment to
environmental responsibility.
An EMS provides a good
method for establishing and
implementing a P2 program.
To achieve maximum environ-
mental benefits, the EMS
should embody the "plan, do,
check, and act" model for
continual improvement.
EMS Approach to P2 Implementation
-------
REFERENCES
6-1. Federal Register Web Site
http://www.epa.gov/fedrgstr/EPA-GENERAL/1998/March/Day-
12/g6389.htm
6-2. Integrated Environmental Management Systems
Implementation Guide, EPA 744-R-00-011. US Environmental
Protection Agency, Office of Pollution Prevention and Toxics,
October 2000
6-3. Multi-State Working Group Web Site
http://www.mswg.org
6-4. Environmental Management Systems: An Implementation
Guide for Small and Medium-Sized Organizations. NSF
International, Ann Arbor, Ml, November 1996
http://www.kppc.org/EMS/emspubs.cfm
6-5. EPA's Environmental Performance Track Web Site
http://www.epa.gov/performancetrack
6-6. ANSI-RAB information on registration, registrars, training and
consulting
http://www.ansi.org/public/iso14000
6-7. EPA's Environmentally Preferable Purchasing (EPP) Web Site
http://www.epa.gov/opptintr/epp/index.htm
6-8. Minnesota Office of Environmental Assistance (MOEA) EPP
Web Site
http://www.moea.state.mn.us/lc/purchasing/
6-9. A Catalogue of the Agency's Partnership Programs, EPA
100-B-97-003, U.S. Environmental Protection Agency, Office
of the Administrator, Spring 1998
SUPPLEMENTAL READING
Environmental Management System Demonstration Project. NSF
International, Ann Arbor, Ml, December 1996
http://www.kppc.org/EMS/emspubs.cfm
Environmental Management System Primer for Federal Facilities,
DOE/EH-0573. U.S. Department of Energy and U.S.
Environmental Protection Agency, Washington, D.C., 1996
http://www.kppc.org/EMS/emspubs.cfm
The ISO 14001 Implementation Guide: Creating an Integrated
Management System. Susan L. Jackson, John Wley &
Sons, Inc., 1997
ISO 14000 Case Studies: Models for Implementation, Mark B. Baker
(Editor), CEEM Information Services, 1996
-------
EPA Standards Network Fact Sheet, ISO 14000: International
Environmental Management Standards, EPA/625/F-97/004
http://www.epa.gov/ttbnrmrl/
ISO 14000 Resource Directory, EPA/625/R-97/003
http://www.epa.gov/ttbnrmrl/
ISO 14001: A Tool for Supporting Government Environmental
Programs and Policies, EPA/625/R-00/006
http://www.epa.gov/ttbnrmrl/
ISO 14001: An Industrial Management Tool for Achieving
Competitive Advantage and Environmental Compliance,
EPA/625/R-00/007
http://www.epa.gov/ttbnrmrl/
See the CD-ROM for more reading.
EMS Approach to P2 Implementation
-------
-------
CHAPTER 7
Using a Quality Model to
Implement P2
INTRODUCTION
This chapter presents an approach to preparing a P2 plan that is
business-oriented, while still meeting any state or local P2 requirements.
P2 has sometimes suffered from its reputation as something that the
environmental personnel do or direct others to do. A more effective
approach is integrating P2 into your organization's core business prac-
tices. This approach allows you to communicate the value of P2 to
both senior management and workers. Your P2 plan also can be main-
tained and improved on an annual basis. This chapter presents a proven
quality model that is based on the highly successful Baldrige Quality
Program.
The Malcolm Baldrige National Quality Award is bestowed each
year by the President of the United States on organizations that have
demonstrated proficiency in the use of this quality model. The award
was established by the U.S. Congress in 1987 to raise awareness about
the importance of quality and performance excellence. When this award
was established, the organizers believed that quality was no longer
optional for American companies but was instead a necessity fordoing
business in an ever-expanding and more competitive world market.
Nearly 50 countries now offer awards based on the Baldrige quality
model, and 43 of the 50 states in the United States offer awards based
on this model.
In 1998, the State of New Mexico began the Green Zia program,
which adopted this quality model to measure environmental excellence.
Environmental excellence is a term that describes the ultimate goal
sought by using a quality program for environment, health, and safety
(EHS) management. An environmental excellence program sets a
"stretch goal" of attaining "best-in-class" status in those areas that best
support a prevention-oriented approach to EHS management. No longer
are short-term goals with percent reduction targets accepted by upper
management and other interested parties. Results from these goal-
driven activities are only "outcomes" of EHS performance and not a
measure of the performance itself. Also, results by themselves offer
little diagnostic value (i.e., were "good" results well below those of your
competitors?). Green Zia shows an organization how to use a 15-item
list of performance characteristics that can be modified to enable fast-
paced EHS program improvement and thus contribute to the results.
By focusing on performance, the organization can both help encour-
age P2 program development and provide a metric to show how effec-
tively that P2 program is working.
Includes:
D Introduction
D Seven Quality Model
Criteria
D Eleven Quality Model
Guiding Principles
D Five-Step Process to
Improve Your P2 Plan
D Using the Quality Model
to Implement P2
D Supplemental Reading
D Web Sites
The Malcolm Baldrige National
Quality Award was established
by the U.S. Congress in 1987
to raise awareness about the
importance of quality and
performance excellence.
In 1998, the State of New
Mexico began the Green Zia
program, which adopted this
quality model to measure
environmental excellence.
Environmental excellence is a
term that describes the ulti-
mate goal sought by using a
quality program for environ-
ment, health, and safety
(EHS) management.
Using a Quality Model to Implement P2
-------
The Green Zia model has all
the essential ingredients that
make a zero waste vision
possible.
Using this quality model, the stretch goal can be set at zero—zero
defects, zero inventory, zero equipment breakdowns, and zero waste.
Many organizations are now extending the zero concept to EHS pro-
grams—zero incidents, zero accidents, zero wastes, zero emissions,
and zero drain on world resources (sustainability). P2 is a major driv-
ing force in the quest for zero waste and zero emissions.
The Green Zia model has all the essential ingredients that make a
zero waste vision possible. First, it has criteria that define "best in class"
so each organization can measure progress towards excellence. Sec-
ond, it has a set of guiding principles (or core values) that must be
present in order to integrate the criteria throughout the program. Third,
it has a rigorous scoring system that is used by trained examiners to
provide a score that represents the current state of the environmental
excellence program on a 1000-point scale. Fourth, the examiners is-
sue a feedback report detailing the strengths and weaknesses of an
organization's excellence program against the criteria and guiding prin-
ciples. The scoring system and the feedback reports are important
tools for organizations to use in their environmental excellence pro-
grams. Organizations seek excellence, in their own way, using this
model by selecting the performance elements for improvement and
determining how to leverage these efforts in the organization. The P2
plan is often used to drive the program.
This chapter will first look at the criteria contained in this quality
model. Next, the quality model's guiding principles will be discussed.
Finally, a five-step process will be presented to show how this quality
information can be integrated with the Systems Approach presented in
the first four chapters of this Guide. You can find more readings on this
topic in the reference section at the end of the chapter and on the CD-
ROM that accompanies this Guide.
SEVEN QUALITY MODEL CRITERIA
When implementing a P2 program, it is important to keep your eye
on what is important. Based on years of quality management experi-
ence, this boils down to seven criteria:
1. Leadership
2. Strategic planning
3. Interested-party involvement
4. Employee involvement
5. Process management
6. Information analysis
7. Results
These criteria form the basis for the Green Zia program and will be
used in the quality model presented in this chapter. Within each of these
criteria, you will need to address how you are working to integrate P2
-------
into your organization. In the past, you have probably focused on what
you were doing. This may still be important. The "how" approach will
lead you to the level of P2 integration that you seek. The first six criteria
show you how to drive performance that will then lead to results, some-
thing that is covered in the seventh criterion. Let's take a look at the
types of "how" questions that should be asked in each of these criteria.
Leadership. A strong top-down direction for P2 or an EMS will en-
hance the chances of success in the program and help integrate it into
the organization as a whole. P2 will be seen as important if the top
leaders support it. Two sets of issues must be dealt with in the leader-
ship criterion:
• How do senior leaders communicate their commitment to
continual P2 program improvement to the employees and
other interested parties?
• How do senior leaders demonstrate that commitment?
The first six criteria show you
how to drive performance that
will then lead to results, some-
thing that is covered in the
seventh criterion.
A strong top-down direction for
P2 or an EMS will enhance the
chances of success in the
program and help integrate it
into the organization as a
whole.
The time you take to keep the leaders informed and involved (i.e.,
"walking the talk") will help you provide answers to these important ques-
tions.
Strategic planning. Leadership most often uses some form of strate-
gic planning to guide the organization's course. Sometimes this involves
a formal strategic planning program. In other cases, the strategic plan-
ning may be much less formal. There are four basic questions that you
need to address in the strategic planning criterion to attain continual P2
program improvement:
How do you identify long-term and related short-term goals
and objectives?
How do you develop these goals and objectives?
How do you implement these goals and objectives?
How do these goals and objectives relate to your
organization's overall business objective?
als
To be ideally situated, the P2 program must be important in the
eyes of the senior leaders and be represented in the strategic planning
process. There is a strong link between strategic planning and leader-
ship.
Interested-party involvement. No organization operates in isolation.
There are many other organizations that can have an impact on your
P2 or EMS programs. Interested parties include a wide variety of differ-
ent stakeholders in your P2 program such as customers, suppliers,
contractors, regulatory agencies, non-government organizations
(NGOs), environmental groups, community groups, and the public at
To be ideally situated, the P2
program must be important in
the eyes of the senior leaders
and be represented in the
strategic planning process.
There are many other organi-
zations that can have an
impact on your P2 or EMS
programs.
Using a Quality Model to Implement P2
-------
large. The questions that need to be considered for this criterion in-
clude the following:
How does your organization involve interested parties in the
development and implementation of your P2 program?
How is your organization involved in other organizations' P2
programs?
Employees are a very impor-
tant part of the P2 program.
The employees represent a special stakeholder position that has its
own criterion.
Employee involvement. This criterion looks at the bottom-up portion
of the P2 program, which is every bit as important as the top-down
portion covered in the leadership category. Employees are a very im-
portant part of the P2 program, so it is important not to rely exclusively
on outside experts and technical assistance to find P2 alternatives.
Who knows the inner workings of an organization better than the em-
ployees? Questions that need to be addressed are the following:
• H
How does your organization prepare and involve employees
in the development and in the implementation of the P2
program approaches?
How are the employees' value and well-being considered in
the P2 program?
Process management con-
cerns itself with how you
manage all work processes in
such a way that P2 behavior is
facilitated.
Both the other interested-party and employee involvement criteria
deal with the involvement of people in your P2 program. Now, you should
turn to the process. In the past, this may have been the sole focus of
the P2 program.
Process management. This is the criterion that ISO 14001 or other
EMSs can help an organization with its score. Process management
concerns itself with how you manage all work processes in such a
way that P2 behavior is facilitated. It is important to realize that the
process management criterion includes both "things people do" and
other organization work processes (e.g., manufacturing). The impor-
tant questions to ask here are as follows:
• He
po
• u^
How does your organization identify the primary and sup-
porting work processes that impact the P2 program?
How does your organization analyze those work processes
to understand their impacts and underlying causes?
How does your organization manage all work processes to
gain P2 program excellence?
This criterion is closely related to the information-analysis criterion.
-------
Information analysis. Information analysis is the fuel of the P2 pro-
gram. Paying attention to this criterion is the only way that clear results
can be determined. The following three questions should be asked:
How does your organization select information to assess the
effectiveness of the P2 program?
How does your organization collect that information?
How does your organization use that information to make
decisions?
:he
Information analysis is the fuel
of the P2 program.
This last question implies an important link to the strategic planning
and leadership criteria. An organization that performs well makes sure
that valuable information finds its way into the strategic planning pro-
cess and is not used solely in the environmental program.
Results. This is the criterion with the greatest number of points in the
quality model. Results measure the outcomes of all the performance
changes and move the P2 program beyond anecdotal information and
success stories to something that will link to all the other criteria. Re-
member that performance (i.e., the first six criteria) drive results. The
two important considerations that need to be addressed in this criterion
are as follows:
:
What are your organization's planned vs. actual results re-
lated to your P2 program approach?
What are the levels and trends as they relate to impacts on
environment, other interested parties, and financial indica-
tors?
Results measure the out-
comes of all the performance
changes and move the P2
program beyond anecdotal
information and success
stories to something that will
link to all the other criteria.
The "how" is still involved in this criterion as you need to consider
the following issues:
How do you select the results you wish to track?
How do you plan to measure them?
How do you use the results to drive the other criteria?
How do you trend your results for continual improvement?
How do you trend the results of other similar organizations to
benchmark your P2 program progress?
ria?
Using the Criteria
The Green Zia program makes it clear that all the criteria are linked
and interrelated with the other criteria. Whenever you address one of
the criteria, you need to ask how you need to leverage this by recogniz-
ing how it interacts with another criterion. The information that can be
found on the CD-ROM will show many important connections between
these criteria.
Using a Quality Model to Implement P2
-------
By using the proper scoring
methodology, you will be able
to see the areas that require
more effort as you seek to
improve the P2 program.
You need to find a way to
integrate each of the guiding
principles with the proper
criteria in the quality model if
you wish to integrate the P2
program into the organization.
Another interesting fact about the Green Zia method is that there are a
number of more detailed questions that can be asked within each criterion
that describe what might be the best one can do (i.e., if you can answer
every question in a positive manner within an example, your organization
may be considered to be doing a great job in that area). A complete list of
these questions can be found on the CD-ROM.
It is not important for your organization to be the best in all seven
criteria areas. You will certainly do better in some than you do in others.
The point is to make sure that the P2 program addresses all seven
criteria in a forthright manner.
The Green Zia program assigns points to each of these criterion.
These points emphasize the greater importance of results in a P2 pro-
gram. By using the proper scoring methodology outlined on the CD-
ROM, you will be able to see the areas that require more effort as you
seek to improve the P2 program. Once you address these opportuni-
ties to improve the program using the Systems Approach tools, you
can measure the amount of improvement in the overall program score.
This concept will be described later in this chapter.
ELEVEN QUALITY MODEL GUIDING PRINCIPLES
Guiding principles, often referred to as core values, are used to set
a context for all activities in an organization. They are meant to provide
guidance for decision-making at all levels in the organization. You need
to find a way to integrate each of the guiding principles with the proper
criteria in the quality model if you wish to integrate the P2 program into
the organization. Your organization may have already published a set
of guiding principles. If so, consider how P2 can be addressed within
each of these areas. If your organization does not have a set of guiding
principles, consider how you can introduce the following principles into
the culture. Keep in mind that it may take a long time (i.e., perhaps
more than two years of concerted effort) to change the culture by ad-
dressing these guiding principles in the statement of the criteria. How-
ever, once this change takes place, the P2 program will be integrated
within the organization. There are 11 guiding principles that can be con-
sidered in this quality model:
1. Interested-party-driven P2
2. Leadership
3. Continual improvement and learning
4. Valuing employees
5. Fast response
6. Efficient product, service, and process design
7. Long-range view of the future
8. Management by fact
9. Partnership development
10. Public responsibility and citizenship
11. Results focus
Let's take a look at what is meant by each of these guiding principles.
-------
Interested-party-driven P2. P2 is judged by interested parties (i.e.,
customers, employees, suppliers, regulators, stockholders, the public,
and the community). Thus, P2 must take into account all product and
service features and characteristics that contribute value to these in-
terested parties and lead to their satisfaction, preference, and contin-
ued interest in your organization.
Interested-party-driven P2 is thus a strategic concept. It is directed
toward organizational customer retention, market share gain, growth,
and maintenance of all relationships with time. It demands constant
sensitivity to changing and emerging interested-party and market re-
quirements and the factors that drive interested-party satisfaction and
attention. Interested-party-driven P2 also demands awareness of de-
velopments in technology and of competitor's offerings and rapid and
flexible response to interested-party and market requirements.
Interested-party-driven P2 means much more than waste dis-
charge and emission reduction, merely meeting regulatory requirements
and specifications, or reducing complaints. Nevertheless, waste re-
duction and elimination of causes of dissatisfaction contribute to the
interested party's view of P2 and are thus also important parts of inter-
ested-party-driven P2. In addition, the organization's success in re-
covering from EHS problems and waste management issues ("mak-
ing things right for the interested party") is crucial to building interested-
party relationships and to customer retention.
Leadership. An organization's senior leaders are the right team to set
directions and create an interested-party orientation, clear and visible
P2 values, and high expectations. These directions, P2 values, and
expectations should address all interested parties. The leaders can
ensure the creation of strategies, systems, and methods for achieving
environmental excellence, stimulating innovation, and building knowl-
edge and capabilities. The strategies and P2 values will help guide all
P2 activities and decisions of the organization. The senior leaders who
are committed to the development of the entire workforce will encour-
age participation, learning, innovation, and creativity by all employees.
Through their behavior and personal roles in P2 planning, commu-
nications, review of P2 performance, and employee recognition, the
senior leaders serve as role models, reinforcing P2 values and expec-
tations and building leadership and initiative throughout the organiza-
tion.
Continual improvement and learning. Achieving the highest levels
of P2 performance requires a well-executed approach to continual im-
provement and learning. The term continual improvement refers to both
incremental and "breakthrough" improvement. The term learning re-
fers to adaptation to change, leading to new goals and/or P2 ap-
proaches. Improvement and learning need to be "embedded" in the
P2 must take into account all
product and service features
and characteristics that
contribute value to these
interested parties and lead to
their satisfaction, preference,
and continued interest in your
organization.
An organization's senior
leaders are the right team to
set directions and create an
interested-party orientation,
clear and visible P2 values,
and high expectations.
The term continual improve-
ment refers to both incremen-
tal and "breakthrough" im-
provement.
The term learning refers to
adaptation to change, leading
to new goals and/or P2 ap-
proaches.
Using a Quality Model to Implement P2
-------
way the organization operates. The term embedded means that im-
provement and learning:
1.
2.
3.
4.
Are a regular part of daily work.
Are practiced at individual, work unit, and organizational
levels.
Seek to eliminate waste at its source.
Are driven by opportunities to innovate and do better in the
P2 program.
P2 improvement and learning include:
2.
3.
4.
5.
6.
Enhancing value to interested parties through new and
improved products and services.
Developing new business opportunities from P2
successes.
Reducing waste, emissions, and discharges and related
costs.
Improving responsiveness to production and quality in
waste (nonvalue added activity) reduction programs.
Increasing productivity and effectiveness in the use of all
resources (e.g., energy, water, and materials).
Enhancing the organization's performance in fulfilling its
public responsibilities and service as a good citizen.
An organization's P2 success
depends increasingly on the
knowledge, skills, innovative
creativity, and motivation of its
workforce.
Thus, improvement and learning are directed not only toward bet-
ter products and services but also toward being more responsive, adap-
tive, and efficient—giving the organization additional marketplace and
performance advantages.
Valuing employees. An organization's P2 success depends increas-
ingly on the knowledge, skills, innovative creativity, and motivation of its
workforce. Employee success depends increasingly on having oppor-
tunities to learn and to practice new skills. Organizations can take ad-
vantage of the workforce's potential by investing in its development
through education, training, and opportunities for continuing growth.
Opportunities might include enhanced P2 awareness and increased
pay for demonstrated P2 awareness, knowledge, and skills. On-the-
job training offers a cost-effective way to train and to better link P2
training to work processes. Education and training programs may need
to utilize advanced technologies, such as computer-based learning and
satellite broadcasts. Increasingly, training development needs to be tai-
lored to a diverse workforce and to be more flexible for high perfor-
mance P2 work practices.
Major challenges in the area of valuing employees include:
-------
rlno
1. Integrating human resource practices: selection,
performance, recognition, training, and career
advancement.
2. Developing, cultivating, and sharing the P2 knowledge
possessed by the organization's employees.
3. Aligning human resource management with strategic
change processes.
Addressing these challenges requires use of employee-related data
on process knowledge, skills, satisfaction, motivation, EHS knowledge,
and well being. Such data can be tied to indicators of organizational or
unit performance, such as interested-party satisfaction, customer re-
tention, and productivity. Through this approach, employee contribu-
tions may be integrated and aligned with business P2 directions.
Fast response. Obtaining permits and regulatory compliance can add
significant time to organizational decision-making. Success in globally
competitive markets demands ever shorter cycles for introductions of
new or improved products and services. Also, faster and more flexible
response to interested parties is now a more important requirement.
Major improvements in response time often require simplification of
work units and processes together with timely incorporation of P2 into
the design phase (i.e., design for the environment). To accomplish this,
the P2 performance of work processes should be among the key pro-
cess measures. Other important benefits can be derived from this fo-
cus on time: time improvements often drive simultaneous improve-
ments in organizational behaviors, quality, P2, cost, and productivity.
Hence, it is often beneficial to integrate response time, quality, P2, and
productivity objectives.
Efficient product, service, and process design. Organizations need
to emphasize P2 in the design phase—problem and waste prevention
achieved through building P2 into products and services and building
efficiency into production and delivery processes. P2 design includes
the creation of fault-tolerant (robust) or waste-free processes and prod-
ucts. Costs of preventing problems at the design stage are lower than
costs of correcting problems that occur "downstream." Accordingly,
organizations can emphasize P2 opportunities for P2 innovation and
interventions "upstream"—at early stages in processes. This approach
should also take into account the organization's supply chain.
The design stage is critical from the point of view of public respon-
sibility. In manufacturing, design decisions impact the production and
content of municipal and industrial wastes as well as other environ-
mental impacts. Effective design strategies should anticipate growing
environmental demands and related issues and factors.
Long-range view of the future. Pursuit of market leadership requires
a strong future orientation and a willingness to make long-term com-
Major improvements in
response time often require
simplification of work units and
processes together with timely
incorporation ofP2 into the
design phase (i.e., design for
the environment).
Organizations need to empha-
size P2 in the design phase—
problem and waste prevention
achieved through building P2
into products and services and
building efficiency into produc-
tion and delivery processes.
Using a Quality Model to Implement P2
-------
Major components of such a
long-term P2 commitment
include developing employees
and suppliers as key P2
participants in the long run and
fulfilling public responsibilities
over this period of time.
P2 measurements are driven
by the organization's strategy
and provide critical data and
information about key pro-
cesses, outputs, and P2
results.
Organizations can better
accomplish their overall goals
by building internal and exter-
nal P2 partnerships.
mitments to all other interested parties. Organizations anticipate many
factors in their strategic planning efforts, such as interested party ex-
pectations, new business opportunities, the increasingly global mar-
ketplace, technological developments, new customers and market
segments, evolving regulatory requirements, community/societal ex-
pectations, and strategic changes by competitors. Short- and long-
term P2 plans, P2 strategic objectives, and P2 resource allocations
can reflect these influences. Major components of such a long-term
P2 commitment include developing employees and suppliers as key
P2 participants in the long run and fulfilling public responsibilities over
this period of time.
Management by fact. Organizations depend on the measurement and
analysis of P2 performance. Such P2 measurements are driven by the
organization's strategy and provide critical data and information about
key processes, outputs, and P2 results. Many types of data and infor-
mation are needed for P2 performance measurement and improve-
ment. Performance areas should include (1) interested-party and em-
ployee satisfaction, (2) product and service offerings, (3) operations,
(4) market and competitive comparisons, and (5) P2 financial benefits.
Analysis refers to extracting larger meaning from P2 data and in-
formation to support evaluation, decision-making, and operational im-
provement within the organization. Analysis entails using data to deter-
mine P2 trends, projections, and cause and effect—knowledge that
might not be evident without analysis. Data and analysis support a va-
riety of purposes, such as P2 planning, reviewing overall P2 perfor-
mance, improving operations, and comparing P2 performance with
competitors or with "best practices" benchmarks.
P2 partnership development. Organizations can better accomplish
their overall goals by building internal and external P2 partnerships.
Internal P2 partnerships might include labor-management coop-
eration, such as agreements with unions. P2 agreements might entail
employee development, cross-training, or new work organizations, such
as worker teams. Internal P2 partnerships also might involve creating
network relationships among work units to improve flexibility, respon-
siveness, and P2 knowledge sharing.
External P2 partnerships might be with customers, suppliers, NGOs,
environmental regulatory agencies, and educational organizations for
a variety of purposes, including P2 education and training. An increas-
ingly important kind of external P2 partnership is the strategic partner-
ship of alliance. Such P2 partnerships might offer entry into new mar-
kets or a basis for new products or services. P2 partnerships also
might permit the blending of an organization's core competencies or
leadership capabilities with the complementary strengths and capabili-
ties of P2 partners, thereby enhancing overall P2 capability, including
the elimination of waste from all business processes.
-------
Internal and external P2 partners should develop longer-term waste
elimination objectives, thereby creating a basis for mutual investments.
P2 partners should address the key requirements for success, means
of regular communication, approaches to evaluating P2 progress, and
means for adapting to changing conditions.
Public responsibility and citizenship. An organization can benefit by
communicating its responsibilities to the public and practicing good citi-
zenship. These responsibilities refer to basic expectations of the orga-
nization—business ethics and protection of public health, safety, and
the environment. These responsibilities apply to the organization's op-
erations as well as the life cycles of its products and services. Organi-
zations also can emphasize resource conservation and waste reduc-
tion at the source. P2 planning should anticipate adverse impacts from
production, distribution, and transportation. The plan must provide re-
sponse if problems occur and make information available and provide
the support needed to maintain public awareness, safety, and confi-
dence.
Practicing good citizenship refers to the following items: (1) im-
proving education, (2) promoting health care in the community, (3) en-
hancing the local environment, (4) promoting resource conservation
and recycling, (5) participating in community service, and (6) sharing
nonproprietary P2 program information. Leadership as a corporate citi-
zen also entails influencing other organizations, private and public, to
partner for these same purposes. For example, individual organiza-
tions could lead efforts to help define the obligations of their industry to
its communities.
Results focus. An organization's P2 performance measurements will
benefit from a focus on key P2 results. Results should be focused on
creating and balancing value for all interested parties—customers, em-
ployees, stockholders, suppliers, NGOs, P2 partners, and the commu-
nity. To meet the sometimes conflicting and changing aims that bal-
ance implies, organizational strategy needs to implicitly include all in-
terested-party requirements. This balance will help to ensure that P2
actions and P2 plans meet interested-party needs and avoid adverse
impact on any stakeholders. The use of a balanced composite of per-
formance measures offers an effective means to communicate short-
and long-term P2 priorities, to monitor actual P2 performance, and to
marshal support for improving results. It is important to remember that
the first six criteria drive performance while the results criterion cap-
tures the measurement of this performance. Results in and of them-
selves are not performance.
Using the Guiding Principles
The criteria describe how best-in-class organizations handle each
of the seven areas covered. The guiding principles show how to inte-
grate P2 into any organization. You can learn more about how to com-
In addition to meeting all local,
state, and federal laws and
regulatory requirements,
organizations should treat
these and related require-
ments as opportunities for
continual improvement "be-
yond mere compliance" or by
attaining compliance through
P2.
An organization's P2 perfor-
mance measurements will
benefit from a focus on key P2
results.
Using a Quality Model to Implement P2
-------
FIVE-STEP PROCESS
1. Plan and develop your P2
program.
2. Develop your organization's
P2 opportunities.
3. Implement your revised P2
plan.
4. Maintain your P2 program.
5. Measure your progress
toward zero waste and zero
emissions.
bine these quality model items by reading the Green Zia and Baldrige
information on the CD-ROM. Let us now see how these items can be
incorporated into a P2 Plan.
FIVE-STEP PROCESS TO IMPROVE YOUR P2 PLAN
Let's examine a simple five-step process that utilizes the quality
model and the Systems Approach tools presented in the first four chap-
ters of this guide. This process should help you integrate your P2 plan
into your organization's core practices. These steps are as follows:
1.
2.
3.
4.
5.
Plan and develop your P2 program.
Develop your organization's P2 opportunities.
Implement your revised P2 plan.
Maintain your P2 program.
Measure your progress toward zero waste and
emissions.
This five-step process is presented as a top-level process map in Fig-
ure 7-1. Each of these steps will be described in the following sections.
You can follow along with the various process maps that were pre-
pared to illustrate the points made in the text.
PLAN AND DEVELOP
P2 PROGRAM
1
DEVELOP P2
OPPORTUNITIES
2
IMPLEMENT P2
PROGRAM
3
MAINTAIN P2
PROGRAM
4
MEASURE PROGRESS
TOWARD
ENVIRONMENTAL
EXCELLENCE
Figure 7-1. Top-level Depiction of Quality Model Approach to Pollution Prevention
Implementation.
Step 1. Plan and Develop Your P2 Program
The first step in preparing a P2 program (Figure 7-2, work step
1.1) is to determine the elements of the quality model that will be ad-
dressed in the P2 planning effort. Four of the seven criteria covered in
this chapter are addressed in this step: strategic planning, interested-
-------
party focus, leadership, and employee involvement. You should deter-
mine the gap that may exist between the more detailed questions that
get asked in the Green Zia program for each of these criteria and what
is currently going on in your organization. The Green Zia criteria ques-
tions can be found on the CD-ROM that comes with this publication.
Your gap analysis should also consider how to integrate the P2 pro-
gram into your core business practice using some combination of the
11 guiding principles. This step is very similar to the first step in the
traditional P2 approach discussed in Chapter 5.
The consideration of the quality model criteria should not only help
you make your plan more businesslike, but it should also help you bet-
ter meet the requirements of any P2 planning laws.
The leadership criterion helps you prepare the management P2
policy. This leadership examination will look at how senior leaders ac-
tually communicate and demonstrate their commitment to continual
environmental improvement and P2 to employees and to other inter-
ested parties.
The employee involvement criterion helps you prepare the employee
involvement, awareness, and training requirements. This effort looks
at how the organization prepares and involves employees in the devel-
opment and implementation of the P2 approaches. It also asks how
the employees' value and well being are considered in these programs.
The strategic planning criterion addresses how the organization
will identify, develop, and implement long-term and short-term goals
and objectives for continual environmental improvement and P2 and
how these goals and objectives relate to the overall business objec-
tive.
Finally, the interested-party focus criterion determines how your
organization involves all interested parties in the development and imple-
mentation of your continual environmental improvement and P2 efforts.
In the next step (Figure 7-2, work step 1.2), the relevant processes
that occur within the organization are characterized using the process-
mapping tool in the Systems Approach. These maps will be used as
templates for gathering information on the process. This activity helps
you identify the production units that require further analysis.
During this work step, consideration of two other criteria is impor-
tant: process management and information analysis. Process man-
agement addresses how the organization will identify, analyze, and
manage all the processes that have the ability to impact the environ-
ment or cause injury to workers. Information analysis determines how
the organization selects, collects, and uses information to assess the
effectiveness of the program and make decisions on the basis of this
information.
The leadership criterion helps
you prepare the management
P2 policy.
The employee involvement
criterion helps you prepare the
employee involvement, aware-
ness, and training require-
ments.
The strategic planning criterion
addresses how the organiza-
tion will identify, develop, and
implement long-term and
short-term goals and objec-
tives for continual environ-
mental improvement and P2.
The interested-party focus
criterion determines how your
organization involves all
interested parties in the devel-
opment and implementation of
your continual environmental
improvement and P2 efforts.
Process management ad-
dresses how the organization
will identify, analyze, and
manage all the processes that
have the ability to impact the
environment or cause injury to
workers.
Using a Quality Model to Implement P2
-------
PLAN P2 PROGRAM
1.1
Ib,-
CHARACTERIZE
PROCESSES
1.2
DOCUMENT PAST
SUCCESSES
1.3
Planning for Continual Environmental
Improvement
Interested Party Focus
Leadership
Employee Involvement
Integrate with Guiding Principles
PREPARE DRAFT
P2 PLAN
1.4
Draft Plan Without Action Plans
Process Maps of Main Process
Process Maps of Supporting Processes
Establish Information Templates
Process Management
Information Analysis
Prepare a Listing
Figure 7-2. Planning and Developing a Pollution Prevention Program.
Information analysis deter-
mines how the organization
selects, collects, and uses
information to assess the
effectiveness of the program
and make decisions on the
basis of this information.
Finally, after all this effort, it is
time to prepare a formal P2
plan in draft form for review
both internally and by the
interested parties. Once the
P2 action plans are prepared,
the P2 plan can be finalized
and distributed.
You will note that six of the seven criteria and the eleven guiding
principles of the quality model are incorporated into the P2 program in
the first two steps. This integration should help strengthen the P2 pro-
gram and integrate it into the organization's key business operations.
The third step (Figure 7-2, work step 1.3) addresses the desirabil-
ity of documenting previous P2 activities. Even at the start of a P2
program, it is important to document what has been done before. The
third work step examines all P2 activities that can be documented with
a time frame of two to five years. Employees and management alike
will be justifiably proud of these accomplishments and can build on
them in this newly constituted P2 program.
Finally, after all this effort, it is time to prepare a formal P2 plan in
draft form for review both internally and by the interested parties. Once
the P2 action plans are prepared, the P2 plan can be finalized and
distributed.
Step 2. Develop Your Organization's P2 Opportunities
The hierarchical process maps prepared in the previous step are
now used to gather information on the production units. You are now
ready to develop the P2 opportunities (Figure 7-3).
In the information and analysis step (Figure 7-3, work step 2.1),
every use of a toxic material represents an opportunity to eliminate that
use. Every loss of a toxic material or the generation of hazardous waste
-------
represents an opportunity not to have that loss or waste. The facility
will have many P2 opportunities visually depicted by the process maps.
You must rank order these P2 opportunities to provide some focus to
your P2 plan. Pareto analysis (also referred to as the 80/20 Rule) is
used in the Systems Approach to separate the vital P2 opportunities
from the "trivial many." You may want to consider selecting between 8
and 11 opportunities for the first planning year of the program. These
opportunities should be selected with a goal of completing them within
that year. The P2 program needs to have some "quick wins" to help
maintain the interest of management and the other interested parties.
You may want to select a couple of opportunities that will take a bit
longer to complete and consider them with respect to the two-year
window in the planning requirements. All the opportunities that will ulti-
mately be included in the program can also be listed at this point. Next,
you will collect more information on these opportunities.
The second step (Figure 7-3, work step 2.2) begins the process of
production unit analysis. For each opportunity, an employee team will
work with a facilitator provided by the organization to determine the root
cause for the use or loss of all resources (i.e., materials, water, and
energy). They will use a cause and effect diagram to look at how mate-
rials, methods, machines (technology), and people contribute to the
P2 opportunity that has been identified. This team will conduct the root
cause analysis and then prepare a memorandum version of a defini-
tive statement of the problem. The time spent by the team determining
the root cause is rewarded by the generation of a higher number of
The facility will have many P2
opportunities visually depicted
by the process maps. You
must rank order these P2
opportunities to provide some
focus to your P2 plan.
For each opportunity, an
employee team will determine
the root cause for the use or
loss of toxic materials or
hazardous waste.
The time spent by the team
determining the root cause is
rewarded by the generation of
a higher number of alterna-
tives.
INFORMATION AND
ANALYSIS
2.1
Ib,
OPPORTUNITY ROOT
CAUSE ANALYSIS
2.2
DEVELOP
ALTERNATIVES
2.3
Resource Accounting
Cost Accounting
Rank-Order Opportunities
Select Opportunity
Cause-and-Effect Diagram
Pareto the Causes
Team Memorandum
Brainwriting of Alternatives
Detail Alternatives
SELECT ALTERNATIVE
2.4
Start with "Quick Wins"
Feasibility Analysis (if needed)
Capital Justification (if needed)
Figure 7-3. Development of Pollution Prevention Opportunities.
Using a Quality Model to Implement P2
-------
The P2 program is imple-
mented by preparing draft
action plans for all the alterna-
tives.
Typically, it is good to aim for
8 to 11 plans each year.
alternatives in the next step. Now, they are in a position to generate alter-
natives for realizing this opportunity by using a brainwriting tool (Figure
7-3, work step 2.3). Finally, they will select an alternative for implemen-
tation using a bubble-up/bubble-down tool (Figure 7-3, work step 2.4).
These interactive problem-solving and decision-making tools will help
the team gather the information needed for successful implementation
and communication with management and other interested parties.
Step 3. Implement Your Revised P2 Program
The P2 program is implemented (Figure 7-4) by preparing draft ac-
tion plans for all the alternatives studied in the previous step. These ac-
tion plans are the core of the P2 program each year and should be care-
fully reviewed before implementation. At this point, it is worthwhile to
reconsider the relevant items in the quality model that were evaluated in
the first step of the program (Figure 7-1). Recall that these criteria, as
well as the guiding principles, are carefully designed to help integrate
programs into core business practices. Constant effort to develop and
improve on these items will keep the P2 program moving towards zero
waste and emissions as a stretch goal. These criteria and guiding prin-
ciples can be reinforced in the action plans and in the revisions to the P2
plan itself.
A key point, given the work done in the previous step, is employee
involvement, awareness, and training. It has often been said "employ-
ees never resist their own ideas." They can become important partners
in P2 when the Systems Approach is used in the program. Once all this
is done, final action plans are created for implementing each P2 alterna-
tive. Typically, it is good to aim for 8 to 11 plans each year. This goal
should not inhibit people from doing other P2 activities. The focus will be
on the main action plans in the program. The P2 plan will provide for
implementation that is subject to a P2 program oversight committee.
This group should be comprised of managers and should include the
organization's senior manager. The action plans should be reviewed at
IMPLEMENT P2 PROGRAM
Prepare Draft Action Plans
Consider All Quality Model Criteria
Finalize Action Plans for Year (8-11 Plans)
Provide for Program Oversight
Provide for Program Auditing
Prepare Final P2 Program
Figure 7-4. Implement the Pollution Prevention Program.
-------
least on a quarterly basis. At the end of the year, they can be audited
both internally and externally (i.e., by interested parties). The final P2
plan should now have internal plan approval and is ready for implemen-
tation.
Step 4. Maintain Your P2 Program
Once the P2 plan is implemented, it must be maintained overtime
(Figure 7-5). It is important to review the quality model criteria for infor-
mation analysis and results. The results criterion examines your
organization's real and anticipated P2 results related to your continual
environmental approach to zero waste and emissions. It suggests that
you consider levels and trends as they relate to impacts on the environ-
ment, worker health and safety, other interested party impacts, and key
financial indicators. Managers love results and continue programs that
deliver good results. Remember that "what gets measured, gets man-
aged." P2 programs cannot survive on success stories. The informa-
tion analysis criterion ensures that these results are used in running
the organization and not simply sent off to the interested parties. The
P2 plan must be improved with feedback received on the actual
progress that is made. Each year, the sequence of preparing action
plans using the Systems Approach is repeated.
Managers love results and
continue programs that deliver
good results. Remember that
"what gets measured, gets
managed." P2 programs
cannot survive on success
stories.
MAINTAIN P2 PROGRAM
Information Analysis
Results
Continual Improvement with Feedback
Reports to Interested Parties
Action Plans for Year 2
Figure 7-5. Maintain the Pollution Prevention Program.
Step 5. Measure Your Progress Toward Zero Waste and
Emissions
After a few years, the P2 program can be scored in light of what it
has contributed to the organization's stretch goal of zero waste and
emissions (Figure 7-6). This scoring can be accomplished in a man-
ner like the Green Zia program. It provides the ultimate scorecard for
how important the P2 plan has been for the organization. Trending
information helps the organization point to its accomplishments. The
organization can also trend itself in comparison to other similar organi-
zations using benchmarking techniques. This information can be used
Using a Quality Model to Implement P2
-------
MEASURE PROGRESS
TOWARD ZERO WASTE AND
EMISSIONS
Prepare Green Zia-type Application
Score Application Using Trained Examiners
Determine How P2 Influenced Feedback Report
Continual Improvement of P2 Program
Figure 7-6. Measure Progress Toward Zero Waste and
Emissions.
Not only can an organization
score itself, but it can also
score all of its suppliers.
These scores can be com-
pared on an "apples-to-apples"
basis. In this manner, the
entire life cycle of a product to
a customer can be scored for
environmental excellence, P2,
and product stewardship.
Your I SO 14001, Global
Reporting Initiative, CERES
Principles, Responsible Care
Program®, balanced
scorecard, six sigma, ISO
9000, and other environmental
and quality initiatives will help
you score points in each of the
criteria. They all help contrib-
ute to environmental excel-
lence.
to continuously improve the P2 plan and other initiatives aimed at
attaining zero waste and emissions.
Not only can an organization score itself, but it can also score all of
its suppliers. These scores can be compared on an "apples-to-apples"
basis. In this manner, the entire life cycle of a product to a customer
can be scored for environmental excellence, P2, and product steward-
ship. Improvements can be weighed against the effect they had on the
trending of these scores in time. While scoring may not be for every-
one, it can be a useful tool for measuring continual improvement.
USING THE QUALITY MODEL TO IMPLEMENT P2
The use of the Systems Approach and the quality model provides
a means of creating a sustainable P2 plan for your organization. Is it
worth the effort? If your organization already has a quality program in
place, the effort is not great at all. It is likely that there is already a
program in place that you can build on. The quality model criteria and
guiding principles simply emphasize good business practice and should
be easy to implement at any rate. Your ISO 14001, Global Reporting
Initiative, CERES Principles, Responsible Care Program®, balanced
scorecard, six sigma, ISO 9000, and other environmental and quality
initiatives will help you score points in each of the criteria. They all help
contribute to environmental excellence. This program simply provides
a means of integrating these approaches with environmental perfor-
mance in your organization.
The P2 plan should be integrated with the core business prac-
tices. "Oh, that is something that the environmental coordinator is do-
ing!"—such an attitude can only limit results. By making the P2 plan
more businesslike, the possibilities for P2 within the organization and
across the country are significantly enhanced.
-------
SUPPLEMENTAL READING
"How do you measure environmental performance?" Pojasek, R.B.
Environmental Quality Management, 10(4), 2001.
"New Mexico's Green Zia Environmental Excellence Program: Using
a Quality Model for a Statewide P2 Program," 1999,
Gallagher, P., Kowalski, J., Pojasek, R. B., and Weinrach, J.
Pollution Prevention Review, 9(1): 1-14.
Green Zia Environmental Excellence Program: 2001 Program
Information and Application Guidance, New Mexico
Department of Environment, Santa Fe, NM, 2001.
WEB SITES
Systems Approach Tools:
http://www.Pojasek-Associates.com
Information on the Baldrige Quality Award Program:
http://www.quality.nist.gov
New Mexico Green Zia Program Information:
http://www.nmenv.state.nm.us/ (See Special Projects)
Using a Quality Model to Implement P2
-------
-------
CHAPTER 8
Finding Your Own Way to
Implement P2
INTRODUCTION
This Guide has presented three approaches to implementing a P2
program: traditional based, EMS based, and quality based. All three
approaches can be improved by using the process characterization,
problem-solving, and decision-making tools that are described in Chap-
ter 4. Your organization may already have some type of P2 program in
place. It may be seeking only to improve its existing program or may
not feel that there is time to implement a brand new program following
any of these three approaches. This chapter will discuss some of the
items that are covered in these approaches to provide you with some
ideas for planning and implementing a P2 program that is specific to
your organization's requirements and culture. Let's take a look at the
program elements in each of these approaches to see where they have
commonality. From this analysis, the elements that your organization
should strive for as it implements the P2 program may be apparent.
We also will look at the various planning elements that were de-
scribed in Chapter 3 of this Guide and the concept of guiding principles
or core values. It will be important to see how these mesh with or re-
main separate from the implementation elements. The implementation
elements that will be covered in this chapter are as follows:
•
Extent of plannin
Leadership
P2 goal setting
Focus on results
Information and analysis
Process management
Employee participation
Focus on interested parties
Guiding principles or core values
P2 program elements
Includes:
D Introduction
D Extent of Planning
D Leadership
D Setting P2 Goals
D Focus on Results
D Information and Analysis
D Process Management
D Employee Participation
D Focus on Interested
Parties
D Guiding Principles
D P2 Program Elements
D Now It's Your Turn
All three approaches can be
improved by using the pro-
cess characterization, prob-
lem-solving, and decision-
making tools that are de-
scribed in Chapter 4.
This chapter will discuss some
of the items that are covered
in these approaches to pro-
vide you with some ideas for
planning and implementing a
P2 program that is specific to
your organization's require-
ments and culture.
Each of these elements should be addressed in the P2 program.
EXTENT OF PLANNING
The three approaches run the full gamut of planning. You will need
to determine the effort your organization wants to devote to planning as
you seek to implement or improve the P2 program.
You will need to determine the
effort your organization wants
to devote to planning as you
seek to implement or improve
the P2 program.
Finding Your Own Way to Implement P2
-------
In the EMS-based implemen-
tation P2 program, much of the
planning is specified in the
guidance set forth in ISO
14001 or other EMS guidance
documents.
The quality-based P2 program
places more emphasis on the
recognition of environmental
matters in the organization's
strategic plan.
There is some upfront planning involved in the traditional P2 pro-
gram. It is modeled around assessments that are conducted in the
workplace. Adding process mapping to this approach will help find more
opportunities for P2. This does not greatly increase the amount of plan-
ning in the process, however. When this program was prepared in the
late 1980s, many people saw a need to just get in there and get started.
A program can be developed from these initial efforts. What happened
is that the initial efforts ran out of steam, since there was no program to
guide continual improvement. Once the easy issues were addressed,
it was difficult for the P2 efforts to continue.
In the EMS-based implementation P2 program, much of the plan-
ning is specified in the guidance set forth in ISO 14001 or other EMS
guidance documents. You will recall that the EMS implementation in-
volves employees and has action plan requirements. Also, recall that
the EMS implementation includes management involvement and con-
tinual improvement. In setting the EMS objectives and targets, the or-
ganization must consider the following items: (1) its significant envi-
ronmental impacts, (2) legal and other requirements, (3) the views of
external parties and societal concerns, (4) technical options and op-
erational feasibility, (5) financial requirements for paybacks, and (6)
business requirements for marketability and profitability. This involves
planning. Planning is very important in the EMS approach to P2. While
there is no requirement that the EMS program be integrated into the
strategic planning of the organization, as shown in Chapter 6 the pro-
gram would be much more successful if it was so integrated.
The quality-based P2 program involves planning in the following
areas:
1. Strategy
2. Formal action
3. Integration and implementation
This approach to P2 places more emphasis on the recognition of
environmental matters in the organization's strategic plan. Even if the
organization does not have a formal strategic planning capability, envi-
ronmental thinking must make it into the executive suite. An entire part
of the evaluation is dedicated to strategic planning. Some questions to
ask of the P2 planning efforts in this regard may be found in Box 8-1.
These questions, which also can be used in the traditional and EMS
approaches, can help align the P2 program with the strategic thrust of
your organization. Any progress made in this direction will help inte-
grate P2 into mainstream activities.
-------
Box 8-1. Questions to Ask About the Planning Component
the
Consider strategic planning for environmental improvement as you ask the
following questions (Reference 8-1). These questions are designed to ask
"how" so that you can compare your organization's performance to others.
Howdoes your organization:
• Use information from the environmental management system in other
organizational planning initiatives?
• Consider the long-term environmental impact of the business on its
quest for sustainability?
• Anticipate and mediate external environmental impacts?
• Include employees in environmental planning?
• Involve vendors, suppliers, customers, and others?
Consider formal action planning as you ask these questions:
Ho ware:
• Formal action plans developed to support process analysis and im-
provement (P2) efforts?
• Employees included in the development of action plans?
• Suppliers, vendors, customers, and other interested parties included in
the development of action plans?
• Action plans assessed and improved on from year to year?
To determine if your P2 program fosters integration and implementation with
other organizational programs, ask these questions:
Ho ware:
• Action plans implemented, tracked, modified (for continual improve-
ment), and communicated to all interested parties?
• The action plans linked to the strategic planning process of the organi-
zation?
• Resources aligned to support improvement (P2) efforts?
• All the results from the programs disseminated to support organiza-
tional learning and improvement of the environmental management pro-
cess?
• Environmental management processes formally maintained and im-
proved?
The quality-based P2 approach and the EMS approach require writ-
ten action plans. The EMS-based approach requires environmental
management programs (EMPs) as written action plans. These docu-
ments are used to track progress made during the year on all sched-
uled P2 projects and activities. They are auditable by independent third
parties. The Systems Approach tools help gather the information needed
for comprehensive action plans. At the end of the year, it is possible to
perform a "lessons learned" review of each of the action plans or EMPs
and a decision can be reached on what to do in the following year.
strategic planning
action planning
integration and implementation
with other organizational
programs
Finding Your Own Way to Implement P2
-------
It is important that P2 activities
not be restricted to the envi-
ronmental professionals in an
organization.
All the implementation models
presented require a policy
statement that is endorsed by
the top management of the
organization.
Leadership is encouraged in
the quality-based P2 approach
by recognizing the importance
of both senior leadership and
community leadership.
The final aspect of the quality- and EMS-based P2 approaches is
the actual integration and implementation of P2 activities with other
organizational programs. It is important that P2 activities not be re-
stricted to the environmental professionals in an organization. Employee
teams from different departments need to be involved. The oversight
committee should be composed of senior managers representing dif-
ferent functions within the organization. Whenever possible, it is pru-
dent to look at their planned activities to see which ones have potential
for P2 involvement. In this manner, the planned integration will be much
more effective.
An emphasis on planning is important no matter which approach
your organization uses. Although your organization may choose not to
have planning dominate your P2 program's implementation, you should
seek to improve your planning efforts each year by asking the ques-
tions provided and enhancing the program incrementally. Your organi-
zation could gradually increase the level of planning by answering those
questions. In this manner, your organization will be integrating the P2
program into the core business practices.
LEADERSHIP
All the implementation models presented require a policy state-
ment that is endorsed by the top management of the organization. Some
important differences exist, however.
In the traditional approach, a "top-down" focus was encouraged.
Management approval was sought before the P2 program was started.
This commitment to the program was communicated to the workforce
using the policy statement. Management names the P2 task force. Al-
though management often saw P2 reports and success stories, this
information loop sometimes did not provide for strong support for con-
tinual improvement.
The EMS-based Implementation Approach also seeks to have top
management periodically review EMS implementation and effective-
ness. Experience has shown clearly that program success is largely
dependent on maintaining the involvement of senior management. The
EMS is a management system that allows organizations to address
the environmental issues in a systematic, organized fashion based on
continual improvement—just like any other area of the organization.
The EMS approach described in this Guide focuses on all manage-
ment issues, including attainment of objectives, completion of correc-
tive actions, effectiveness of policy, and cost-driven targets.
Leadership is encouraged in the quality-based P2 approach by rec-
ognizing the importance of both senior leadership and community lead-
-------
ership. Senior leaders must demonstrate a commitment in this
approach. Refer to the questions in Box 8-2 to see how to reach best-
in-class status in this area. Striving to get positive answers to these
questions will help the organization improve the management compo-
nent of the P2 program.
Box 8-2. Questions to Ask About the Leadership Component
Howdoes senior management:
• Demonstrate commitment to continual environmental improvement on
par with other major organizational goals?
• Conduct proactive communication with all interested parties?
• Provide support for continual environmental improvement?
• Assure that continual environmental improvement is integrated, reviewed,
and tracked?
Ask these questions about the community leadership components of the P2
program and Aiowyour organization accomplishes the following tasks.
Howdoes your organization:
• Initiate and support environmental protection and sustainability efforts
in the community?
• Seek to understand environmental issues specific to the community
and address those issues with strategies, actions, and collaborative
efforts?
• Support mentoring of other organizations in the community to promote
P2 and continual improvement?
• Set affirmative procurement goals?
• Communicate your environmental performance to the community?
How does senior management
demonstrate commitment to
continual environmental
improvement on par with other
major organizational goals?
community leadership
Many senior managers also recognize the importance of being a
good corporate citizen in the local community. In the quality approach,
good corporate citizenship goes beyond giving to local charities. The
P2 ideals of the organization need to be promoted to all the local inter-
ested parties as a demonstration of the senior leadership's commit-
ment to these ideals.
Senior leadership (i.e., those people to whom the environmental
manager reports) must "walk the talk" to provide true leadership to the
P2 program. A good "bottom-up" program with a results focus may
help senior management go this extra distance. The literature on qual-
ity improvement and change management stresses the importance of
having serious commitment from top management. Finding a way to
gain this advantage will promote the implementation of your
organization's P2 program.
Senior leadership must "walk
the talk" to provide true leader-
ship to the P2 program.
The literature on quality im-
provement and change man-
agement stresses the impor-
tance of having serious com-
mitment from top manage-
ment.
Finding Your Own Way to Implement P2
-------
SETTING P2 GOALS
In the traditional approach, the
purpose of the P2 program is
to meet these pre-set goals.
The EMS approach selects
significant aspects and sets
objectives and targets after
studying the environmental
impacts of the organization's
activities, products, and
services. Objectives are the
overall environmental goals
that an organization sets out to
achieve.
In the quality-based P2 ap-
proach, the goals are not
formally set until after the
action plans are prepared.
Many believe that stretch
goals of zero waste and
emissions are best since it will
take both continual improve-
ment and some breakthrough
thinking to get there.
In the traditional approach, senior management sets the goals for
P2 before any formal information is gathered. This is based on the
philosophy of "management by objectives." The purpose of the P2 pro-
gram is to meet these pre-set goals. Much of the literature on goal
setting supports this approach.
The EMS approach selects significant aspects and sets objec-
tives and targets after studying the environmental impacts of the
organization's activities, products, and services. Objectives are the over-
all environmental goals that an organization sets out to achieve. Action
plans (EMPs) are written to meet the goals and objectives in the planned
time frame.
In the quality-based P2 approach, the goals are not formally set
until after the action plans are prepared. Each action plan has perfor-
mance goals set for each step. The sum of the performance goals
listed in the action plans are the goals for the period of time set forth in
the planning sequence (i.e., typically one year). It is possible to have
some action plans cover a longer time span, so that two-year goals
can be set. It is important to set only continual improvement goals.
Many believe that stretch goals of zero waste and emissions and con-
tinual improvement will increase the likelihood that significant strides
will be made.
FOCUS ON RESULTS
Results will demonstrate whether goals have been met. Continual
improvement is based on careful measurement and trending of the
actual results. Maintaining top management support is based on achiev-
ing these results. A focus on results is an important part of any P2
program.
The traditional approach involves the collection of results from the
various P2 activities and placing them into reports that are prepared for
each effort. Sometimes the results are plotted, such as reduction in
the use or emissions of certain regulated chemicals. In some cases,
financial savings are given.
The EMS approach requires procedures to monitor and measure
environmental performance, to record information that tracks opera-
tional controls and conformance with the objectives and targets, and to
evaluate compliance with environmental regulations. Top management
reviews these results on a periodic basis.
In the quality-based P2 approach, results represent the most im-
portant element. It is weighted with nearly one-third of the total evalua-
tion points provided in the seven categories. Results are segmented
into three items: environmental results; customer, supplier, employee,
-------
and other results; and financial results. The environmental results look
at current levels and trends just as the other approaches do. The sec-
ond segment of the results summarizes customer, employee, com-
munity, supplier, market, and other interested-party results within the
context of the continual environmental improvement approach. In other
words, how is their perception of your organization's environmental
excellence changing? The third segment of the results summarizes
the financial performance results related to the implementation of your
continual environmental improvement approach.
The organization's results need to convey levels (the current level
of environmental performance reported graphically), trends (multiple
data points presented graphically), and comparative data (how your
organization is performing with respect to similar organizations). It may
take a few years to build strong results, but it is an important means of
improving your organization's P2 program. The link between environ-
mental and financial results is very important. All environmental results
can be "translated" into financial results. This is the best means avail-
able to get and maintain top management leadership in the P2 pro-
gram. Make establishing this connection a priority as you plan a new
P2 program or seek to improve an existing one.
INFORMATION AND ANALYSIS
It is necessary to examine how your organization uses information
in order to identify and evaluate environmental aspects of products,
services, or production processes. It is also important to determine
how this information is used to assess service, product, or process
performance and to identify areas for improvement (i.e., P2 opportuni-
ties) based on environmental considerations.
Most of the information in the traditional approach comes from as-
sessments performed in the workplace. Checklists are often used to
gather information for the analysis of each P2 project. Everything is
usually handled on a project-by-project basis.
In the EMS approach, information is gathered on the aspects of the
organization and analyzed on a general level to determine the signifi-
cant environmental impacts and to set EMS objectives and targets.
Further information is required for each of the environmental manage-
ment programs. Documentation is maintained in the EMS to track in-
formation and make it available for analysis. This is an important ele-
ment in the quest for continual environmental improvement.
In the quality-based P2 approach, information and the analysis of
that information play a pivotal role in the program. The information and
the results should be linked and used in the planning efforts. Manage-
ment can use these items to make P2 a central issue in the day-to-day
operation of the organization.
The link between environmen-
tal and financial results is very
important. All environmental
results can be "translated" into
financial results. This is the
best means available to get
and maintain top management
leadership in the P2 program.
It is important to determine
how this information is used to
assess service, product, or
process performance and to
identify areas for improvement
(i.e., P2 opportunities) based
on environmental consider-
ations.
Finding Your Own Way to Implement P2
-------
In Box 8-3, there are some questions that may help determine how
information is collected and analyzed in the P2 program.
Box 8-3. Questions to Ask About the Information and Analysis
Component
How does your organization:
• Measure resource use efficiency and environmental losses?
• Determine environment, health, and safety requirements?
• Understand the true cost of a product, service, or production process?
• Determine the environmental impacts of a product, service, or produc-
tion process through its life?
• Use information to document organization-wide environmental activi-
ties?
• Track your competitors' "green" trends and use this data in product
design?
• Analyze information to prioritize areas for improvement?
• Use information and results to identify organization-wide areas for im-
provement (e.g., P2 opportunities)?
• Use comparative information to assess and improve its environmental
performance (i.e., benchmarking)?
• Evaluate competitors and market trends in the formulation of its envi-
ronmental strategies?
For the program to be results-
driven, there will have to be an
organized means for managing
information and analysis in
your P2 program.
For the program to be results-driven, there will have to be an orga-
nized means for managing information and analysis in your P2 pro-
gram. The tools in Chapter 4 provide some order to the program and a
good starting point. By selecting more items from the questions, you
can drive continual improvement.
PROCESS MANAGEMENT
The traditional approach is project-based and does not place a
great deal of emphasis on process. Assessments are used to locate
opportunities for P2 and a project is set forth to minimize or prevent
waste at that location. These assessments may not find other points at
which the P2 opportunities can be leveraged. Furthermore, the assess-
ments may not involve the institutionalization of P2 by changing the
process of environmental management.
On the other hand, the EMS- and quality-based approaches em-
phasize process; both ask the type of questions that can be found in
Box 8-4. A strong EMS is a vital component of the quality-based P2
approach and will help the organization attain a maximum number of
points in this criterion.
Process mapping and resource accounting as described in Chap-
ter 4 help measure and report the results of reducing your environmen-
tal impacts. The organization will benefit by addressing the issue of
-------
process management when implementing the P2 Program. Using the
Systems Approach tools will provide a head start in this direction.
Box 8-4. Questions to Ask About the Environmental Process
Management Component
How does your organization:
• Conduct analysis of all pertinent processes to identify environmental
issues (aspects)?
• Involve employees, customers, and suppliers in process analysis?
• Use its environmental management system to manage processes in
day-to-day operations?
• Conduct process analysis of corrective actions or other nonoperational
problem areas?
• Improve its process analysis system?
• Systematically prioritize areas for continual improvement?
• Develop action plans to improve processes?
• Involve employees, customers, and suppliers in identifying and imple-
menting process improvements?
• Manage processes to meet or exceed environmental performance
goals?
• Communicate information on improvement projects to ensure organiza-
tional learning?
• Use benchmarking as part of ongoing process improvement activities?
• Improve its process improvement system?
EMPLOYEE PARTICIPATION
All approaches include employee involvement. Both the EMS- and
quality-based approaches address employee education and skill de-
velopment. The quality-based approach also emphasizes employee
satisfaction and well being. As more and more organizations address
the issue of sustainable development and its focus on the social as-
pects of environmental issues, it will become more important to pay
attention to the well being of the employees.
It is always informative to walk around a facility and randomly ask
employees what they know about the organization's P2 program. Hav-
ing a P2 policy statement hanging on the wall does not ensure that the
employees will be able to participate effectively in the program. When-
ever an organization undertakes a new management program, quite a
bit of time is spent preparing the employees for participation in that
program. It makes sense that the same would hold true for P2.
Box 8-5 lists some questions to ask about employee participation
in a P2 program.
Employee involvement plays a key role in any successful P2 pro-
gram, so it is important to be diligent in promoting it.
Having a P2 policy statement
hanging on the wall does not
ensure that the employees will
be able to participate effec-
tively in the program.
Employee involvement plays a
key role in any successful P2
program, so it is important to
be diligent in promoting it.
Finding Your Own Way to Implement P2
-------
Box 8-5. Questions to Ask About the Employee Participation
Component
How does the organization:
• Assess employees' skills and determine and align their training
needs to the continual environmental improvement approach?
• Promote employee input to the training program to improve environ-
mental performance?
• Use the training program to encourage employees to share and dis-
seminate the ethic of environmental excellence outside of the work-
place?
• Assess and improve its environmental training program ?
• Involve employees in product, service, and process design for continual
environmental improvement?
• Encourage and support broad employee involvement in P2 programs?
• Involve employees in the development of action plans and align human
resources to implement action plans?
• Ensure that employees are up to date about the organization's P2
successes?
• Encourage employee participation to address specific community en-
vironmental issues?
• Considerthe inside work environment (i.e., employee health and safety
concerns) when designing work areas or making process improvement
decisions?
• Gather input on the work environment from employees?
• Motivate and reward employee participation in the organization's envi-
ronmental improvement program?
• Assist employees in dealing with life issues that can impact their abil-
ity to do work?
• Assess employee satisfaction?
Some organizations have
already begun to extend their
EMS program to the supply
chain. It is logical to extend
this involvement to the P2
program as well.
FOCUS ON INTERESTED PARTIES
The EMS- and quality-based approaches clearly recognize the im-
portance of having ties with regulators, customers, suppliers, and a
host of other interested parties. The traditional approach provides for
technology transfer, but it does not seek feedback on environmental
concerns of the interested parties.
By addressing the questions asked in Box 8-6, your organization
can move in the direction of involving interested parties in the P2 pro-
gram. Some organizations have already begun to extend their EMS
program to the supply chain. It is logical to extend this involvement to
the P2 program as well. Customers need to see decisions regarding
the products and services in light of what the environment, health, and
safety implications may be throughout the life cycle. Other interested
parties need to see how their actions affect the organization's ability to
effectively implement and integrate P2 into its core business practices.
-------
Box 8-6. Questions to Ask About the Other Interested-Party
Component
How does your organization:
• Communicate with customers to assess their needs and satisfaction
regarding the environmental impact of products and services?
• Solicit and use customer feedback for environmental improvements?
• Work with customers to encourage effective product and environmental
stewardship?
• Support the P2 and continual environmental improvement efforts of cus-
tomers?
• Market "green" products, services, and processes?
• Develop markets for new and/or "greener" products and services?
• Involve suppliers, contractors, and vendors in the development and im-
provement of products, services, and processes as part of the con-
tinual environmental improvement program?
• Evaluate suppliers, contractors, and vendors for their environmental
performance?
• Support the P2 or environmental improvement efforts of suppliers, con-
sultants, contractors, and vendors?
• Work with oversight agencies to manage compliance in a mutually bene-
ficial fashion?
• Communicate continual environmental improvement goals and action
plans to interested parties to gain feedback, support, and buy-in?
• Develop systematic processes for timely reporting of reportable events/
activities to appropriate interested parties?
• Work with oversight agencies to develop regulations and compliance
approaches that encourage P2?
• Provide a regular, independent evaluation of successes made in the
program?
• Communicate results to interested parties?
P2 cannot be thought of as a strictly internal matter. It is becoming
much more important to consider other interested parties when con-
ducting a P2 program.
GUIDING PRINCIPLES
Unlike the traditional approach, the EMS- and quality-based ap-
proaches seek to align the P2 program with the organization's guiding
principles or core values. Many experts feel that guiding principles are
essential to the successful integration of P2 into core business prac-
tices. The guiding principles that are presented in Chapters 6 and 7 are
as follows:
1. I nterested-party-driven P2
2. Leadership
3. Continual improvement and learning
P2 cannot be thought of as a
strictly internal matter. It is
becoming much more impor-
tant to consider other inter-
ested parties when conducting
a P2 program.
Finding Your Own Way to Implement P2
-------
4. Valuing employees
5. Fast response
6. Efficient product, service, and process design
7. Long-range view of the future
8. Management by fact
9. Partnership development
10. Public responsibility and citizenship
11. Results focus
12. Prevention of pollution
13. Compliance with legal requirements
The guiding principles are used to drive the P2 program's objectives
and targets.
P2 PROGRAM ELEMENTS
The six program elements for a P2 program using any of the ap-
proaches have a number of now-familiar items:
Provide for top management support
Characterize the process
Perform periodic assessments
Conduct program evaluations
Each of these items is covered in the implementation chapters
(Chapters 5-8).
Two crucial program elements require consideration as you de-
velop or seek to improve the P2 program. These are:
i
1. Maintaining a cost allocation system
2. Encouraging technology transfer
The importance of communicating with top management in finan-
cial terms is quite clear. It is important to determine the real cost of all
resource use and loss in the process (including all ancillary and inter-
mittent processes). It is important to translate environmental perfor-
mance measured in volume and weight into financial terms. Some basic
information on this topic can be found in Chapter 4. Additional material
on this and on EPA's Environmental Accounting Project is available on
the CD-ROM. The quality-based P2 approach scores the ability to evalu-
ate costs effectively. In most cases, this evaluation is required to get
and maintain top management approval for the program.
-------
Technology transfer is very important to the propagation of P2. The
Baldrige program requires winners of the award to go out and speak
about what it takes to be successful with this program. Many winners
give more than 100 speeches the year after they win. The EMS ap-
proach encourages organizations to mentor suppliers and contractors.
Both approaches willingly share their successes so others can follow.
NOW IT'S YOUR TURN
This Guide has presented a number of useful P2 implementation
approaches. It is up to your organization to use them and get started
with a program that will work in your organization. The CD-ROM will
provide you with the information needed to move forward.
This Guide was not written to provide a "one-size-fits-all" formula
for starting or improving a P2 program. Its intention is to spark some
ideas and provide tools that you can use to successfully complete your
organization's mission.
Finding Your Own Way to Implement P2
-------
-------
INDEX
A
Accounting procedures, 43
Action plans, 17, 64
EMS environmental management programs, 90-91
quality-based program, 116-117,122-123
traditional P2 program, 71
Alternatives for P2 problem, 72
brainstorming, 61
brainwriting, 61-62
bubble-up/bubble-down, 62-63
criteria matrix, 62-63
forced pair analysis, 62-63
generating, 61-62
provocation technique, 62
selecting alternative for implementation, 62-64
selection grid, 62
American Chemistry Council (ACC), 3, 44
Analysis
cost and benefit, 42
forced pair, 17, 62-63, 116
information, 38-39, 105, 114, 115, 127-128
objective gap, 81
Pareto, 57-58, 70, 115
production unit, 115-116
root cause, 17, 59-60, 74-75, 116
Aspect identification, 87
Aspects, 86-87, 97
Assessment
environmental performance, 93-94, 111
need for objective data and analysis, 38-39
P2 opportunities, 41-42
periodic updates, 42, 45, 64, 132-133
program, 44
in traditional P2 program, 70, 71-72
use of checklists, 65-66
Audits
compliance, 82, 95
gap analysis, 81
B
Baldrige criteria, 25
BAT (best available technology), 82
-------
Benefits of P2, 1, 11-13
continual improvement, 13
enhanced public image, 13
immediate, 27
improved worker safety, 11-12
increased environmental protection, 12
increased productivity, 12
reduced costs, 11, 12
reduced exposure to future liability, 12
resource conservation, 13
Best available technology, 82
Best management practices (BMP), 52
BMP (best management practices), 52
Bottom-up approach, 2, 26, 70, 125
Brainstorming, 17, 61, 72
Brainwriting, 17, 61-62,116
Bubble-up/bubble-down (forced pair analysis), 17, 62-63,116
C
Cause-and-effect diagram, 17, 59-60, 75, 116
CD-ROM, 6-7
Change
acceptance of, 27-28, 46, 50
behavioral, 27-28
change management, 28, 46
dealing with, 28-30
facilitating, 30, 50
intra-organizational teams, 50
management of, 28, 50, 56
process changes in EMS, 92
Checklists, 50, 65-66, 67
Cleaner production, 22, 23
Climate Wise, 97
Communication, 29, 74
of EMS policy, 84
external and internal, 84
traditional P2 program, 74
Complexity in P2 program, 29-30
Compliance audits, 82, 95
Conservation, resource, 13, 23, 40
Continual improvement, 13, 37, 67, 93
as core value, 37, 107-108
EMS program, 95-96
management review and, 95-96
Quality model, 107-108, 112-118, 131-132
Continuous improvement, 13
Core business practices, integration of P2 into, 2, 10, 24-26
-------
Core values, 35-40
corporate responsibility and citizenship, 39, 111
fast response, 39-40, 109
goal of continual improvement, 37, 107-108
interested party-driven P2, 36,107,131
leadership, 36-37, 107
long-range outlook, 38
management by fact, 39-40
partnership development, 39,110-111,132
quality and prevention, 38
valuing employees, 37,108-109, 131-132
See a/so guiding principles
Corporate citizenship and responsibility, 39, 111, 125
Corrective actions, 96, 98
Cost and benefit analysis, 42
Cost of the loss, 56-57
general ledger costs, 56
lost resources, 56-57
management of non-product loss, 57
Costs
compliance, 12
cost allocation systems, 42-43
determining cost of the loss, 56-57
future liability, 12
information updating, 42
operating, 11
savings with EMS programs, 88
tracking with Systems Approach, 53, 56
true, 42, 43
valid product, 43
Cost vs. volume/weight of waste, 58-59
Criteria matrix (selection grid), 17, 62
Customers, 14, 39
D
Decision-making, 17
Design, 109
Design for Environment (DfE), 11, 19, 38, 97
Documentation, 91, 99, 114
Dupont mission statement, 34
Dupont vision statement, 32
E
Eco-efficiency, 22-23
Education, 44, 73, 74
employee, 73, 89-90
public, 29, 44, 74
-------
EHS (environment, health and safety) management, 101-102
80/20 rule, 16,57,59
Embedded goals, 107-108
Emergency preparedness, 96
Employee participation, 26, 39,116-117, 129-130
award programs, 74
educational training, 73
EMS training and responsibility, 89-90
growth opportunities, 37
valuing, 37,108-109,132
EMPs (Environmental Management Programs), 5, 90-91
EMSs. See Environmental management systems
Energy intensity, 22
Environmental accounting, 43
Environmental Accounting Project (EAP), 11
Environmental awareness training, 89-90
Environmental compliance audits, 82, 95
Environmental excellence, 5, 101
Environmental, health and safety (EHS) management, 101-102
Environmental impacts, 86-88, 97-98
Environmentally Preferred Purchasing (EPP), 11
Environmental Management Programs (EMPs), 5, 90-91
Environmental Management Systems: An Implementation Guide for Small and Medium-Sized
Organizations, 87
Environmental management systems (EMSs), 5, 24-25, 79-100
aspects, 86-91
checking and corrective action, 93-94
communication of EMS policy, 84
emergency preparedness, 96
environmental impacts, 86-91
Environmental Management Programs (EMPs), 90-91
environmental policy, 83-84
getting started, 80-83
implementation, 91-94
ISO 14001 format, 24, 79
lessons learned, 96-99
management commitment, 83-84
management review and continual improvement, 95-96
monitoring and measurement, 94-96
objectives and targets, 88-89
operational control, 92-93
planning, 85-91
principles, 79-80, 96
process management, 128-129
process mapping, 80, 81
scope of EMS, 83-84
spill prevention, 96
training and responsibility, 89-90
-------
Environmental manager, 26
Environmental policy, 83-84
Environmental protection, 12
Environmental Protection Agency
Design for Environment (DfE), 11, 19, 38, 97
Environmental Accounting Project, 19
Environmental Performance Track program, 83
pollution prevention definition, 21
EPA. See Environmental Protection Agency
EPP (environmentally preferred purchasing), 11
Evaluation. See assessment
External partnerships, 39, 110-111
F
Facility Pollution Prevention Guide, 1, 9, 69
Fast response, 39-40, 109, 132
FDA (Food and Drug Administration), 14
Fishbone diagram, 17, 59-60
Food and Drug Administration (FDA), 14
Forced pair analysis (bubble up/bubble down), 17, 62-63, 116
G
Gap analysis audit, 81
Goal setting, 31, 34, 75
continual improvement, 37,107-108
embedded goals, 107-108
EMS programs, 80-81, 126
Goals statement, 31, 34
Quality model, 126
traditional P2 approach, 126
Green Lights, 97
Green Zia Program, 5, 25, 76, 101, 102
Guiding principles of P2, 36, 106-112, 131-132
EMS programs, 96
quality-based program, 106-112
See a/so Core values
H
Hierarchical process maps, 41-42, 52-55, 114, 115
I
Impediments to P2 use, 1, 13-15
Implementation, 26,62-64
customizing for your organization, 121-133
EMS programs, 91-94
quality-based program, 118-119
revised P2 program, 116-117
traditional P2 program, 71-73, 76-77
-------
Implementation elements
employee participation, 129-130
extent of planning, 121-124
focus on interested parties, 130-131
focus on results, 126-127
goal setting, 126
guiding principles, 131-132
information and analysis, 127-128
leadership, 124-125
P2 program elements, 132-133
process management, 128-129
See a/so Program elements
Improvement
continual (see Continual improvement)
continuous, 13
incremental, 67, 75, 107
opportunities, 57-58
P2plan, 112-118
Incremental improvements, 67, 75, 107
Indicators, 35, 94-95
Inertia, 15
Information analysis, 38-39, 105, 114, 115, 127-128
EMS-based program, 127
quality-based program, 127-128
traditional P2 program, 127
Information sharing, 43
Information sources, 19
See a/so Web Sites
Insurance/risk management, 26
Integrated Environmental Management Systems Implementation Guide, 87
Integration into core business practices, 24-26
environmental management systems, 24-25
insurance/risk management, 26
preventive/predictive maintenance, 25
quality initiatives, 25
safety, 26
Interested party-driven P2, 36,107,131
Internal partnerships, 39,110-111
International Organization for Standardization (ISO), 24
ISO 9000, 25
18014001,24,79,80,82
ISO (International Organization for Standardization), 24
J
Juran, J. M., 58
-------
L
Leadership
as corporate citizen, 39
EMS-based program, 124
getting and maintaining top management, 127
as guiding principle, 36-37,107,131
management commitment, 37, 46, 93
Quality model, 103, 107, 124-126, 131
tradition P2 program, 124
Lean manufacturing, 10
Learning, 107-108
Legal requirements, 82-83
Long-range outlook, 38
Loss
cost of the loss, 56-57
determining the cost, 56-57
management of non-product, 57
non-product, 56, 57
process, 23, 53
weight vs. cost of loss, 58-59
Low hanging fruit, 63, 72
M
Malcolm Baldrige National Quality Program, 5, 25,101
Management
leadership commitment, 37, 46, 83-84, 93
program, 17-18
representative in EMS, 85, 99
review by, 95-96
role of, 26, 27, 37
strong guiding team, 29
Systems Approach and, 50
top management support, 40-41, 46, 82, 132-133
See a/so Leadership
Management by fact, 39-40, 110,132
Material intensity, 22
Material recyclability, 22,23
Material safety data sheets (MSDSs), 52-53
Measuring environmental performance, 93-94,111
Mission statement, 31, 33-34
Monetary metrics, 16
Monitoring P2 performance, 93-96,111
MSDSs (material safety data sheets), 52-53
Multi-State Working Group (MSWG), 79, 83
-------
N
National Park Service vision statement, 32
National Pollution Prevention Roundtable, 44
Non-product loss, 53, 56, 57
Non-product use, 53
Nonproprietary knowledge, sharing, 43
Nothing to Waste, 49, 75-76
Nothing to Waste program, 75-76
O
Objective gap analysis, 81
Occupational Safety and Health Administration (OSHA), 97
Olin vision statement, 32
Opportunities
80/20 rule, 57, 59, 115
assessment, 41-42
developing, 115-116
Pareto analysis, 57-58, 115
rank ordering, 58,115
selecting, 57-59
Options. See alternatives
Organizational waste, 10
Organization image, 15
OSHA (Occupational Safety and Health Administration), 97
Overhead allocation, 43
P
P2 (pollution prevention)
alternative view of, 15-18
benefits of, 11-13
decision-making, 17
definition, 21
as environmental program, 28
evolution of, 9-11
impediments to use of, 13-15
implementation with quality-based program, 118-119
improving P2 plan, 112-118
lessons from past programs, 27-28
maintaining P2 program, 73-74, 117
as mindset, 27
opportunities, 16
planning (see Planning)
problem solving, 17
program elements, 3, 31-47
program evaluation, 44
program management, 17-18
starting P2 efforts, 27
steps in, 15-18
-------
tools (see Tools)
traditional P2 program, 15
P2 (pollution prevention) assessment, 41-42
hierarchical process maps, 41-42
periodic updates, 42, 45, 64, 132-133
process characterization, 41
P2 Resource Exchange (P2Rx), 11
Pareto analysis, 57-58, 70, 115
Pareto chart, 16, 58
Pareto Principle, 57
Partnership development, 39, 110-111,132
Planning
action (see Action plans)
EMS program, 85-91, 122
for P2 implementation, 121-124
program, 31-47, 107
Quality model, 122-123
strategic, 103
traditional P2 program, 70, 71-72, 122
Pollution Prevention Act, 21
Pollution Prevention Code of Management Practices, 44
Prevention of pollution, 24, 84
Preventive/predictive maintenance, 25
Preventive procedures, 96, 98
Prioritization tools, 62-63
Problem solving, 17
Process changes and operational control in EMS, 92
Process characterization, 41-42, 51-52, 74
Process loss, 23, 53
Process management, 114, 128-129
EMS program, 128
quality-based program, 128
traditional P2 approach, 128
Process mapping, 9, 16, 51-56, 74
computerized, 53
EMS programs, 80, 81
hierarchical process maps, 41-42, 52-55, 114, 115
maps as templates, 52-53
resource tracking, 53, 55-56
traditional P2 program, 15, 69, 70, 71, 72, 73
Process safety management (PSM), 97
Product durability, 22
Production concerns, 14
Production models, biologically-inspired, 10
Production quality issues, 14
Production unit analysis, 115-116
Productivity, 12
-------
Program elements, 3, 4CM6, 132-133
cost allocation system, 42-43
opportunity assessment, 41-42
other elements, 44-45
periodic P2 assessments, 42-43, 132-133
process characterization, 41, 132-133
program evaluations, 44,132-133
technology transfer, 43
top management support, 40-41, 132-133
See a/so Implementation elements
Program management, 17-18
Program planning, 31-47
core values, 35-40
corporate responsibility and citizenship, 39, 111
designing quality and prevention together, 38
fast response, 39-40
indicators, 35
interested party-driven P2, 36,107
leadership, 36-37
long-range outlook, 38
management by fact, 39-40
mission statements, 31, 33-34
partnership development, 39
planning, 31-35
statement of goals, 31, 34
valuing employees, 37,108-109,131-132
vision statements, 31, 32-33
Project XL (excellence and Leadership), 97
Proper treatment, 21
Provocation technique, 62
Public image, 13, 15
Public outreach, 29, 44, 74
public responsibility and citizenship, 39, 111, 125
Q
Quality initiatives, 25
Quality model, 5-6, 26, 38, 44, 101-119, 122-124
action plans, 116-117, 122-123
Green Zia program, 101, 102
guiding principles, 106-112,131-132
continual improvement and learning, 107-108,131-132
efficient product, service and process design, 109
fast response, 109, 132
interested party-driven P2,107,131
leadership, 107,131
long-range view, 109-110
management by fact, 110, 131-132
-------
partnership development, 110, 132
valuing employees, 108-109,131-132
implementation, 116-117,118-119,124
improving the P2 plan, 112-118
developing opportunities, 115-116
implementing revised plan, 116-117
maintaining the program, 117
planning and development, 112-114
Malcolm Baldrige National Quality Award, 101
measuring progress, 117-118
model criteria, 102-106
employee involvement, 104
information analysis, 105
interested party involvement, 103-104
leadership, 103
process management, 104
results, 105
strategic planning, 103
public responsibility and citizenship, 111
strategic planning, 103
to implement P2, 118-119
Quick wins, 63, 72, 115
R
Rank ordering, 16, 58, 115
Recycling, 21,22, 23
Registration of EMS, 91
Regulators, 39
Regulatory compliance, 9-10, 35
Regulatory issues as impediment to P2 use, 14
Regulatory permit monitoring, 95
Requirements for success, 27-28
Resource accounting, 55, 128
Resource conservation, 13, 23, 40
Resource Conservation and Recovery Act, 40
Response time, 40, 109, 132
Responsible Care Program, 3, 44, 97
Results focus, 111
EMS-based program, 126
Quality model, 126-127
traditional P2 program, 126
Reviews of P2 programs, 44, 95-96
Risk management, 26
Root cause analysis, 17, 59-60, 74-75, 116
cause and effect diagram, 59-60, 75
80/20 rule, 59, 115
fishbone diagram, 59-60
-------
s
Safe disposal, 21
Safety, worker, 11-12,26
Selection grid (criteria matrix), 17, 62
Service intensity, 22
Six sigma, 24
Small organizations, 75-76, 87
SOP (Standard operating procedure), 52
Source reduction, 21
Specifications, 14
Spill prevention, 96
Stakeholders, 71
Standard operating procedure (SOP), 52
State mandated P2 planning, 10, 26
Statement of goals, 31, 34
Strategic needs and P2, 28
Strategic planning, 103
Suppliers, 39
Support from top management, 40-41, 46, 82, 132-133
Sustainable development, 2, 23-24
use of indicators, 35
Sustainable use of renewable resources, 22
Systematic approach, 87
Systems Approach, 3, 49-50
combining with traditional approach, 74-75
Systems Approach tools, 3-5, 49-64
action planning, 64
determining the cost of the lost, 56-57
generating alternatives, 61-62
process mapping, 51-56
root cause analysis, 59-60
selecting an alternative for implementation, 62-64
T
Targets of EMS, 88-89, 90, 98
Team approach, 26, 29, 50
EMS organizational teams, 85-86
multi-functional, 26
Technical expertise, 15
Technology transfer, 43
The Natural Step, 32
Time available, 15
Timing of P2 efforts, 27
Tools, 49-68
checklists, 65
Systems Approach, 3-5, 49-64
action planning, 64
determining the cost of the lost, 56-57
generating alternatives, 61-62
-------
process mapping, 51-56
root cause analysis, 59-60
selecting an alternative for implementation, 62-64
using P2 tools, 49, 66
Top-down approach, 2, 26, 70
Top management
management representative in EMS, 85, 99
support by, 40-41, 46, 82, 132-133
Total Quality Management (TQM), 25
Toxic emissions, 22
Toxic materials, substitutes for, 93
TQM (Total Quality Management), 25
Trade associations, 39
Traditional P2 program, 4-5, 69-77
combining with Systems Approach, 74-75
communication, 74
establishing P2 program, 70
maintaining the P2 program, 73-74
educational training, 73
integration into other P2 initiatives, 73
other implementation approaches, 76-77
planning, 70, 71-72, 123
process maps, 15, 69, 70, 71, 72, 73
program implementation, 71-73
top-down focus, 70
very small organizations, 75-76, 87
writing P2 program plan, 71
Traditional program, process management, 128
Training
EMS, 89, 99
environmental awareness, 89
U
Union Carbide mission statement, 33-34
U.S. Air Force Compliance Through Pollution Prevention, 12
USPS vision statement, 33
V
Valid product costs, 43
Valuing employees, 37,108-109,131-132
Very small organizations, 75-76, 87
Vision statements, 31, 32-33
VOC (volatile organic chemical), 14
Volume of waste vs. cost, 58-59
W
War on waste, 25
Washington State, 83
-------
Waste management hierarchy, 21
Waste Minimization Opportunity Assessment Manual, 1, 9, 69
WBCSD (World Business Council for Sustainable Development), 22
Web Sites
American Chemistry Council's Responsible Care, 47
ANSI-RAB information on registration, registrars, training and consulting, 100
Baldrige Quality Award Program, 119
Environmental Management System Demonstration Project, 100
Environmental Management System Primer for Federal Facilities, 100
EPA, 30
EPA Design for Environment, 19
EPA Environmental Accounting Project, 19
EPA Environmentally Preferable Purchasing (EPP), 100
EPA Environmental Performance Track, 100
EPA EPP Program, 19
EPA listing of State P2 programs, 30
EPA P2 Programs and Initiatives, 19
EPA Resource Exchange (P2Rx), 19
EPA Sustainable Industry, 19
Federal Register, 100
Green Zia manual, 47
Green Zia Program Information, 119
Maintenance Technology, 30
Mass environmental excellence paper, 47
MOEA'sEPP, 100
Multi-State Working Group, 100
NIST Baldrige, 30
NISTMEP, 19
Nothing to Waste Manual, 67, 77
NPPR, 19
NPPR Position Paper on Facility Planning, 47
OSHA, 30
SBDC, 19
State P2 Programs, 19
Sustainable Measures, 47
Systems Approach tools, 119
United Nations, 30
World Business Council for Sustainable Development, 30
Weight vs. cost of loss, 58-59
Worker involvement, 26
Worker safety, 11-12,26
Working capital, 75
World Business Council for Sustainable Development (WBCSD), 22
World Commission on Environment and Development, 23
Z
Zero waste/zero emission, 10, 23-24, 37, 102, 117-118
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U.S. DEPARTMENT OF ENERGY
MODEL POLLUTION PREVENTION
OPPORTUNITY ASSESSMENT GUIDANCE
Prepared under the direction of
U.S. Department of Energy
Office of Defense Programs
Revised December 1993
United States Department of Energy
Washington, DC 20585
| Printed with soy ink on recycled paper
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TABLE OF CONTENTS
Page
INTRODUCTION 1
A. PURPOSE OF GUIDANCE 1
B. GUIDANCE SCOPE AND OBJECTIVES 1
II. GRADED APPROACH 3
A. INTRODUCTION 3
B. GRADED APPROACH LOGIC DIAGRAM & PRIORITY LIST 3
C. LEVEL I - ACTIVITY CHARACTERIZATION 5
D. GRADED APPROACH WEIGHTED SUMS EVALUATION 6
E. LEVEL II - INFORMAL ASSESSMENT 7
F. LEVEL III - FORMAL ASSESSMENT 9
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT TEAMS 10
IV. ASSESSMENT OF PROCESSES AND WASTE STREAMS 11
A. INITIAL DATA GATHERING 11
B. PROCESS DESCRIPTION 11
C. PROCESS FLOW DIAGRAM 12
D. MATERIAL BALANCES 13
E. MEASUREMENT OF WASTE 14
F. WASTE STREAM CHARACTERIZATION 15
V. DEVELOPMENT AND EVALUATION OF WASTE
MINIMIZATION/POLLUTION PREVENTION OPTIONS 15
A. IDENTIFICATION OF WMIN/PP OPTIONS 15
B. PRELIMINARY SCREENING OF WMIN/PP OPTIONS 16
C. EVALUATION OF WMIN/PP OPTIONS 17
VI. FINAL REPORT 18
VII. APPENDIX 19
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APPENDIX
APPENDIX A: GENERAL CONSIDERATIONS FOR PRIORITIZING THE
ASSESSMENT OF WASTE STREAMS
APPENDIX B: SOURCES OF MATERIAL BALANCE INFORMATION
APPENDIX C: LEVEL I EXAMPLE ACTIVITY CHARACTERIZATION
APPENDIX D:
PPOA GRADED APPROACH WEIGHTED SUMS FORM, CRITERIA,
AND INSTRUCTIONS
APPENDIX E: LEVEL II EXAMPLE INFORMAL ASSESSMENT
APPENDIX F: LEVEL III EXAMPLE FORMAL ASSESSMENT
APPENDIX G:
MODEL POLLUTION PREVENTION OPPORTUNITY
ASSESSMENT WORKSHEETS
APPENDIX H: REFERENCES
FIGURES
FIGURE 1:
FIGURE 2:
FIGURE 3:
PPOA FLOW CHART
PPOA GRADED APPROACH LOGIC DIAGRAM
PPOA GRADED APPROACH WEIGHTED SUMS EVALUATION
-------
LIST OF ACRONYMS
ACGIH
DOE
EPA
ES&H
MNCAW
MSDS
NPDES
ODC
OSHA
PCB
PM/WSL
POTW
PPOA
PWA
VOC
WMin/PP
American Conference of Governmental Industrial Hygienists
Department of Energy
Environmental Protection Agency
Environmental, Safety, & Health
Materials Not Categorized As Waste
Material Safety Data Sheet
National Pollutant Discharge Elimination System
Ozone Depleting Compound
Occupational Safety and Health Administration
Polychlorinated biphenyl
Priority Material/Waste Stream List
Publicly Owned Treatment Works
Pollution Prevention Opportunity Assessment
Process Waste Assessment
Volatile Organic Compound
Waste Minimization/Pollution Prevention
-------
ACKNOWLEDGMENT
In July, 1988, DOE Defense Programs recognized the need for a waste minimization
program that would focus beyond pollution control and the traditional media-by-media
approach to containment and treatment of environmental releases. Defense Programs
was proactive in initiating a Waste Minimization Program that included the completion of
process waste assessments as a means to identify opportunities which would reduce
the generation of waste.
The Waste Minimization Program evolved to a Pollution Prevention Program through the
auspices of the DOE Defense Programs' Pollution Prevention Strategic Plan issued in
April, 1992. The Strategic Plan reiterated the hierarchy of preferred environmental
practices outlined in the Pollution Prevention Act of 1990 (i.e. source reduction,
recycling, treatment, and finally, disposal).
The first Model PWA Guidance was assembled by Defense Programs' contractors
based on the published EPA guidance and previous work performed at the Y-12 Plant.
The manual was originally issued in February 1990, and distributed throughout the
Weapons Complex. This is the first revision to the document, and it replaces the term
"PWA" with a more positive term, "Pollution Prevention Opportunity Assessment". The
new term avoids the implication that assessments should be limited to process wastes,
rather, they should address all releases.
The following DOE personnel and DOE contractors assisted in the suggestions for this
revision. Their time and effort were greatly appreciated.
Frank Adams
EG&G Mound
Don Adoiphson
Sandia National Labs/CA
Doyle Anderson
Raytheon Serv - Nevada
Carl Barr
Westinghouse - Hanford
Angela Bolds
Martin Marietta - Pinellas
Angela Colarusso
DOE/DP - Nevada
Paul Deltete
Analytical Resources Inc.
Cindy Dutro
Reynolds Elect & Eng Co.
George Goode
Brookhaven National Lab
Kent Hancock
DOE/EM-352
Jim Henderson
Raytheon Serv - Nevada
Diana Hovey-Spencer
Desert Research Institute
Dr. Roger Jacobson
Univ & Com Coll - Nevada
Alice Johnson-Duarte
Sandia National Labs/CA
Ed Kjeldgaard
Sandia National Labs/NM
John Marchetti
DOE/DP-64
Elizabeth McPherson
McPherson Env. Resources
Susan Pemberton
AlliedSignal Inc., KCP
Bill SchFosberg
AlliedSignal Inc., KCP
Don Watson
AlliedSignal Inc., KCP
Jill watz
Strategic Env. Services
Jeff Weinrach
Los Alamos National Lab
A point of contact has been established in the DOE complex for Pollution Prevention Opportunity
Assessments. If you are in need of training, assistance, and/or methodology, call or fax your
requests or questions to the following:
Susan Pemberton
AlliedSignal Inc., Kansas City Plant
D/837 2C43
P.O. Box419159
Kansas City, Mo 64141-6159
816-997-5435 (Phone)
816-997-2049 (Fax)
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1. INTRODUCTION
A. PURPOSE OF GUIDANCE
The purpose of this document is to provide a guide for DOE sites to conduct pollution
prevention opportunity assessments (PPOAs), commonly known through the DOE as
process waste assessments (PWAs). This will avoid the implication that assessments
should be limited to process wastes - PPOAs address all releases. This guidance
describes those activities and methods that can be employed to characterize all waste
generating processes and identifies opportunities to reduce or eliminate waste
generation. The document also includes a methodology to evaluate proposed
modifications to site processes and other options to minimize waste and prevent
pollution.
B. GUIDANCE SCOPE AND OBJECTIVES
PPOAs will be conducted as part of an ongoing program to identify opportunities to
eliminate or reduce the generation of waste. A PPOA documents the amount of material
that is disposed of as waste during operations. It provides a summary of material usage,
process by-products, and waste generation; and it targets those processes and
operations that need to be improved or replaced to promote waste minimization and
pollution prevention. The assessment also establishes a basis to prioritize modifications
to site processes or other pollution prevention options that are developed during the
assessment.
The objective of a PPOA is to document a facility's processes, operating procedures,
and waste streams in a manner that will permit the identification of the best
improvements to avoid or minimize waste generation. This guide shall not be used as
an audit tool. The assessment consists of a systematic approach which may include the
following:
GRADED APPROACH LEVEL DETERMINATION
ORGANIZATION OF PPOA TEAMS
ASSESSMENT OF PROCESSES AND WASTE STREAMS
DEVELOPMENT AND EVALUATION OF POLLUTION PREVENTION
OPTIONS
RECOMMENDATIONS OF POLLUTION PREVENTION OPTIONS & FINAL
REPORT
A step-by-step process for completing a PPOA is shown in Figure 1. These steps are
sequential and should be performed in that order for best results.
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POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
FLOW CHART
FIGURE 1
PLANNING & ORGANIZATION
•
*
ORGANIZE ASSESSMENT TEAM
REVIEW PPOA GUIDANCE
PROCESS ASSESSMENT
*
•
•
•
*
COLLECT & COMPILE DATA
DEVELOP PROCESS DESCRIPTION
GENERATE FLOW DIAGRAM
CALCULATE MATERIAL BALANCE
SUMMARIZE WASTES & COSTS
OPTION GENERATION & EVALUATION
GENERATE AND SELECT OPTIONS
EVALUATE OPTIONS
PPOA FINAL REPORT
•
*
*
SUMMARIZE PROCESS ASSESSMENT
RECOMMEND FEASIBLE OPTIONS
IDENTIFY FUNDING REQUIREMENTS TO
IMPLEMENT OPTIONS
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II. GRADED APPROACH
A. INTRODUCTION
The DOE Complex is comprised of numerous sites located in many different states.
These facilities range from single-mission to multiple-disciplinary facilities, and vary in
size from quite small to very large. The facilities as a whole represent a tremendous
diversity of technologies, processes and activities. Due to this diversity, there is also a
wide variety and number of waste streams generated. Many of these waste streams are
small and intermittent, and not of consistent composition. The value added of detailed
analysis for individual, small waste streams is often not sufficient to justify the cost, nor is
the analysis necessarily meaningful since many of these waste streams are constantly
changing.
Although waste minimization activities have been implemented at DOE sites, these
efforts are not being sufficiently documented. A DOE survey of PPOA activities across
several sites indicated that these waste minimization practices need to be documented
so that waste generation baselines can be more accurately established. Furthermore,
the documentation can ensure that the site receives credit for accomplishing waste
minimization.
The PPOA Graded Approach addresses these complexities and recognizes that
processes vary in the quantity of pollution they generate, as well as in the perceived risk
and hazards associated with an operation. It also recognizes the variance due to the
cost and function of the final product. Therefore, the graded approach is intended to
provide a cost-effective and flexible methodology which allows individual sites to
prioritize their local concerns and align their efforts with the resources allocated, while
also providing some consistency throughout the DOE to perform PPOAs. In order to
achieve this, the approach has defined three levels of effort to satisfy the requirement of
completing a PPOA. This section documents the minimum amount of effort required,
Level I, Activity Characterization, and provides a systematic approach using the
Weighted Sums Evaluation to determine if additional and more detailed analysis should
be conducted for either a Level II, Informal Assessment, or a Level III, Formal
Assessment.
If used properly, the graded approach will allow a site to concentrate its shrinking
resources on the most important waste problems first. While all of the site's waste
streams and processes will be assessed, the most critical areas will be assessed first
and to the greatest extent.
B. GRADED APPROACH LOGIC DIAGRAM & PRIORITY MATERIAL
/WASTE STREAM LIST
Figure 2, the Graded Approach Logic Diagram, illustrates graphically how the graded
approach methodology works. The diagram starts at the top with the Level I, minimum
effort assessment and works down to an informal and/or formal assessment. The
methodology shown in the logic diagram allows flexibility and provides a consistent
-------
FIGURE 2
Pollution Prevention Graded Approach
Logic Diagram
Level I
Activity Characterization
Activity
Enters
Does Process
Use or Generate a
Priority Listed Material
j>r Waste Stream?,
Yes
Apply Weighted
Sums Criteria
Yes
Level III
Formal Assessment
No
Level I-STOP!
Assessment Completed
I As Priority or
Facility Needs
I Change
I
Weighted Sums Score
Higher than xxx?
Level II
Informal Assessment
-------
structure. A site must develop the priority material / waste stream list (PM/WSL) to use
the graded approach. This list is not limited to the requirements specified below but can
include any other additional concerns. (See Appendix A for an additional list of
considerations.) The priority list provides the site an opportunity to identify their
individual regulatory and/or prioritized needs to cost-effectively determine if additional,
more detailed analysis is necessary. DOE has established requirements and
suggestions for this list as follows.
PRIORITY MATERIAL / WASTE STREAM LIST
Required or Mandatory PM/WSL:
• Waste of any amount for which an approved disposal method does not exist
(i.e., mixed wastes, classified waste, etc.)
• Waste which is equal to 5% or more of the facility's total waste stream (Total
waste = Manifest records (Hazardous) + Radioactive + Mixed)
• Clean Air Act, Class I Materials (ODCs - Ozone Depleting Compounds)
• EPA's 33/50 Materials
• Known Human Carcinogens (ACGIH, Type 1)
Suggested Additions to PM/WSL:
• Federal, State, & Local Requirements
» Permitted Waste & Materials (e.g., VOCs, NPDES, POTW, etc.)
• Site Health Risks for Hazardous Materials & Hazardous Wastes (e.g., OSHA -
Suspect carcinogens, teratogens, explosives, PCBs, Asbestos, etc.)
• Municipal Solid Waste
• Materials Not Categorized As Waste Inventory (MNCAW)
C. LEVEL I - ACTIVITY CHARACTERIZATION
Level I, Activity Characterization, requires a minimal amount of descriptive, quantitative,
and qualitative information to document each of the facility's processes and activities
which are defined as "Any existing or planned operation or activity (including
remediation projects) which generates waste or pollution to the air, land, or water." In
gathering this information, the facility begins the initial step to determine whether any
waste reduction or pollution prevention opportunities exist. The collection of this
information will also provide the basis to determine whether or not any of the facility's
-------
processes/activities necessitate further analysis per the graded approach methodology.
Therefore the principle objectives of Level I are to:
* define the process,
« document Waste Minimization / Pollution Prevention (WMin/PP) activities
(past or current),
• determine the level of effort that should be performed for a cost-effective
Pollution Prevention Opportunity Assessment Program, and
• provide information to determine if more analysis is necessary.
Level I Required Documentation
1. A brief process description / simple flow diagram;
2. A quantitative estimate of the material inputs, products, by-products, and
wastes;
3. A preliminary evaluation of WMin/PP potential; and
4. A decision to determine if further analysis is necessary.
Level I process assessments will establish the site's baseline of operational information.
These process/activity descriptions should include input materials, process products, by-
products and/or waste generated. Identification of these elements and estimates of
quantities is made using the best available information source, or combination of
sources. Possible information sources are listed in Appendix B.
In addition to the descriptive information, the potential for WMin/PP can be initially
evaluated based on the activity or process expert's knowledge. These
recommendations should be included in the Level I documentation. If opportunities do
exist and are easily implemented, then the actions taken or planned to be taken should
be documented. Furthermore, for WMin/PP options identified and implemented,
upstream / downstream impacts should also be included in the documentation.
After collecting the process/activity information, it is necessary to determine whether the
process/activity continues to a Level II or III analysis as defined by the graded approach
logic diagram and the site's priority material / waste stream list.
If the process does not contain any of the materials or waste streams on the priority list,
then the Level I documentation satisfies the PPOA requirement. Conversely, those
processes/activities which are captured by the site's priority list are included in the
Weighted Sums Evaluation to determine the next level of effort to be performed.
A completed example Level I Activity Characterization is shown in Appendix C. PPOA
Worksheets 1S-3S can be used to document the information required in a Level I
assessment.
D. GRADED APPROACH WEIGHTED SUMS EVALUATION
The graded approach methodology continues when the site selects a core team to
determine which processes require Level II and Level III assessments. The core team
-------
should be cross-functional and consist of key site personnel with knowledge about the
site's processes, waste management, and regulations. The team's objectives are to
assign weights to the criteria, to determine the numeric value that distinguishes a Level
It from a Level III, and to provide consistency in scoring across processes. The form to
aid in this evaluation (weighted sums) is shown in Figure 3. (Appendix D contains the
weighted sums form, criteria, and instructions.) First the site assigns a weight to each
criteria listed in the first column of the weighted sums. Then, for each process being
evaluated, the team determines a scale for the five listed criteria and a multiplier. From
the products and sums, a total point value is assigned. Finally, the team determines the
cut-off value for which Level II assessments will be completed versus Level III
assessments. Processes identified by the Weighted Sums Evaluation which require a
Level III, Formal Assessment, are those processes that are critical to the site's priorities
and would benefit by the allocation of resources to examine how to best implement
pollution prevention technologies to these critical areas.
E. LEVEL II - INFORMAL ASSESSMENT
After completing the Graded Approach Weighted Sums Evaluation, the facility has
distinguished which processes/activities require the Level II, Informal Assessment. The
principal objectives of Level II are to:
develop and screen WMin/PP opportunities and
recommend viable options for implementation.
This level of effort does not require the collection of new data. Much of the
documentation has already been completed in the Level I assessment. However, due to
some aspect of the process, the facility needs to further explore the WMin/PP
opportunities available to reduce the quantity of waste or the risk/hazard associated with
the operation.
Level II Required Documentation
(1.} Brief process description / simple flow diagram;
{2.} Quantitative estimate of the material inputs, products, by-products, and
wastes;
{3.} Preliminary evaluation of WMin/PP potential;
4. WMin/PP options identification and evaluation;
5. Consideration of potential upstream / downstream impacts; and
6. Recommendations for option implementation.
{} - denotes those items already completed in Level I, Activity Characterization
Further suggested reading for Level II information can be found in sections IV: A-C and
V: A-B. A completed example Level II, Informal Assessment, is shown in Appendix E.
PPOA Worksheets 1S-5S can be used to complete the requirements of a Level II
assessment.
-------
Date:
Page of
FIGURE 3
Pollution Prevention Opportunity Assessment Graded Approach
Weighted Sums Evaluation
Evaluation Criteria
Environmental, Safety,
& Health Hazards
Quantity of Waste
Generated
Site Liabilities
Economic Factors -
Process & Waste Costs
(Unit &/or Annual)
Process By-Product
Management
Other
Subtotal
IwMin/PP Potential
(Multiplier
Total
PPOA Level
Weight
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F. LEVEL III - FORMAL ASSESSMENT
In addition to the information completed in the Level I assessment, the Level III requires
considerably more documentation to complete the PPOA. For example, both the
process description and a corresponding block flow diagram are required to illustrate
the basis of generation. The use of narratives, calculations, photographs, illustrations,
figures and/or data sufficient to convey an understanding of the process are certainly
recommended. The Level III assessment also requires collection of quantitative data for
a material balance. A material balance should be completed to account for all waste
generated. This information, if not already available, may need to be tracked to
accurately establish the current process waste generation information necessary to
complete the WMin/PP options analysis.
The primary objectives of the Level III Assessment are to:
• conduct a detailed analysis of the process for WMin/PP opportunities and
» document the results of the process evaluation in a written report.
Level HI Required Documentation
{1.} Brief process description / simple flow diagram;
{2.} Quantitative estimate of the material inputs, products, by-products, and
wastes;
{3.} Preliminary evaluation of WMin/PP potential;
4. Process description;
5. Flow diagram;
6. Material balance;
7. WMin/PP options identification;
8. Analysis of WMin/PP options generated: economic, technical, upstream /
downstream impacts, and other benefits;
9. Prioritized list of options; and
10. Formal report with documentation and recommendations for option
implementation.
{} - denotes those items already completed in Level I, Activity Characterization
A completed example Level III, Formal Assessment, is shown in Appendix F.
The following sections of this guidance describe the details necessary to achieve the
requirements of a Level III, Formal Assessment. Each of these sections can also be
used as a reference for the information required in the Informal Assessment and Activity
Characterization, Levels II and I, respectively. Blank Model Worksheets have been
included in Appendix G to help guide a team through the PPOA requirements. They are
only suggested forms - they are not requirements. A site may prefer to modify them to fit
their individual site needs. Model PPOA Worksheets 1-10 were developed for the Level
III assessment, PPOA Worksheets 1S-3S were developed for Level I, and Worksheets
1S-5S were developed for a Level II.
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III. POLLUTION PREVENTION OPPORTUNITY ASSESSMENT TEAMS
The Waste Minimization and Pollution Prevention Awareness Program Plan states that
assessments of all waste-generating operations at the site will be conducted by PPOA
teams. The team leader should have the authority to complete the assessment, line
responsibility, familiarity with the site's process and waste management operations, and
proven technical and problem-solving abilities (e.g. Value Engineering Specialist).
The remainder of each assessment team should be drawn from line staff, or
subcontractor organizations that can furnish the type of specialized expertise that will be
needed to conduct the assessment. Each PPOA team should consist of a small core of
individuals familiar with the site's operations, who will direct the assessment efforts and
guide the data gathering. The careful selection of personnel to conduct the assessment
is essential. Experienced people familiar with the site's operations are crucial to
completing an accurate and timely assessment. Subsets of this team are satisfactory for
Levels I and II of the graded approach. Other personnel with specialized skills will be
used on a part-time, as-needed basis. Each team may include members who have
knowledge in the following areas:
process operations;
federal, state, and local hazardous waste statutes and regulations;
operation and waste minimization principles and techniques;
quality control requirements;
purchasing procedures;
material control/inventory procedures; and/or
value engineering skills.
Model Worksheets 1 and "IS can be used to record the PPOA team members and the
assessment title and identification (ID) code. The PPOA ID Code should be unique for
each PPOA at the site. For uniformity, the site should determine the structure of this
code.
PPOA team leaders should receive training on the procedures, methodologies,
techniques and documentation requirements for PPOAs before the assessments are
conducted. The team leader needs to have clear authority from the WMin/PP
Coordinator or line management to select other team members, obtain support services,
and to direct the efforts of the assessment team in its interaction with operating
personnel. The team should be given unrestricted access to all facility personnel and
information that may, in the team's estimation, be relevant to the assessment.
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IV. ASSESSMENT OF PROCESSES AND WASTE STREAMS
A. INITIAL DATA GATHERING
For each assigned process, the PPOA team begins with gathering data about that
process and associated waste streams. The boundaries of the process must be
established. The team should consider the following process boundary criteria: (1) the
process must have a distinct starting and ending point, (2) the process input materials
must be accounted for, (3) the time frame must be considered, and (4) the process must
be manageable - an appropriate size to collect information and provide focus. The team
will collect information through interviews and the review of process documents that will
permit a thorough understanding of the process to be assessed and the development of
a written analysis on how that process generates waste (see Appendix B for sources of
additional information). The team should also visit the process areas to witness how the
process is conducted and to validate the written information that has been collected.
Each PPOA team should develop and/or collect information as defined in the graded
approach level. The following assessment tools may be used:
• process descriptions,
» process flow diagrams,
• material balances, and/or
• waste stream characterizations for assessment area or process.
Additional guidance may be found in the EPA Facility Pollution Prevention Guide
(Reference #8 of Appendix H) to complete the PPOA.
PPOA team members may identify ways to reduce waste during the data collection
phase. It is at this point that observations about operations, schedules, and procedures
can be noted which may easily be changed to prevent waste. These changes can have
a wide impact. The knowledge and experience of team members and their colleagues
will help to develop these ideas into potential options. The team members should also
make effective use of technical literature from equipment vendors and trade
associations; the experience of plant engineers, operators, and consultants; and the
databases available from environmental agencies.
B. PROCESS DESCRIPTION
The PPOA will include a general description of each process step in the waste
generating operation. The narrative should describe the following:
purpose of the process;
material and equipment used in the process;
equipment layout;
personnel and their experience / training level; and
products, by-products, and waste streams generated.
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Model Worksheets 2 and 2S can be used to complete the process description.
Chemicals and other materials purchased or otherwise introduced into the process
should be identified. The description should also include other information that
adequately describes the process and may be relevant to WMin/PP planning. For
example, process or product specifications, requirements, assumptions, and upstream
and downstream impacts may have a critical bearing on waste generation and should
be included in the description.
To further understand the process, the team may perform a function analysis as
explained in the DOE/Defense Program's Prioritization of Pollution Prevention Options
Using Value Engineering (Reference #13 of Appendix H). The principal objective of
function analysis is to discover the basic purposes of a process in contrast to its
secondary or support uses. It aids the team in determining the process1 primary
functions and in minimizing or eliminating secondary functions which, in turn, may
produce unnecessary wastes. The function analysis can help answer the question as to
whether this process is actually necessary.
C. PROCESS FLOW DIAGRAM
The analytical work of the waste assessment effort starts with the development of a
simple process flow diagram for the operation being assessed. The requirement for this
flow diagram is based on the maxim that a picture is worth a 1000 words. It is also the
foundation upon which the material balance is built. The process flow diagram should
identify the major steps within an operation and diagram the flow of materials into and
out of each step during the process. The diagram should indicate the following:
• process steps,
• material inputs, and
• process outputs (e.g., product, by-products and waste streams).
The diagram should also characterize the streams according to the nature of the release
and waste classification, including but not limited to the following:
air,
liquid,
solid,
radioactive,
mixed,
hazardous, and/or
non-hazardous.
Model Worksheets 3 and 2S can be used for the completion of the process flow
diagram. There are three styles to chose from for Model Worksheet 3 depending on the
complexity of the analysis and whether radioactive materials and waste streams are
involved.
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D. MATERIAL BALANCE
The PPOA shall account for all input materials that enter the process which are either
consumed, transferred, or disposed of as waste. This accounting, which is called a
"material balance", will be indicated on the process flow diagram and transferred to a
spreadsheet. A material balance is a tool which is used to provide an input/output
summary of the process being assessed. Closing the balance on an unknown stream
can help identify the constituents in that stream. The material balance should indicate
the following;
* amount of input materials introduced into the process,
• amount of materials consumed,
* amount of materials withdrawn as a product or by-product, and
* amount of materials flowing out of a process as a waste stream.
Using the best available information, the material balance should be closed (i.e., all
input materials and transfers should be accounted for in the product, by-product and
waste streams). The purpose of closing the balance is to identify streams which are
difficult to quantify, e.g. fugitive and point-source emission streams. The material
balance should show the average material flows over a representative time period
which is logical for the site's operations. For example, it may be appropriate to gather
data for Operation A from monthly averages, while a longer time span may be more
appropriate for Operation B. Material balances performed over the duration of a
complete production run are typically the easiest to construct and are reasonably
accurate.
In its simplest form, the material balance is represented by the mass conservation
principle:
Mass in = Mass out + Mass Accumulated
That is, materials placed into a process can be accounted for through products, by-
products, air emissions, water discharges, spills, recycling streams, waste streams,
scrap, out-of-shelf life materials, or out-of-specification materials. All materials
(hazardous and non hazardous) should be accounted for in the input and output
streams. The quantification units for the material balance should be consistent, i.e.
pounds. The Material Safety Data Sheet (MSDS) can be helpful in converting materials
into a common unit.
Measurement of Feed Materials: All input materials that are introduced into a process
must be identified. The amount and type of the input materials can be determined by
examining the following:
• procurement and inventory records;
• processing logs; and/or
» other records that show purchase, transfer, donation, or other receipt of
materials by production unit.
Other examples of information sources are found in Appendix B.
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Products and By-products: The material balance should indicate the amount of
materials leaving the work unit as a product or by-product.
Transfer of Materials: Some materials may be used in a process and then transferred to
another area or process for further processing. The material balance should account for
the transfer of the materials.
E. MEASUREMENT OF WASTE
Information about the quantity and character of the waste streams is a critical component
of the PPOA. Waste stream information should be obtained from sources such as:
site tracking system,
permits and permit applications,
monitoring reports,
hazardous waste manifests,
emission factors,
experiments,
emission or toxic substance release inventories,
hazardous waste reports,
waste analyses, and/or
environmental audit reports.
If the waste data is not available from the above sources, it may be necessary to monitor
the process and record the needed information. Model Worksheet 4 can be used to
record material balance data. The completed material balance should be a database of
process information that represents the process area over a time period long enough to
characterize that operation. The suggested time period to record this data is an annual
basis to coincide with other site reporting requirements. If data was taken over a shorter
time period, extrapolation can be used. The material balance will show the source of
waste streams and the contribution that different activities make to the waste streams. It
will serve as a baseline for tracking WMin/PP efforts and will provide data needed for
evaluation of WMin/PP options. The process data used to calculate a baseline of
operations should be as representative of current operations as possible.
Monitoring waste stream flows and compositions is something that should be done
periodically. By tracking waste streams, seasonal variations in waste flows or single,
large waste streams can be distinguished from continual, constant flows. Changes in
waste generation cannot be meaningfully measured unless the information is collected
both before and after a pollution prevention option is implemented.
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F. WASTE STREAM CHARACTERIZATION
Each waste stream identified in the process flow diagram will be characterized,
including but not limited to the following:
• source of waste;
• composition;
* rate of generation from work unit operation; and
• costs associated with treatment, storage, or disposal of wastes.
The waste stream characterization information is also part of Model Worksheet 4. The
cost information for the input materials and waste streams can be recorded on Model
Worksheet 5. After characterization, consideration should be given to each waste
stream to determine where WMin/PP is most needed.
V. DEVELOPMENT AND EVALUATION OF WASTE MINIMIZATION/
POLLUTION PREVENTION OPTIONS
A. IDENTIFICATION OF WMIN/PP OPTIONS
Once the process and causes of waste generation are understood, the PPOA enters the
creative phase. Following the collection of data and site inspections, the members of
the team will have begun to identify possible ways to minimize waste or prevent
pollution in the assessment process. Identifying potential options relies both on the
expertise and creativity of the team members. Much of the requisite knowledge may
come from their education and on-the-job experience, however, the use of technical
literature, contacts, and other sources may also be employed.
The process by which pollution prevention options are identified should occur in
an environment that encourages creativity and independent thinking by the
members of the assessment team. The key to successful results is the deferral of
any critical judgments or comments which might inhibit any of the team members.
While the individual team members will suggest many potential options on their
own, the process can be enhanced by using some of the common group decision
techniques. These techniques allow the assessment team to identify options that
the individual members might not have come up with on their own. Employees
having practical experience with the process may have given thought to the
process1 input and output efficiencies or alternative operating methods. Therefore,
creativity and brainstorming is strongly encouraged.
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To identify WMin/PP options, the PPOA teams will utilize the following priorities:
« source-reduction options:
- material substitution,
- process changes,
- product reformulating,
- equipment changes,
- operational improvements,
- schedule changes,
- affirmative procurement, and/or
- administrative controls (e.g., inventory control, employee
training, polices, etc.).
• recycling/reuse options
Each of these different approaches may generate many options or none, i.e., while
operational improvements are a very broad approach, input or process changes may be
difficult to control. Are there any processes / prodiicts upstream and downstream which
could be affected by changes to the process or product? As these different approaches
are discussed several questions should be repeatedly asked:
Is this operation necessary?
Why is this waste generated?
Why do we do this operation in this manner?
Why must we use these chemical??
Are there any non-hazardous substitutions available?
In addition to using the process expert's knowledge, there are numerous outside
references to assist in developing a list of options. These include EPA publications,
databases, and technical references; state and local environmental agency's
publications, bibliographies, and technical assistance; as well as, published literature in
technical magazines, trade journals, research briefs, vendor equipment information and
chemical supplier information.
Model Worksheet 6 can be used in a team brainstorming session to generate the
pollution prevention opportunities. Model Worksheets 7 and 4S can be used to record
the detailed description for each of the options generated. The description should
include the basic idea behind the option, affected materials and product, any roadblocks
to implementation, and the anticipated reduction quantity.
B. PRELIMINARY SCREENING OF WMIN/PP OPTIONS
Many pollution prevention options will be identified in a successful assessment. At this
point, it is necessary to identify those options that offer real potential to minimize waste
and reduce costs. Since detailed evaluation of technical and economic feasibility is
usually costly, the proposed options should be screened to identify those that deserve
further evaluation. The screening procedure serves to eliminate suggested options that
appear marginal, impractical, or inferior without a detailed and more costly feasibility
-------
study. The screening procedures may include any combination of the following
methods:
* information reviews by program managers,
* ballots by team members, and/or
• quantitative tools (e.g. weighted sum method).
Whatever method is used, the preliminary screening procedure should consider the
following questions:
Is implementation of the option cost effective?
What is the principal benefit of the option?
What is the expected change in the type or amount of waste generated
(toxicity, reactivity, etc.)?
Does it use existing technology?
What kind of development effort is required?
Will implementation be constrained by time?
Does the option have a dependable performance record?
Will the option effect product, employee health, or safety?
What are the upstream/downstream impacts if implemented?
The results of the screening process will be a list of options that are candidates for more
detailed technical and economic evaluation. It is important to document the decisions
made in the screening process for future reference. Model Worksheet 7 can also be
used to record the results from the initial screening process.
C. EVALUATION OF WMIN/PP OPTIONS
The PPOA team should perform an in-depth evaluation on the potential economic and
technical feasibility of each option using Model PPOA Worksheets 8 and 9. The options
will then be ranked in order of preferred implementation. The highest priority normally
should be given to source-reduction projects, after which projects that recycle/reuse all
or part of a waste stream or by-product will be considered.
Model Worksheet 8 evaluates each option from a cost perspective. The three major cost
categories for weighing options are: Implementation Costs, Incremental Operating
Costs, and Incremental Intangible Costs. EPA's Pollution Prevention Benefits Manual
(Reference #12 of Appendix H) provides more detail on cost analysis and contains
examples of each of these cost categories.
The following considerations must be fully evaluated to determine the recommended
WMin/PP options. These include: economic evaluation including capital cost, operating
cost, waste management costs and return on investment; expected change in the type or
amount of waste generated (toxicity, reactivity, etc.); technical feasibility; avoided costs;
effect on product, employee health and safety; permits, variances, and compliance
schedule of applicable agencies; releases and discharges to all media; previous
successes; implementation period; and/or ease of implementation.
-------
This evaluation is most easily accomplished and documented by the use of a simple
matrix for scoring and ranking - the suggested evaluation is the weighted sums method
shown on Model Worksheet 9. The DOE/DP Prioritization of Pollution Prevention
Options Using Value Engineering (Reference #13 in Appendix H) also demonstrates
how options can be evaluated and prioritized using this method. The evaluation matrix
provides a means to quantify the important criteria that affect the site and is a quick
visual representation of the factors affecting various WMin/PP options. The scoring
system for each criteria, used in the matrix and some rational for selection or weighting
of scores should be included in the formal report. Evaluation of this matrix would
complete the final requirement for prioritizing the list of options for implementation. The
formal report should provide sufficient detail to allow transfer of the measure to other
generators with similar processes or operations.
VI. FINAL REPORT
A final report is required for each PPOA. The final report is a compilation of essential
facts about the process, pollution prevention options, feasibility of those options,
upstream/downstream impacts of those options, and future implementation costs. The
final report documents the work performed, assumptions made during the assessment,
and identifies funding requirements necessary to implement pollution prevention
options. The length of the final report will depend on the complexity of the PPOA. For
Level II assessments, Model Worksheet 5S can be used to complete the requirements of
the final report.
For a Formal Assessment, Level III, each option will be ranked by the PPOA team
according to its economic and technical feasibility using Model Worksheets 8 & 9.
Economic feasibility will be a factor, but not the determining factor, in judging the relative
merit of each WMin/PP option. The PPOA team will report the results of its evaluation,
including final rankings and ranking criteria, to the Waste Minimization Committee or
line management. The PPOA team will indicate its preferred options in the report.
Easily implemented options will be completed and documented in the final report.
Options that require additional analysis and/or approval shall be addressed via the
site's Waste Minimization and Pollution Prevention Program Plan.
Documentation of the WMin/PP options and recommendations should demonstrate a
good faith effort undertaken to identify alternatives and should provide a narrative
description of these factors in sufficient detail to allow transfer of the measure to other
generators with similar processes or operations.
The final report and associated data will be maintained as permanent records for later
reference and tracking information. PPOAs should be reviewed on an annual basis
after the initial PPOA is completed and should be revised if significant process changes
are made.
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VII. APPENDIX
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APPENDIX A
GENERAL CONSIDERATIONS FOR PRIORITIZING
THE ASSESSMENT OF WASTE STREAMS
» Costs savings (direct and indirect)
« Potential for (or ease of) minimization
• Potential recovery of valuable by-products
• Reduced quantity of waste
» Compliance with current and future regulations
« Hazardous properties of the waste (including toxicity, fiammability,
corrosivity, and reactivity)
• Other safety hazards to employees
• Potential environmental and safety liability/improvements
• Potential for removing bottlenecks in production or waste treatment
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APPENDIX B
SOURCES OF MATERIAL BALANCE INFORMATION
Listed below are potential sources of information for preparing a process description,
flow diagram or material balance inventory. The list is not meant to be exclusive.
• Process Expert Knowledge
• Operating Logs
* On-site Tracking Systems
• Purchasing Records
• Vendor Information
• Process Design Information
• Batch Makeup Records
• Emission Inventories
• Equipment Cleaning and Validation Procedures
• Material & Chemical Inventories
* Operating Procedures and Manuals
• Production Records
• Product Specifications
* Samples, Analyses, and Flow Measurements
• Waste Disposal Records
• Waste Manifests
• E S & H reports
• Permitting Applications
• Experiments
• Laboratory Notebooks
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APPENDIX C
LEVEL I EXAMPLE PPOA
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PROCESS DEFINITION
SNL/NM Oroanization: 7813-5
Page _J of 2
Process Name: Asbestos Brakes & Clutch Removal
DATA FORM
DESCRIPTION OF
PROCESS/OPERATIONS
Area I,II,III,IV,V & Remote Area
Process Location SNL-Albuguerque NM/SNL-Livermore CA./TTR-Las Vaeas NV./KTF-Kauat
(include site, TA, building, room, as appropriate)
Describe the general operations or activities of the organization performing the process. Continue on
the back of this sheet, if necessary.
The Crane and Hoist section is responsible for performing annual
Repairs, and Preventative Maintenance on Cranes and Hoists.
Describe the particular process that generates wastes and/or other pollutants, or uses hazardous
materials. Describe how the hazardous materials are used, and how the wastes or pollutants are
generated. (See Chapter 2 of the PWA Guidance Manual for guidelines on defining a process.)
Continue on the back of this sheet, if necessary.
Asbestos Brakes and Clutches are generated waste In this process.
Asbestos Brakes and Clutches becomes a generated waste when the Asbestos
and Clutches areremoved and replaced with Non-Asbestos Brakes and Clutches,
Date: 7/22/93
PWA#:
Prepared by (MinNet Rep): Bernard. Alexander Phone: 4-1365
Process Contact: Bernard Alexander Phone: 4-1361
(to be completed fay WMSC)
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PROCESS D
SNUNM Organization: 7B13-5
Pane _| ol
Process Name: Asbestos Brakes & Clutch Removal
DATA FORM
PROCESS
FLOW DIAGRAM
Re»ote Areas
Process location: SHL-Atsuqaerque
,
CA*
StaHO. . flow |Seal rfoves shall be s"!f'fifi*itftl*f:!F3(.^,
If •vlGeneciile KAF8 Form 483 Asbestos Containing Materials WasJel
-------
PROCESS DEFINITION
SNL/NM Organization: 7813-5
Sheet 1 of 2 Page __ lm: of 2
Process Name: Asbestos Brakes and Clutches Removal
DATA FORM
CALENDAR YEAR 1992 WASTE
MINIMIZATION ACTIVITIES
Area I,II,III,IV,V, & Remote Areas
Process Location: SNL-Albuqgerque NM/SNL-Livermore CA./TTR-Las Vegas HV. /KTF-Kauai
(include site, TA, building, room, as appropriate)
Have waste minimization (WM) activities been undertaken in CY92? E Yes O No
If No, briefly discuss factors that have prevented waste minimization activities:
If Yes, short name of WM activity (e.g., Increase Input Purity, Improve Rinse Process) (use other sheets
if more than one activity taken): Removing and disposing of a hazardous material.
Type of WM activity (check best one that applies):
Source Reduction
09 Good Operating Practice
D Inventory Control
O Spill and Leaks Prevention
D Raw Material Modification
D Production Modification
O Process Modification (Clean and Degreasing)
D Process Modification (Surface Prep and Finish)
D Process Modification (Other)
D Other (specify below)
Recycling
O Began Onsite Recycling
O Began Off site Recycling
O Reuse in Original Process
O Reuse in Another Process
Energy Recovery
O Began Onsite Energy Recovery
O Began Off site Energy Recovery
Treatment
O Began Onsite Treatment
D Began Offsite Treatment
Briefly describe WM activity: Removal of Asbestos Brakes and Clutches to be replace with
a non-asbestos material. __^_^___ __^_
Prepared by (MinNet Rep): Bernard Alexander Phone: 4-1365
Process Contact: Bernard Alexander Phone: A-1365
7/22/93
PWA#:
(to b« comploted by WMSC)
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PROCESS DEFINITION
SNL/NM. Organization: 7813-5
Sheet 2 of 2 Page 2 of 2
Process Name: Asbestos Brakes and Clutches Removal
DATA FORM
FISCAL YEAR 1992 WASTE
MINIMIZATION ACTIVITIES
Waste stream type affected: D Hazardous (Chemical! Solid Waste
D Radioactive/Mixed Solid Waste
O Waste Water Discharge
O Air Emission
Waste stream name affected (see corresponding Data Form 2): Asbestos Brakes and Clutches
Did WM activity increase the toxicity of waste generated? D Yes E No
Did WM activity increase the quantity or toxicity of wastes emitted to other media (air, waste, land)?
D Yes 0 No
Did WM activity reduce toxicity but not quantity? E Yes D No
Indicate the quantity impact of the WM activity (use most appropriate measure):
Mass before WM activity (kg/yrj:
Volume before WM activity (4/yr):
Specific activity before WM activity (Ci/kg/yr):
Mass after WM activity (kg/yrj:
Volume after WM activity (l/yr|:
Specific activity after WM activity (Ci/kg/yr}:
Basis of quantities (e.g., direct measurement, material balance calculation, published emission factors,
engineering calculations, engineering/scientific judgment):
Has the WM activity been successful? d Yes D No
Is the activity still being used? Q Yes O No
If unsuccessful or otherwise not being used, describe why:
Date: 7/22/93
PWA #:
Prepared by (MinNet Rep): Bernard Alexander Phone: 4-1365
Process Contact: Bernard Alexander Phone: 4-1365
(to b« completed by WMSCI
-------
PROCESS CHARACTERIZATION Page i . of 1
SNUNM Organization: 7813-5 Process Name: Asbestos Brakes and Clutches
DATA FCnM
HAZARDOUS/RADIOACTIVE
MATERIAL INPUTS
Nam* of Hazardous/Radioactive Material
Asbestos
Glove Bag
Tvvek Suits .Rags, Drip Cloth
input Stream
Number
1
2
9
Predicted
Frequency of
Usage"1
Average
Annual Usage
Rate
-------
PROCESS CHARACTERIZATION Sheet 1 of 3 Page 1 of
SNUNM Organization: 7813-5 Process Name: Asbestos Brakes and Clutches
DATA FORM
HAZARDOUS (CHEMICAL)
SOLID WASTE
Waste Stream Number (from Worksheet 1): 1,2,9.10
Waste Stream Name (from Data Form 2/Worksheet 1): Asbestos,tyvk suits,rags .drip cloth, plastic
Location of waste generation (TA, building, room): SNL-Alb/SNL-CA/TTR-NV/KTF-Kauai bag
Inside RMMA? D Yes ® No
Briefly describe how waste is generated: Asbestos Brakes and Clutches are removed and replaced
with non-asbestos material. Glove bages.tyvek suits rags, and drip cloth are used in th
removal process to remove the generated waste.
Frequency of waste generation:
O Continuously
d Monthly
D Daily
O Quarterly
D Weekly
O Annually
Which description fits the process step that generates the waste (check best one):
IE A regularly scheduled process step that is likely to be repeated several times during the upcoming year.
O A one-time activity that is not likely to be repeated during the upcoming year.
Predicted average quantity of waste generated annually - normal operations (kg): 200 Ibs.
Predicted min/max quantity generated annually - normal operations (kg): Min Max
List (describe) all hazardous constituents (e.g., mercury inside switches, benzene-tainted glassware)
or brand names (e.g., WD-40) that could be in the waste:
Asbestos , ___^__
Do the hazardous constituents of the waste stream listed above vary (e.g., sometimes contains lead,
sometimes contains lead and cadmium)? D Yes H No if yes, describe how the waste varies:
Describe physical characteristics of wastes (e.g., aqueous solution, solid, sludge, oil, containerized
compressed gas - include % of solids or % moisture, If applicable): Solid
Date: 7/22/92
PWA#:
{to b* completed by WMSCI
Prepared by (MinNet Rep): Bernard Alexander
Process Contact: Bernard Alexander
Phone:,
Phone:
4-1365
4-1365
-------
PROCESS CHARACTERIZATION Sheet 2 of 3 Page 2 of _
SNUNM Organization: 7813-5 Process Name: Asbestos Brakes and Clutches
DATA FORM
HAZARDOUS (CHEMICAL)
SOLID WASTE
The pH of the waste stream may range from N/A to N/A (answer if appropriate)
Is the waste ignitable? (see Guidance Manual for clarification!
Is the waste corrosive? (see Guidance Manual for clarification}
Is the waste reactive? (see Guidance Manual for clarification)
D Yes
D Yes
D Yes
m NO
BNo
BNo
O Unknown
O Unknown
O Unknown
Does the waste stream contain any of the following toxic metals: Q Yes H No (check all that apply)
D Arsenic D Barium O Cadmium O Chromium
O Lead O Mercury D Selenium D Silver
Does the waste stream, contain a toxic volatile, semi-volatile, or pesticide listed in Table 3-2?
D Yes S No If yes, list:
Does the waste stream contain any of the spent solvents listed in Table 3-3? O Yes B No
If yes, list:
Does the waste stream contain, or is it generated from the production of, any of the following benzene
derivatives? O Yes 0 No (check all that apply)
D trichlorophenol D tetrachlorobenzene
O tetrachlorophenol Q pentachlorobenzene
O pentachloropheno! D hexachlorobenzene
Is the waste any of the following? O Yes
O waste water treatment sludge
O petroleum refining waste
E No (check all that apply)
O wood preserving process waste
O leachate from treatment, storage, or disposal of waste
Does the waste contain cyanide or is cyanide used in the process? O Yes B No
Is the waste any of the following? O Yes E No (check all that apply)
O waste from the production of inorganic pigments
O waste from the production of inorganic chemicals
O waste from the production of organic chemicals
D waste from the production of explosives
D waste from the production of ink formulations
D waste from the production of pesticides
D waste from the production of metals
O waste from the production of Pharmaceuticals
D coking waste
O petroleum refining waste
Date: 7/22/93
PWA #:
(to be completed by WMSC)
Prepared by (MinNet Rep):Bernard Alexander
Process Contact: Bernard Alexander
Phone: 4-1365
Phone:4-1365
-------
PROCESS CHARACTERIZATION Sheet 3 of 3 Page 3 of
SNL/NM Organization: 7813—5 Process Name: Asbestos Brakesand Clutches
DATA FORM
HAZARDOUS (CHEMICAL)
SOLID WASTE
Based on the above description of how the waste is generated, select the single best summary of the
waste-generating process step.
CLEANING AND DECREASING
D Stripping (A01)
D Acid cleaning ((A02)
O Caustic (Alkali) cleaning (A03)
D Flush rinsing (A04)
n Dip rinsing (A05)
D Spray rinsing (A06)
O Vapor degreesing (A07)
D Physical scraping and removal (A03I
O Clean out process equipment (AOSJ
O Other cleaning and degreasing (A19)
SURFACE PREPARATION AND FINISHING
D Painting (A21J
D Electroplating (A22)
D Electroless plating (A23)
O Phosphating (A24)
O Heat treating (A25)
D PieWing (A26I
D Etching (A271
D Other surface coating/preparation (A29)
PROCESSES OTHER THAN SURFACE PREPARATION
D Product rinsing (A31)
D Product filtering {A32»
O Product distillation (A33)
D Product solvent extraction (A34J
D By-product processing (ASS)
O Spent catalyst removal (A36)
O Spent process liquids removal (A38)
O Tank sludge removal (A38)
O Slag removal (A39)
O Metal forming (A40)
O Plastics forming (A41)
PRODUCTION OR SERVICE DERIVED ONE-TIME AND
INTERMITTENT PROCESSES
O Leak collection (ASK
O Cleanup of spill residues (A53)
D Oil changes (A54)
D Filter/battery replacement (ASS)
O Discontinue u*« of process equipment (ASS)
B Discarding off-spac material (A571
O Discarding out-of-date products or chemicals (ASS)
D Other production-derived on-time and intermittent
processes (ASS)
D Sludge removal (A60)
REMEDIATION DERIVED WASTE
D Superfund Remedial Action (A61)
D Superfund Emergency Response (A62)
O RCRA Corrective Action at solid waste management
unit (A63)
D RCRA closure of hazardous waste management unit
(A64|
O Underground storage tank cleanup (A65)
O Other remediation (A69)
POLLUTION CONTROL OR WASTE TREATMENT
PROCESSES
O Filtering/screening (A71)
O Metals recovery (A72)
O Solvents recovery (A73)
D Incineration/thermal treatment (A74)
O Westeweter treatment (A75)
O Sludge dewetering (A76)
O Stabilization (A77)
O Air pollution control devices (A78)
O Leachate collection (A79)
O Other pollution control or waste treatment (ASS)
OTHER PROCESSES
S Clothing end personal protective equipment (A91)
S Routine cleanup wastes (e.g., floor sweepings)
-------
APPENDIX D
PPOA GRADED APPROACH WEIGHTED SUMS
FORM, CRITERIA, AND INSTRUCTIONS
-------
Date:
Page
of
Pollution Prevention Opportunity Assessment Graded Approach
Weighted Sums Evaluation
Evaluation Criteria
Weight
'W'
Process:
Scale
'S' 'WxS1
Process:
Scale
'S1 'WxS1
Process:
Scale
'S1 'WxS1
Process:
Scale
'S1 'WxS1
Process:
Scale
'S1 'WxS1
Environmental, Safety,
& Health Hazards
Site
Assigns
Quantity of Waste
Generated
Site Liabilities
Economic Factors -
Process & Waste Costs
(Unit &/or Annual)
Process By-Product
Management
Other
Subtotal
WMin/PP Potential
Multiplier
Total
PPOA Level
8/93
-------
Date;
Page
of
Pollution Prevention Opportunity Assessment Graded Approach
Weighted Sums Evaluation
Evaluation Criteria
Weight
•W
Process:
Scale
'S1 'WxS'
Process:
Scale
'S' 'WxS1
Process:
Scale
'S1 'WxS1
Process:
Scale
'S' 'WxS'
Process:
Scale
'S' 'WxS'
Environmental, Safety,
& Health Hazards
Site
Assigns
Quantity of Waste
Generated
Site Liabilities
Economic Factors -
Process & Waste Costs
{Unit &/or Annual)
Process By-Product
Management
Other
Subtotal
i
Min/PP Potential
[Multiplier
Total
PPOA Level
8/93
-------
Graded Approach Worksheet
The purpose of this worksheet is to determine the PPOA level for each of the facility processes. To begin, a list of these
processes or areas should be generated for each facility. Then for each item listed, complete one column on this worksheet.
For consistency, each facility should establish site-specific weights for each of the criteria. Once each item has received a
weighted sum value, then each facility should establish the dividing line from which to require informal (Level II) or formal PPOAs
(Level III).
Weighted Sums Instructions:
a. The values in the Weight column (designated by W)
represent the facility's priority for the criteria.
b. In the Scale column for each process (designated by 'S'),
rate each criteria by assigning a value from 0-10
(lowest to highest).
c. In the 'Wx S' column for each process, enter the product of
the weight and scale.
d. Sum the 'W x S1 column for each process to obtain a
subtotal.
e. Calculate the process ratio for waste generated/input
material used (0-1). This is the multiplier.
f. Multiply the subtotal by the multiplier and enter the product
in the Total column for each process.
g. Determine the level of PPOA required by comparing the
Total weighted sums value with the site guidelines in
the following table.
Weighted Sums
Total
If 0 to (?)
If > (?)
PPOA Level
Required
Level II
Informal PPOA
Level III
Formal PPOA
-------
APPENDIX E
LEVEL II EXAMPLE PPOA
-------
[ PPOA-1 1 Original Issue Date: 8/31/91
V / Revision Mn •
Revision No.:
Revision Date:
Pollution Prevention Opportunity Assessment
Team & Scope
Assessment ID Code: Assessment Title:
SNL/CA MS001 Machine and Fabrication Shop
Name Job Classification Phone
Alice Johnson- Duarte
Andy Cardiel
Charlie Schmitz
Kim Shepodd
WMin Coordinator
Shop Supervisor
Machinist
Waste Manager
4-3266
4-2544
4-2315
4-1475
* Team Leader
Assessment Scope:
The Machining and Fabrication Shop is a support function whose principal
purpose is machining parts requiring a quick turn-around, restriction of
access due to classification, and/or close liaison with the designer and
engineer. The shop maintains equipment suitable to perform turning,
milling and grinding operations. The major hazardous waste stream
generated by this facility is the spent coolant used in the machining
process. The diluted Aqua-Syn 180 itself is a non-hazardous material per
29CFR 1910.1200(c); however, in the machining process it is mixed with
small amounts of machine oil and metal shavings. The coolant is routinely
changed after 3 to 4 months of service except as noted in the shop's
operating procedures.
Potential for Pollution Prevention / Waste Minimization or Recommendations:
There are limited operational and administrative pollution prevention
opportunities to reduce the spent coolant waste.
-------
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
PROCESS FLOW DIAGRAM
PWA ASSESSMENT ID CODE: SNL/CA MS001
TITLE: Machine and Fabrication Shop
Unspecified Aqueous Solution
CY91 Generated 11,000 pounds
COOLANT
SOLUTION
Water, 20 Parts
Aqua-Syn 180,
1 Part
Replaced
"only as "
required
Small Metalic Chips
Thin Film Machine Oil
A total of
35 machines
including:
19 lathes,
9 mills,
5 grinders,
and 2 handsaws
use coolant.
Waste
Solution
55 GAL
Sent to Off-site
Disposal
-------
PPOA-2
Pago; 1 of
Pollution Prevention Opportunity Assessment
Material & Waste Stream Summary
Assessment ID Code: SNUG A MS001
Title: Machine and Fabrication Shop
Input
Material
Name/No.
Water
Aqua-Syn
Metafic chips
Machine oil
Annual
Quantity
Used
10400.0
520.0
65.0
15.0
%
Product
%
Recycled
Total Releases
%
Air
5
1
%
Liquid
95
99
100
%
Solid
100
Totals/Page: 11000.0
Total Annual Quantity 11000.0
Does the process require further analysis
based on the site's Priority Material/Waste
Stream List?
ONo
[Level II DLevel II
9/16/93
-------
Page _1_of J
Pollution Prevention Opportunity Assessment
Option Summary
Assessment ID Code: Title:
SNL/CA MS001 Machine and Fabrication Shop
Option Description
One consideration for an operational improvement would be to recycle the spent coolant. According to industrial
sources, a reduction of approximately 50% in the present amount of coolant disposed of.
Type
Recycling
Consider?
• Yes ONo
Feasibility
Fair
Estimated
Cost
$25,000.00
Estimated
Savings
$100.00
Anticipated
Reduction Qty
5,000.00
Qpilan Description
&°-* Analyze the spent coolant solution for contaiminants and determine if it is indeed hazardous.
2
Type
Disposal
Consider?
OYes 9No
Feasibility
Poor
Estimated
Cost
$5,000.00
Estimated
Savings
$100.00
Anticipated
Reduction Qty
1,0000
-------
Date
8/31/91
Pollution Prevention Opportunity Assessment
Final Summary
Assessment ID CodeSNUCA MS001
Title: Machine and Fabrication Shop
Assessment:
A Level I and Level II PWA were completed on the Machining and Fabrication Shop
coolant waste stream. The machinist responsible for the operational maintenance of
the machine shop equipment had limited suggestions for reducing the amount of
spent coolant generated. Recycling and treatment options were generated and
evaluated. Assumptions made during this assessment were: the level of activity of the
machine shop is relatively stable; the coolant must be changed on a periodic basis
which is dependent on use and/or time and; disposal costs are relatively stable.
Conclusions:
The PWA team concluded the options are not economically feasible at this time since:
1) option one would require a considerable investment with the possibility of
increasing the actual amount of coolant waste caused by contamination; 2) the
recycling equipment presently available is not designed to treat the small quantity of
spent coolant generated; 3) a conservative approach regarding waste management is
consistent with the site's policy.
Recommendations:
The Line Management will continue monitoring the amount of waste generated and
the availability of recycling equipment for improvement in the economical feasibility of
implementation.
-------
APPENDIX F
LEVEL III EXAMPLE PPOA
-------
Worksheet 1
Level ill
Original Issue Date;
Revision No.:
Revision Date:
OI-Dae-1993
Pollution Prevention Opportunity Assessment
PPOA Team
PPOA Title: Polyurethane Foam Mixing and Curing
PPOA ID Code(s): G517-034-Machine_Mix
Name
"Team Leader
Additional Resources
Job Classification
Phone
*Bill Harrison
John Taylor
Albert Green
Mary White
Violet Jones
Process Engineer
Area Supervisor
Foam Machine Operator
Foam Machine Operator
Area Production Planner
X1234
X1235
X1235
X1235
X1236
Name
Phone
PPOA Coordinator
Waste Management
Industrial Hygiene
Environmental Protection
Safety
Fire Protection
Process Engineering
Materials Engineering
Utilities Engineering
Facilities Engineering
Maintenance (Equipment)
Analytical Lab Testing
Scheduling
Purchasing
Nancy Notrebmep
Hakim Senoj
Tim Sregge
Dottie Muldune
X5432
X5433
X5434
X5431
11/93
-------
Worksheet 2
Level 111
Revision No.:
Revision Date:
Pollution Prevention Opportunity Assessment
Process Description
PPOA Title: Polyurethane Foam Mixing and Curing
PPOA ID Code(s): G517-034-Machine_Mix
Process Location: Main Building #105, Post FN33
Process Description:
The foam mixing process is a process in which the required material
components are metered and mixed at a defined ratio. The ratio of the two
component streams is set and calibrated by production personnel. The
materials are then mixed during the dispense cycle by the action of a motorized
impeller. The mixed material "foam" is transferred manually to a mold and cured
at temperatures from 165 to 350 deg. F. for four to six hours. Input materials
include polyol resins, isocyanates, cleaning solvent and processing supplies.
Five foam dispensing units are used. They range in age from four to fifteen
years. The cure ovens are ventilated as is the foam pouring area. The foam
machine operators have sufficient training to operate the dispensing units.
Their previous training did not emphasize pollution prevention.
Waste streams include solid and liquid waste from the foaming operations as
well as air emissions from the foam pouring and curing activities.
Description of Major Product(s) of Process:
Molded Polyurethane Foam Products
11/93
-------
Level 111
Revision No.: 0
Revision Data:
Pollution Prevention Opportunity Assessment
Process Flow Diagram
PPOA Title or PPOA ID Code(s):
G517-034-Machine Mix
Inputs:
Isocyanate Comp.
Resin Component
Solvent
Supplies
Process:
Foam Mixing
and Curing
Outputs:
Product
Hazardous
Non-Hazardous
Other
(PR2)
(PR3)
Solid
Foam
Product
Liquid
Air
Solid
Purge
Waste
Calibration
Waste
Air
Isocyanate
Emissions
(NH2)
(NHS)
Solid
Scrap
Product
Liquid
Air
(Sri)
(cm)
(OT3)
Solid
Liquid
Air
11/93
-------
Level
Time frame
Pollution Prevention Opportunity Assessment
Material Balance Summary
PPOA Title or PPOA ID Code(s): G517-034-Machlne_Mlx
Revision No.:
Revision Date;
Page 1 of
muni, ui— uan — 9£
To: 31-Dec-92
Material
Description
Isocyanate
Resin
Solvent
Supplies
Foam
Totals/Subtotals
Total
Input
313.6
186.4
80.0
94.0
0.0
674.0
Total
Output
124.5
73.5
80.0
94.0
302.0
674.0
Stream
ID Code
Foam
Product
(S)
237.0
237.0
Stream
ID Code
Purge
Waste
@)
98.3
58.9
80.0
94.0
331.2
Stream
ID Code
Calibration
Waste
(HZ2)
24.4
14.6
39.0
Stream
ID Code
Isocyanate
Emissions
(HZS)
1.8
1.8
Stream
ID Code
Scrap
Product
(NHI)
65.0
65.0
Stream
ID Code
o
Stream
ID Code
O
Stream
ID Code
O
Stream
ID Code
O
11/93
-------
Worksheet 5
Level 111 Revision No.: _
Revision Date:
Page 1 of
Pollution Prevention Opportunity Assessment
Material Cost
PPOA Title or PPOA ID Code(s); G517-034-Machine_Mix
Material
Isocyanate Component
Resin Component
Solvent
Supplies (paper cups, etc.)
Stock Number
(if applicable)
Cost Per
Unit
$1.96/lb
$2.25/1 b
$0.27/1 b
$O.S7/lb
Total /
Subtotal
Annual Cost
$614.65
$419.40
$ 21.60
$ 53.60
$1109.25
Waste Disposal Cost:
Material / Waste Stream
Waste Liquid
Waste Solid
Scrap Product
Waste Stream
Category
Haz. Liquid
Haz, Solid
Non Haz. Solid
Cost Per
Unit
$4.60/lb
$2.97/lb
$0.69/lb
Total/
Subtotal
Annual Cost
$179.40
$983.66
$ 44.85
$1207.91
11/93
-------
Worksheet 6
Level III
Pollution Prevention Opportunity Assessment
Option Generation
PPOA Title or PPOA ID Code(s): GS17-034-Machme-Mix
Revision No.:
Revision Date:
Practices &
Procedures
Material
Substitution
New Product
&/or Process
Reduce calibration
Amount & duration.
Reduce solvent
purge time
Increase operator
^awareness & training
Redefine foam
kit requirements
In-line calibration
system
Use submerged
pumps
Equipment
Modification
Pollution
Prevention
Options
11/93
-------
Worksheet 7
Level III Revision No.: 0_
Revision Date:
Page 1 of 2
Pollution Prevention Opportunity Assessment
Option Description
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Option Name and Description
(Include input materials, products affected, and anticipated reduction quantity.)
Option No. 1 : Calibration Reduction. Reduce the amount and duration of the
calibration shots for the foam dispensers. Use new analytical methods "nitrogen
testing" to justify the reduced level.
Consider; Yes X No_
Practices & Procedures X Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation
Option No. 2 : Increase Awareness and Training. Conduct training session to
increase pollution prevention awareness. Instruct in the importance of the individual
in the waste generation process.
Consider: Yes X No_
Practices & Procedures X Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation
Option No. 3 : Use Submerged Pumps. Replace gear pumps on foam
machines with in-tank pumps. Leakage will be into material tanks. This will eliminate
material waste and exposure as the result of clean-up
Consider: Yes X No
Practices & Procedures Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process X Recycling, Reuse, & Reclamation
Option No. 4 : In-Line Calibration System. Purchase new foam equipment
with "in-line" calibration capability. This would replace the open cup method and
would reduce the liquid and solid waste streams
Consider: Yes X No
Practices & Procedures Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification X
New Product &/or Process Recycling, Reuse, & Reclamation
-------
Worksheet 7
Level III Revision No.:
Revision Date:
Page 2 of 2
Pollution Prevention Opportunity Assessment
Option Description
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Option Name and Description
(Include Input materials, products affected, and anticipated reduction quantity,)
Option No. 5 : Substitute for TDI. Lessen the toxicity of the waste stream by
replacing TDI isocyanate with a PMDI based foam system. PMDI is not a carcinogen
and is not a RCRC Hazardous waste.
Consider: Yes X No_
Practices & Procedures Waste Segregation/Hazard Reduction
Material Substitution X Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation
Option No. 6 : Reuse Calibration Material. Retain spent calibration material
for use on low end product requirements. This could include machine tryout parts,
or foam billets used as base material for holding fixtures.
Consider; Yes X No_
Practices & Procedures Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation X
Option No. 7 : Reduce Solvent Purge Time. Reset the solvent timers on the
foam machine to the absolute minimum to flush the mix head. Subsequent soaking
of mixer blade and housing can also reduce the required amount.
Consider; Yes X No_
Practices & Procedures X Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation
Option No. 8 : Redefine Foam Kit Requirements. Set-up separate material
numbers for resin and isocyanate components so ratio/usage of material will be
balanced. Current "matched set" distribution result in waste of excess component.
Consider: Yes X No_
Practices & Procedures X Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation
-------
Worksheet 8
Level
Revision No.: 0
Revision Date: _
Page 1 of 2_
Pollution Prevention Opportunity Assessment
Options Cost Evaluation
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Option No.:
1
Option No.:
2
Option No.:
3
Option No.:
4
Option No.:
5
Implementation Costs
Purchased Equipment
Installation
Materials
Utility Connections
Engineering
Development
Start up / Training
Administrative
Other
Total Implementation
Cost
$250
$100
$50
$400
$100
$100
$50
$250
$500
$100
$150
$150
$900
$75,000
$10,000
$2000
$3000
$5000
$95,000
$1000
$500
$1500
Incremental Operating Costs
Change in Raw
Materials
Change in Maintenance
Change in Labor
Change in Disposal
Other
Annual Operating
Savings/(Cost)
$215
$500
$50
$765
$100
$50
$150
Incremental Intang
Penalties and Fines
Future Liabilities
Other
Annual Intangible
Savings/(Cost)
Total Annual
Savings/(Cost)
Payback Period
$0
$765
0.5 yrs
$0
$150
1 .6 yrs
$150
($150)
$100
$100
$750
$500
$600
$1850
$500
$500
$1000
ible Costs
$0
$100
9.0 yrs
$0
$1850
51 yrs
$0
$1000
1.5 yrs
11/93
-------
Worksheet 8
Level III
Revision No.: 0
Revision Date:
Page 2 of 2_
Pollution Prevention Opportunity Assessment
Options Cost Evaluation
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Option No.:
6
Option No.:
7
Option No.:
8
Option No.:
Option No.:
Purchased Equipment
Installation
Materials
Utility Connections
Engineering
Development
Start up / Training
Administrative
Other
Total Implementation
Cost
$200
$200
$150
$150
$300
$150
$150
$300
Incremental Operating Costs
Change in Raw
Materials
Change in Maintenance
Change in Labor
Change in Disposal
Other
Annual Operating
Savings/(Cost)
$180
$180
$15
$125
$140
Penalties and Fines
Future Liabilities
Other
Annual Intangible
Savings/(Cost)
Total Annual
Savings/(Cost)
Payback Period
$0
$180
1.1 yrs
$0
$140
2.1 yrs
$350
$350
mm>mfmmmmm:mmmmm] ; • •.
$0
$350
0.9 yrs
11/93
-------
Worksheet 9
Level ill
Revision No.:
Revision Date:
Page 1 of
Pollution Prevention Opportunity Assessment
Weighted Sums Option Evaluation
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Criteria
Public Health, Safety, &
Environment
Employee Health & Safety
Regulatory Compliance
Economic
Implementation Period
Improved Operation /
Product
Other
Subtotal
Likelihood of Technical
Success (Multiplier)
Likelihood of Useful
Results (Multiplier)
Total
Rank
Weight
W
10
10
8
6
4
2
iiiiiiiiiitill
liiiiiiiiiiilif
:-;•:•:•:--•.-:-.• :-:-;-:-:•:-;•:•;•;•:•:•:•:•:•:•:•:•:•:•:
;:;>:-[[[
:^S:?:^:^:^'^SS$!::™'. *:: :•
Option N
Scale
'S1
8
8
7
8
7
5
sssssiisspsss?
X
X
:%::?S:^S;:^^SS::^::::
;;x:x:£:;:x:;:;:;:;:;:|:;:;:;:£:j:;:;:;:
o.: 1
'WxS'
80
80
56
48
28
10
302
0.8
0.9
217
7
Option N
Scale
'S'
6
7
7
9
9
8
X
X
o.: 2
'WxS1
60
70
SB
54
36
16
292
1.0
0.9
262
4
Option N
Scale
•S'
6
5
8
7
6
7
X
X
x*:W:W:*: : ?:v£*:;;::
xl:;:*:*:*:*: : :|: £>:-#
;S:;:;:;:£:;::$- | £ <:;:$:•:
1111 1111
o.: 3
'WxS1
60
50
64
42
24
14
254
0.9
0.9
205
8
Option N
Scale
'S'
7
8
7
5
6
8
lllllllilllll
X
X
o.: 4
'WxS'
70
80
56
30
24
16
276
0.9
0.9
224
5
Option N
Scale
'S'
8
9
9
8
7
8
X
X
'^^?^^^^^^ :¥:
o.: 5
'WxS1
80
so
72
48
28
16
334
1.0
1.0
339
1
-------
IliiiiiBiiiaig^iiiiiiilllKliflaiSllaahi':
Level III
Pollution Prevention Opportunity Assessment
Weighted Sums Option Evaluation
Revision No.:
Revision Date:
Page 2 of
PPOA Title or PPOA ID Code(s): G517-034-Machine Mix
Criteria
Public Health, Safety, &
Environment
Employee Health & Safety
Regulatory Compliance
Economic
Implementation Period
Improved Operation /
Product
Other
Subtotal
Likelihood of Technical
Success (Multiplier)
Likelihood of Useful
Results (Multiplier)
Total
Rank
Weight
W
10
10
8
6
4
2
mi
111 \
• i iiiii
:-;-:-;;:-:|:v:;:::;:;;|x-;::::-:'X:L::^LjLj;j;J;J;J
y;-;J;y;v;J;;;|:;::;::::-:-x-:-:-:-:-;":|:;:':;:j;j:
Option No.: _6
Scale
'S1 'WxS'
6
7
6
7
7
7
1
1
X
X
60
70
48
42
28
14
262
0.9
0.9
212
6
Option No.: 7
Scale
'S1 'WxS'
8
8
7
9
9
6
X
X
5i5:sg;S¥gft;: SSs : f
1111111$ 1 |l M
tp;?SS:tP :w : S
80
80
56
54
36
12
318
1.0
0.9
286
2
Option No.: _8
Scale
'S' 'WxS'
6
7
7
8
8
9
X
X
60
70
56
48
32
18
284
1.0
1.0
284
3
Option No.:
Scale
'S1 'WxS'
X
X
Option No.:
Scale
'S1 'WxS'
X
X
11/93
-------
Worksheet 10
Level HI
Revision No,: 0
Revision Date:
1 of 1
Pollution Prevention Opportunity Assessment
Final Report Check Sheet
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Requirement Completed
Title Page X
PPOA Title
PPOA ID Code(s)
Team members
Issue date/revision date/revision no.
Executive Summary X
Process description
Process assessment
Option summary and analysis
Conclusions
Recommendations
Introduction X
Background of evaluation
Process Description X
Associated equipment
Process flow diagram
Process Assessment X
Methodology
Material Balance
Unusual occurrences
Option Summary and Analysis X
Option description and rank
Upstream/Downstream impacts
Material usage
Anticipated reduction
Estimated costs
Estimated benefits
Feasibility
Waste streams affected
Conclusion X
Concluding evaluation
Option analysis decisions
Concerns
Options already implemented
Lessons learned
Recommendations X
Future work
New equipment
Implementation strategies
Worksheets X
1-10
11/93
-------
APPENDIX G
MODEL PPOA WORKSHEETS
-------
Worksheet 1
Level
Original Issue Date:
Revision No.:
Revision Date:
Pollution Prevention Opportunity Assessment
PPOA Team
PPOA Title:
PPOA ID Code(s):
Name
Job Classification
Phone
*Team Leader
Additional Resources
Name
Phone
PPOA Coordinator
Waste Management
Industrial Hygiene
Environmental Protection
Safety
Fire Protection
Process Engineering
Materials Engineering
Utilities Engineering
Facilities Engineering
Maintenance (Equipment)
Analytical Lab Testing
Scheduling
Purchasing
11/93
-------
Worksheet 1
Worksheet 1 provides the identification of the PPOA assessment team. For the PPOA
to be successful, employees involved with the process should be members of the
team. The assessment team needs a leader, members, and additional resources,
as required.
The team leader should have technical knowledge of the process, knowledge of the
current production operations, and the personnel involved. The leader shall
assemble the team to perform the assessment. Team members may include
process engineers, product engineers, knowledgeable department personnel such
as production operator(s), and material experts. Additional resources may be called
in to provide information not available within the team. The size of the team may be
large for complicated processes, but should be kept to a minimum to maintain focus.
1. Original Issue Date: List the original issue date of the PPOA.
2. Revision No.: List the revision number for this worksheet. {Original issue = 0.}
3. Revision Date: List the most recent revision date for this worksheet.
4. PPOA Title: List the PPOA title selected by the team.
5. PPOA ID Code(s): List the PPOA ID Code(s) selected by the team.
6. Name, Job Classification, Phone: To facilitate team meetings and for future
reference, this information should be completed when the PPOA team is
formed.
-------
Level III
Revision No.:
Revision Date:
Pollution Prevention Opportunity Assessment
Process Description
PPOA Title:
PPOA ID Code(s):
Process Location:
Process Description:
Description of Major Product(s) of Process:
-------
Worksheet 2
Worksheet 2 provides a brief description of the process. The main elements of
the process description are the process location, input materials, equipment,
summary of operations performed, process controls, operator training, major
products, and the waste streams affected.
1. Revision No.; List the revision number for this worksheet,
2. Revision Date: List the most recent revision date for this worksheet.
3. PPOA Title: List the PPOA Title given on Worksheet 1.
4. PPOA ID Code(s): List the PPOA ID Code(s) given on Worksheet 1.
5. Process Location: List the best descriptor of the process location. It may
be a department, building, room, etc..
6. Process Description: The process description should detail important
attributes of the process. Equipment, summary of operations
performed, process controls, input materials, and operator training
(qualification or certification) should be included.
7. Description of Major Product(s) of Process: Describe the major products
which result from this process or the reason the process is being
perfromed.
-------
Worksheet 3
Sty to 1
Revision No.:
Revision Date:
Level III
Pollution Prevention Opportunity Assessment
Process Flow Diagram
PPOA Title or PPOA ID Code(s):
Inputs:
Outputs:
Highlight those sections that apply.
: Use Worksheet 4 to identify and
quantify the appropriate stream.
Non-Hazardous
(PRJ)
(PR2)
(PR3)
Solid
Liquid
Air
(HZI)
(HZ2)
(HZS)
Solid
Liquid
Air
(NHI)
(NH2)
(NH|)
Solid
Liquid
Air
(on)
(012)
(ora)
Solid
Liquid
Air
11/93
-------
Worksheet 3
Worksheet 3 provides a process flow diagram for the PPOA. The flow diagram should identify
all PPOA ID Code(s) associated with the process, all input materiats, and outputs
(products/wastes). The flow diagram should track materials from the time they enter the
process boundary until they leave. This diagram represents a very simplistic flow model; a
more detailed diagram may be required to identify all waste streams, especially for complex,
multi-step processes.
1. Revision No.; List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
4. Process Flow Diagram; List the input materials on the lines provided. Fill in the Process
Name box. Then highlight those outputs that are applicable to the process (e.g.
Product, Hazardous, etc.). Then sub-categorize those outputs into solid, liquid, or air
emission streams by highlighting the corresponding output stream. A Stream ID Code is
provided for each sub-category of waste.
5. Outputs: The Stream ID Code provides a uniform coding scheme for the release
information requested on Worksheet 4. A brief waste description may be recorded in the
box to the right of the Stream ID Code.
-------
Revision No.:
Revision Date:
Level III
Pollution Prevention Opportunity Assessment
Process Flow Diagram
PPOA Title or PPOA ID Code(s):
Inputs:
Solid
Liquid
Air
(on)
(^2)
(OT3)
Solid
Liquid
Air
•tt:vX-^x<<<<<<^x<*x-x-:-:-x*:^;-;-x-X"X"X"X^
m ^^mismmm^^mmmm^^ff^^^^msmmrmmmm
quantify the appropriate stream.
(pm)
(pj§)
(PRS)
Solid
Liquid
Air
Solid
Liquid
Air
(HZI)
(nz2)
(HZS)
Solid
Liquid
Air
(em)
(5^
(RDS)
Solid
Liquid
Air
11/93
-------
Worksheet 3
Worksheet 3 provides a process flow diagram for the PPOA. The flow diagram should identify
all PPOA ID Code(s) associated with the process, all input materials, and outputs
(products/wastes). The flow diagram should track materials from the time they enter the
process boundary until they leave. This diagram represents a very simplistic flow model; a
more detailed diagram may be required to identify all waste streams, especially for complex,
multi-step processes.
1. Revision No.: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
4. Process Flow Diagram: List the input materials on the lines provided. Fill in the Process
Name box. Then highlight those outputs that are applicable to the process (e.g.
Product, Hazardous, etc.). Then sub-categorize those outputs Into solid, liquid, or air
emission streams by highlighting the corresponding output stream. A Stream ID Code is
provided for each sub-category of waste.
5. Outputs: The Stream ID Code provides a uniform coding scheme for the release
information requested on Worksheet 4. A brief waste description may be recorded in the
box to the right of the Stream ID Code.
-------
: •: •: -x—x-^xvx-x>> x-x-x->x •: •
Level
Revision No.:
Revision Date:
Pollution Prevention Opportunity Assessment
Process Flow Diagram
PPOA Title or PPOA ID Code(s):
Inputs:
Solid
Liquid
Air
/Process:
Outputs:
(Jim)
(NH2)
(NH^)
Solid
Liquid
Air
Product
Hazardous- RCRA
Hazard, non RCRA
Toxic, TSCA
Non-Hazardous
Other
to worksheet 3B
(for radioactive wastes)
(pm)
(PR2)
(PR3)
Solid
Liquid
Air
Solid
Liquid
Air
(HRI)
(HR2)
(HRS)
Solid
Liquid
Air
(HNI)
(HN2)
(HN3)
Solid
Liquid
Air
11/93
-------
Worksheet 3A
Worksheet 3 provides a process flow diagram for the PPOA. The flow diagram should
represent all PPOA ID Code(s) associated with the process, all input materials, and outputs
(products/wastes). The flow diagram should track materials from the time they enter the
process boundary until they leave. This diagram represents a very simplistic flow model; a
more detailed diagram may be required to identify all waste streams, especially for complex,
multi-step processes.
1, Revision No.: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet!
4. Process Flow Diagram: List the input materials on the lines provided. Fill in the
Process Name box. Then highlight those outputs that are applicable to the process
(e.g. Product, Hazardous, etc.). Then categorize those outputs into solid, liquid, or
air emission streams by highlighting the corresponding output stream. A Stream ID
Code is provided for each category of waste.
5. Outputs: The Stream ID Code provides a uniform coding scheme for the release
information requested on Worksheet 4. A brief waste description may be recorded
in the box to the right of the Stream ID Code.
DOE Definitions:
Hazardous Waste - Waste, which because of its quantitiy, concentration, or physical,
chemical or infectious nature may (a) cause or significantly contribute to an increase
in mortality or an increase in serious irreversible, or incapacitating reversible illness,
or (b) pose a substantial present or potential hazard to human health or the
environment when improperly treated, stored, transported, disposed of, or otherwise
managed. Hazardous waste can be further defined as:
RCRA-reguIated - solid waste not specifically excluded from regulation under 40 CFR
261.4, or delisted by petition, that is either a listed hazardous waste (40 CFR 261.30 -
261.33) or exhibits the characteristics of a hazardous waste (40 CFR 261.20 -
261.24).
Non RCRA-regulated - any other hazardous waste not specifically regulated under
TSCA or RCRA, which may be regulated by the state or local authorities, such as
used oil.
TSCA Waste - Individual chemical wastes (both liquid and solid), such as polychlorinated
biphenyls (PCBs).
-------
Revision No.:
Revision Date:
Level
Pollution Prevention Opportunity Assessment
Process Flow Diagram
PPOA Title or PPOA ID Code(s):
Solid
Liquid
Air
from Worksheet 3A
Outputs:
(LMI)
(LM|)
(LMJ)
Solid
Liquid
Air
High Level
Transuranic, (TRU)
TRU, Mixed
Low Level
Low Level, Mixed
Other, Rad
Solid
Liquid
Air
(ryj)
(?U2)
(rua)
Solid
Liquid
Air
(TMI)
(TM2)
(TMS)
Solid
Liquid
Air
(LLJ)
(J£2)
(E)
Solid
Liquid
Air
11/93
-------
Worksheet 3B
Worksheet 3 provides a process flow diagram for the PPOA. The flow diagram should
represent all PPOA ID Code(s) associated with the process, all input materials, and outputs
(products/wastes). The flow diagram should track materials from the time they enter the
process boundary until they leave. This diagram represents a very simplistic flow model; a
more detailed diagram may be required to identify all waste streams, especially for complex,
multi-step processes.
1. Revision No,: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
4. Process Flow Diagram: List the input materials on the lines provided. Fill in the
Process Name box. Then highlight those outputs that are applicable to the process
(e.g. Product, Hazardous, etc.). Then categorize those outputs into solid, liquid, or
air emission streams by highlighting the corresponding output stream. A Stream ID
Code is provided for each category of waste.
5. Outputs: The Stream ID Code provides a uniform coding scheme for the release
information requested on Worksheet 4. A brief waste description may be recorded
in the box to the right of the Stream ID Code.
DOE Definitions:
High Level Waste- Irradiated reactor fuel, liquid wastes resulting from operation of the
first cycle solvent extraction system, or equivalent, and the concentrated wastes
from subsequent extraction cycles, or equivalent, in a facility for reprocessing
irradiated reactor fuel, and solids into which such liquid wastes have been
converted. (10CFR60.2)
Transuranic Waste - Waste that is contaminated with alpha-emitting radionuclides with
(1) an atomic number greater than 92 (heavier than uranium); (2) half-lives greater
than 20 years; and (3) concentrations greater than 100 nanocuries per gram of
waste.
Transuranic Mixed Waste: - Waste which contains both transuranic waste and
hazardous components, as defined by the Atomic Energy Act and RCRA,
respectively.
Low Level Waste: - Radioactive Waste not classified as high level waste, transuranic
waste, spent nuclear fuel, or by-product material [specified as uranium or thorium
tailings and waste in accordance with DOE Order 5820.2A].
Low Level Mixed Waste: - Waste which contains both low level waste and hazardous
components, as defined by the Atomic Energy Act and RCRA, respectively.
-------
Level III
Time frame
From:
To:
Polli
Material
Description
Totals/Subtotals
Total
Input
ution Prevention Opportunity Assessment
Mass Balance Summary
PFOA Title or PPOA ID Code(s):
Total
Output
Stream
ID Code
o
Stream
ID Code
O
Stream
ID Code
O
Stream
ID Code
O
Stream
ID Code
O
Stream
ID Code
O
Revision No.;
Revision Date:
Page
Of
Stream
ID Code
O
Stream
ID Code
O
Stream
ID Code
O
11/93
-------
Worksheet 4
A material balance is a summation of the total quantity of input material
to a process and the releases to the environment, another process, or
made into product. The purpose of Worksheet 4 is to tabulate this
information and total the inputs and outputs for all streams.
1. Revision No.: List the revision number of the PPOA.
2.
3.
Revision Date: List the most recent revision date for the PPOA
worksheet.
PPOA Titie/PPOA ID Code(s):
given on Worksheet 1.
List the PPOA Title or ID Code(s)
4. Page
of
Indicate the page number for this worksheet and
the number of pages for this worksheet.
5. From/To: Report the dates (month and year) for the time period
covered. An annual period is suggested for purposes of averaging
and documenting performance toward facility goals.
6, Material Description: List the material name and stock number
(optional) or the output product if different than originating material.
7. Units : Enter the unit of measure for the input/output summary.
A consistent unit of measurement is suggested. If requirements
dictate mixing units, designate the units for a particular column
under the Stream ID Code heading.
8. Total Input: For the material described in the far left column enter the
weight of material used in the process during the time frame
specified.
i. Total Output: For the material specified in the Material Description
column enter the weight of the output. This is the sum of all waste
streams and any product generated. For processes where chemical
reactions take place, input materials are consumed or changed to
different compounds, a separate entry in the Material Description
column is required to adequately define the output. In these cases,
the input and output quantities will not balance for the listed
material in that row.
10. Output Quantity: Use these columns to break down the total output
into output categories. Refer to Worksheet 3 for the appropriate
Stream ID Code for the output type. Enter the Stream ID Code at
the top of the column (e.g., HZ1 for a hazardous solid waste
stream), then enter the discharge amount for the material described
in the Material Description column that relates to that Stream ID
Code. Continue across the worksheet for all Stream ID Code(s)
utilized in Worksheet 3.
11. Totals/Subtotals: Sum the Total Input, Total Output, and Output
columns. Record the sum at the bottom row of the last worksheet.
Subtotals are recorded at the bottom row for other pages of the
worksheet. The Total Input column should equal the Total Output
column unless there is system accumulation. The Total Output
column should also be the sum of all the Stream ID Code output
streams.
Stream ID Codes:
Designator
Product
Hazardous
Non-Hazardous
Radioactive
Mixed
Other
Hazardous, RCRA
Hazardous, Non-
RCRA
Toxic, TSCA
High Level
Transuranic, TRU
TRU, Mixed
Low Level
Low Level, Mixed
Other, Radioactive
Style 1
PR
HZ
NH
OT
Style 2
PR
HZ
NH
RD
MX
OT
Style 3
PR
NH
OT
HR
HN
TS
HL
TU
TM
LL
LM
OR
Solid Stream = 1, Liquid Stream = 2, Air Stream = 3
Style refers to the version of Worksheet 3 used.
-------
Worksheet 5
Level
Revision No.: _
Revision Date:
Page of _
Pollution Prevention Opportunity Assessment
Material Cost
PPOA Title or PPOA ID Code(s):
Input Material Cost:
Material
Stock Number
(if applicable)
Waste Disposal Cost:
Material / Waste Stream
Waste Stream
Category
Cost Per
Unit
Total /
Subtotal
Annual Cost
Cost Per
Unit
Total /
Subtotal
Annual Cost
-------
Worksheet 5
Worksheet 5 details the cost of the PPOA input materials (use the quantities from
Worksheet 4) and the cost of disposal for these materials. The material cost may be
obtained from Purchasing or Stores. The cost of disposal may be obtained from Waste
Management or Accounting. Annual Cost is calculated from the amount of material placed
in the process or from the amount of disposed material, multiplied by the cost per unit.
1. Revision No.: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. Page of : Indicate the number of this page and the total number of pages for
this worksheet.
4. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
5. Input Material Cost: List the material, stock number (if applicable), cost per unit
($/lb., $/gal, etc.), and the annual cost for this process.
6. Waste Disposal Cost: List the material or waste stream, waste stream category, (e.g.,
hazardous liquid), stock number if applicable, the cost per unit ($/lb., $/gal, etc.),
and annual cost.
7. Totals / Subtotals: Record the sum of the annual costs for the materials or waste
streams listed. There will be a total for both the input material cost and waste
disposal cost.
-------
Worksheet 6
Level III
Pollution Prevention Opportunity Assessment
Option Generation
PPOA Title or PPOA ID Code(s);
Practices &
Procedures
Revision No.:
Revision Date:
Material
Substitution
fidr Prlaceis
Equipment
Modification
Pollution
Prevention
Options
11/93
-------
Worksheet 6
Worksheet 6 provides a tool for option generation.
The purpose of this diagram (sometimes referred to
as a Fishbone Diagram) is to help generate pollution
prevention ideas. It is especially useful in a
brainstorming session to group ideas undersimilar
pollution prevention categories. It also helps insure
that all of the pollution prevention categories are
considered.
1. Revision No.: List the revision number for this
worksheet.
2. Revision Date: List the most recent revision date
for this worksheet.
3. PPOA Title or PPOA ID Code(s): List the PPOA title
or PPOA ID Code(s) given on Worksheet 1.
4. Brainstorming ideas: Using the Fishbone
Diagram, briefly document ideas for pollution
prevention.
The following definitions clarify each of the major
categories.
Practices & Procedures - Good operating
practices and procedures apply to the human
aspect of operations. They are largely
efficiency improvements. Examples are:
Pollution Prevention Programs, personnel
training, material handling & inventory
practices, material loss prevention, scrap
reduction, cost accounting, production
scheduling, etc.
Material Substitution ~ Changes to the input
materials of the process. The result is a
reduction or elimination of a pollutant or
hazard.
New Product &/or Process -- Product changes
which result in the reduction or elimination of
waste. In addition, a different process can be
used to create the same product with the intent
of minimizing waste.
Waste Segregation/Hazard Reduction -- Actions
taken to segregate waste streams to prevent
nonhazardous waste from being designated
and handled as hazardous. Hazard reduction
can result from changes to the physical,
chemical, or biological character or
composition of the waste. These include
neutralization, toxicity reduction, or volume
reduction.
Equipment Modification -- Changes that occur to
the equipment used in a process. These could
include minor adjustments, additions, or
complete replacements.
Recycling - A material is recycled if it is used,
reused, or reclaimed: (1) if it is used for
something other than its original purpose, (2) if
it goes back into the original process, or (3) if it
is chemically or physically treated for use or
reuse.
-------
Level III
Revision No.:
Revision Date:.
Page pf_
Pollution Prevention Opportunity Assessment
Option Description
PPOA Title or PPOA ID Code(s):
Option Name and Description
( Include input materials, products affected, and anticipated reduction quantity.)
Option No. :
Practices & Procedures
Material Substitution
New Product &/or Process
Option No.
Consider: Yes No
Waste Segregation/Hazard Reduction
Equipment Modification
Recycling, Reuse, & Reclamation
Practices & Procedures
Material Substitution
New Product &/or Process
Option No.
Consider: Yes No
Waste Segregation/Hazard Reduction
Equipment Modification
Recycling, Reuse, & Reclamation
Practices & Procedures
Material Substitution
New Product &/or Process
Option No.
Consider: Yes No
Waste Segregation/Hazard Reduction
Equipment Modification
Recycling, Reuse, & Reclamation
Practices & Procedures
Material Substitution
New Product &/or Process
Consider: Yes No
Waste Segregation/Hazard Reduction
Equipment Modification
Recycling, Reuse, & Reclamation
11/93
-------
Worksheet 7
The purpose of this worksheet is to further document the pollution prevention options
identified on Worksheet 6. The process by which options are identified should occur in an
environment that encourages creativity and independent thinking. Brainstorming sessions
are effective ways for individuals to generate options. Consideration of the options
generated in a brainstorming session can lead to questions. Answering these questions
may require additional research. Listed below are some of the sources that can help to
answer questions and/or generate additional options.
Literature searches
Technical conferences
Equipment exhibitions
Trips to other plants
Vendor surveys
Contact with design engineers
Contact with personnel in other departments who have participated in similar
PPOAs
Materials engineers
Benchmarking
1.Revision No.: List the revision number for this worksheet.
2. Revision Date; List the most recent revision date for this worksheet.
3. PPOA Title or PPOA ID Code: List the PPOA Title or PPOA ID Code given on
Worksheet 1.
4. Page of : Indicate the number of this page and the total number of pages for this
worksheet.
5. Option: Options generated should be numbered consecutively and placed on this
worksheet (reference Worksheet 6). They may or may not be evaluated. Briefly
describe each option, affected materials and product, any roadblocks to
implementation, upstream and downstream impacts if implemented, and
anticipated reduction quantity.
6. Consider Yes/No: If the suggestion is worth further consideration, check
'Yes1. If the suggestion will not be pursued, check 'No' and indicate
briefly in the Option Description why not.
7. Practices & Procedures, Material Substitution, New Product &/or Process, Waste
Segregation/ Hazard Reduction, Equipment Modification, and Recycling, Reuse, &
Reclamation: Check the appropriate descriptions. See Worksheet 6 for definitions.
-------
Worksheet 8
Level III
Revision No,:
Revision Date:
Page
of
Pollution Prevention Opportunity Assessment
Options Cost Evaluation
PPOA Title or PPOA ID Code(s):
Option No.:
Option No.:
Option No.:
Option No.:
Purchased Equipment
Installation
Materials
Utility Connections
Engineering
Development
Start up / Training
Administrative
Other
Total Implementation
Cost
Option No.:
Incremental Operating Costs
Change in Raw
Materials
Change in Maintenance
Change in Labor
Change in Disposal
Other
Annual Operating
Savincjs/(Cost)
Penalties and Fines
Future Liabilities
Other
Annual Intangible
Savings/(Cost)
Total Annual
Savings/(Cost)
Payback Period
incremental jfritang
|$e Costs
11/93
-------
Worksheet 8
This worksheet provides a method to compare and contrast the pollution prevention options
generated on Worksheet 6 from a cost perspective. The three major cost categories for
weighing options are: Implementation Costs, Incremental Operating Costs, and incremental
Intangible Costs. These costs are totaled for each option considered from Worksheet 7.
This worksheet will aid in completing the economic evaluation portion of Worksheet 9.
1. Revision No.: List the revision for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. Page of : Indicate the number of this page and the total number of pages for
this worksheet.
4. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
5. Implementation Cost: These are the one-time, first-year costs associated with the
implementation of each option. Installation costs should be reported as an estimate.
Implementation Cost may include materials, utility connections, site preparation,
installation, engineering, procurement, start-up, training, permitting, initial catalysts and
chemicals, and working capital; minus the salvage value of any existing equipment.
6. Annual Operating Savings/(Costs): These are the costs associated with day-to-day
operations. List the incremental costs compared to the current process costs (positive for
savings or negative for increased costs) that would be incurred if this option is
implemented. Incremental operating costs could include waste disposal, raw material
consumption, ancillary catalysts and chemicals, labor, maintenance and supplies,
insurance, incremental revenues from increased / decreased production, and incremental
revenues from marketable by-products.
7. Annual Intangible Savings/(Cost): These include hidden, liability, and other costs not
immediately obvious for each option. List the incremental costs compared to the current
process costs (positive for savings or negative for increased costs) that would be incurred
if this option is implemented. These costs could include penalties and fines, future
liabilities (storage, transportation, and disposal of hazardous waste), reporting, consulting
fees, monitoring/testing, record keeping, preparedness and protective equipment,
medical surveillance, manifesting, inspections, and corporate/public image.
8. Total Annual Cost/Savings: This is the sum of the Annual Operating Savings/(Cost) and
the Annual Intangible Savings/(Cost)
S. Payback Period: Divide the Total Implementation Cost by the Total Annual
Savings/(Cost).
-------
Worksheet 9
Level Hi
Pollution Prevention Opportunity Assessment
Weighted Sums Option Evaluation
PPOA Title or PPOA ID Code(s):
Revision No.:
Revision Date:
Page of
Criteria
Public Health, Safety, &
Environment
Employee Health &
Safety
Regulatory Compliance
Economic
Implementation Period
Improved Operation /
Product
Other
Subtotal
Likelihood of Technical
Success (Multiplier)
Likelihood of Useful
Results (Multiplier)
Total
Rank
Weight
W
10
10
8
6
4
2
Ilillii I?
1
111 ;
Option N
Scale
'S'
X
X
o.:
•WxS'
Option N(
Scale
'S'
X
X
a.:
'WxS1
Option N<
Scale
'S'
X
X
iililiiii
D.:
'WxS'
Option N
Scale
'S1
X
X
o.:
'WxS'
Option N
Scale
'S*
X
X
o.:
'WxS1
-------
Many pollution prevention options will be identified in a successful assessment. At this point, it is necessary to identify those
options that offer real potential to minimize waste and reduce costs. Worksheet 9 serves as a screening tool to prioritize or
eliminate suggested options.
1. Revision No.: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. Page
of : Indicate the number of this page and the total number of pages for this worksheet.
4. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on Worksheet 1.
Additional Instructions:
a. The values in the Weight column (designated by W)
represent the facility's priority for the criteria.
b. In the Scale column for each option (designated by 'S'),
rate each criteria by assigning a value from 0-10
(lowest to highest). Use the definitions which follow to
help determine a value.
c. In the 'W x S' column for each option, enter the product of
the weight and scale.
d. Sum the 'W x S1 column for each option to obtain a subtotal.
e. Multiply the subtotal for each option by the Likelihood of
Technical Success.
f. Multiply the value in step e. above for each option by the
Likelihood of Useful Results.
g. Enter the product found in step f. in the Total column for
each option.
h. Assign a priority rank for each option; #1 for the highest
score, #2 for the next highest, and so on.
-------
Worksheet 9 -- (Scale & Multiplier Definitions)
Scale Factor Definitions (0-10)
10
Reduce the risk of loss of life or long-term
environmental damage. High concentrations of
hazardous materials.
8
Reduce the risk of long-term disability or moderate
environmental damage. Moderate concentrations
of hazardous materials.
Reduce the risk of short-term disability or
unplanned releases to the environment. Low
concentrations of hazardous materials.
No effect.
0
Negative effect.
10
Reduce the risk of loss of life through an accident
or long-term exposure.
8
Reduce the risk of permanent or long-term
disability through an accident or long-term
exposure.
Reduce the risk of short-term disability or lost-time
through an accident or long-term exposure.
No effect.
0
Negative effect.
10
Reduce the risk and avoid criminal penalties.
8
Reduce the risk and avoid civil penalties.
Reduce the risk.
No effect.
0
Negative impact.
10
Large savings and short payback.
8
Moderate savings and moderate payback.
Positive cost savings and extented payback.
No cost savings and no possibility of payback.
0
Negative cost savings.
10
Immediate (e.g., within 1 month).
8
Short-term (e.g., within 1 year).
Intermediate (e.g., within 2 years).
Long-term (e.g., within 3 years).
0
Greater than 3 years.
10
8
6
4
0
Significant improvement.
Moderate improvement.
Positive improvement.
No improvement.
Negative effect.
-------
Worksheet 9 - (Scale & Multiplier Definitions)
Multiplier Definitions (0-1)
High likelihood: No major technical breakthrough
required. Well-designed plans to meet objectives
and successful track record exists.
0.5
Medium likelihood: Technical advancements may
be necessary. Key issues are identified but no
specific contingency plans have been made.
0.1
Low likelihood: Major technical breakthroughs are
required. Adequate plans for meeting objectives or
key problems have not been Identified.
^^: M^
High likelihood: Project has demonstrated that it
can meet production requirements. There is a high
confidence that implementation will not create
unacceptable risks. Benefits outweigh the costs.
0.5
Medium likelihood: Project has not yet
demonstrated that it can meet production
requirements. There are reservations that
implementation can be achieved without creating
unacceptable risks. Benefits do not clearly
outweigh the costs.
0.1
Low likelihood: The option is not capable of
demonstrating that it can meet production
requirements. Serious reservations are present
that implementation can be achieved without
creating unacceptable risks. Costs significantly
outweigh the benefits.
-------
Level III
Revision No.:_
Revision Date:_
Page of.
Pollution Prevention Opportunity Assessment
Final Report Check Sheet
PPOA Title or PPOA ID Code(s):
Requirement Completed
Title Page
PPOA Title
PPOA ID Code(s)
Team members
Issue date/revision date/revision no,
Executive Summary
Process description
Process assessment
Option summary and analysis
Conclusions
Recommendations
Introduction
Background of evaluation
Process Description
Associated equipment
Process flow diagram
Process Assessment
Methodology
Material Balance
Unusual occurrences
Option Summary and Analysis
Option description and rank
Upstream/Downstream impacts
Material usage
Anticipated reduction
Estimated costs
Estimated benefits
Feasibility
Waste streams affected
Conclusion
Concluding evaluation
Option analysis decisions
Concerns
Options already implemented
Lessons learned
Recommendations
Future work
New equipment
Implementation strategies
Worksheets
1-10
-------
Worksheet 10
A final report is required for each PPOA. The final report is a compilation of essential facts
about the process, pollution prevention options, feasibility and impact of those options, and
future implementation costs. The report documents the work performed and identifies
funding requirements necessary to implement pollution prevention options. The length of
the final report will depend on the complexity of the PPOA.
1. Revision No.: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. Page of : Indicate the number of this page and the total number of pages for
this worksheet.
4. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
5. While writing the final report, check the blank next to each major requirement as all
elements of that task are completed.
Title Page
Executive Summary
Introduction
Process Description
Process Assessment
Option Summary
& Analysis
Conclusion
Recommendations
Uniquely identify the PPOA, including team members and
issue/revision date.
This should be an overview of all of the elements of the final
PPOA report. It should relate to the reader any information that
is critical about this PPOA.
Present background information and efforts taken to initiate the
PPOA.
Detail process flow and associated equipment. Include
process flow diagram, if desired.
Describe the approach used to complete the PPOA. Document
any assumptions made. Include information on the material
balance.
Present the options generated, impacts if implemented, and
their respective pollution prevention possibilities.
Provide closure to the report. The team's consensus on the
benefits achieved from this PPOA or any concerns respective to
the process should be included.
Describe any actions that will be taken to further advance the
results of this PPOA.
-------
Level I Date:
Page of.
TOe:
Pollution Prevention Opportunity Assessment
Team & Process Description
PPOAIDCode:
Team Members ('Leader) Job Classification Phone
Process Description:
Potential for Pollution Prevention or Recommendations:
11/93
-------
Worksheet 1S
This worksheet provides the scope arid identification of the pollution prevention
opportunity assessment (PPOA) team. For the PPOA to be successful,
employees involved with the activity being assessed should be members of the
team. The assessment team needs a leader, members, and additional
resources, as required.
The team leader should have technical knowledge of the area's operations and
the personnel involved. The leader shall assemble the team to perform the
assessment. Team members may include engineers, waste generators,
waste management specialists, scientists, laboratory technicians, and other
line personnel. Additional resources may be utilized to provide information not
available within the team. The size of the team may be large for complicated
operations, but should be kept to a minimum to maintain focus.
1. Date: List the initiation date for this PPOA.
2. Title: List the PPOA title selected by the team.
3. PPOA ID Code: List the PPOA ID Code selected by the team. This should
be a unique identifier.
4. Team Members, Job Classification, Phone: To facilitate team meetings
and for future reference, this information should be completed when the
PPOA team is formed.
5. Process Description: This should detail important attributes of the
operation. Equipment, summary of operations performed, controls,
input materials, and operator training (qualification or certification) may
be included.
6. Potential for Pollution Prevention or Recommendations: For this process,
describe the potential for pollution prevention, source reduction, and/or
waste minimization. (Is there any pollution prevention potential for the
following changes: material substitution, procedures, process
parameters, equipment, general practices, recycling, reuse, reclamation,
etc.?) Are there any recommendations for this process?
-------
Level I
Date:
Pollution Prevention Opportunity Assessment
Process Flow Diagram
Title or Assessment ID Code:
Inputs:
(MXI)
(MX2)
(MXS)
Solid
Liquid
Air
Solid
Liquid
Air
Solid
Liquid
Air
Solid
Liquid
Air
(NHI)
(NH2)
(NH3)
Solid
Liquid
Air
Solid
Liquid
Air
-------
Worksheet 2S
This worksheet provides a method to document the process flow diagram for
the assessment. The flow diagram should identify all Assessment Code(s)
associated with the process, all input materials, and outputs
(products/wastes). The flow diagram should track materials from the time they
enter the process boundary until they leave. This diagram represents a very
simplistic flow model; a more detailed diagram may be required to identify all
waste streams, especially for complex, multi-step processes.
1. Title or Assessment ID Code(s): List the PPOA Title or PPOA ID Code given
on Worksheet 1S.
2. Page of.
Indicate the page number for this worksheet and the
number of pages for this worksheet.
3. Inputs: List the input materials on the lines provided. Fill in the Process
Name box. Then highlight those outputs that are applicable to the process
(e.g. Product, Hazardous, etc.). Then sub-categorize those outputs into
solid, liquid, or air emission streams by highlighting the corresponding
output stream. A Stream ID Code is provided for each sub-category of
waste.
4. Outputs: The Stream ID Code provides a uniform coding scheme for the
release information. A brief waste description may be recorded in the box
to the right of the Stream ID Code. The code information is summarized in
the table below:
Stream ID Codes
Designator
Product
Hazardous
Non-Hazardous
Radioactive
Mixed
Other
Code
PR
HZ
NH
RD
MX
OT
Solid Stream = 1, Liquid Stream = 2, Air Stream = 3
-------
Level I
Page
of
Pollution Prevention Opportunity Assessment
Material & Waste Stream Summary
Title:
PPOA ID Code:
Input
Material
Annual
Quantity
Used
%
Product
%
Recycled
Total Releases
%
Air
%
Liquid
%
Solid
Does the process require further analysis based on the site's Priority
Material/Waste Stream List? Yes No
Level II Level
-------
Worksheet 3S
This worksheet provides a brief summary of the input materials and output
streams from the operation or activity being assessed. Its purpose is to
provide the pollution prevention team an overview of the waste streams
resulting from the PPOA.
1. Title: List the PPOA title given on Worksheet 1S.
2. Assessment ID Code: List the PPOA ID Code given on Worksheet 18.
3. Input Material: List the material names which enter the operation.
4. Annual Quantity Used: Enter the annual quantity used for each material
listed - include the unit of measure, e.g., Ibs, curies, etc. For input
material from another process, it may be helpful to also identify the
release components of those materials.
5. % Product: For each input material, estimate the percent of the annual
quantity used which goes to product.
6. % Recycled: For each input material, estimate the percent of the annual
quantity used which is recycled.
7. % Air: For each input material, estimate the percent of the annual quantity
used which is an air waste stream.
8. % Liquid: For each input material, estimate the percent of the annual
quantity used which is a liquid waste stream.
i. % Solid: For each input material, estimate the percent of the annual quantity
used which is a solid waste stream.
10. Does the process require further analysis based on the site's Priority
Material/Waste Stream List? Using your site's Priority Material/Waste
Stream List and the DOE Graded Approach Logic Diagram, determine if
further assessment is necessary. If yes, indicate the level of
assessment required.
-------
Worksheet 45
Level II
Page
of.
Pollution Prevention Opportunity Assessment
Option Summary
Title or PPOA ID Code(s)
Option h
o. :
Type
<*)
Option N
Consider?
Feasibility
Estimated
Cost
Estimated
Savings
Anticipated
Reduction Qty
o. :
Type
n
Option N
Consider?
Feasibility
Estimated
Cost
Estimated
Savings
Anticipated
Reduction Qty
o. :
Type
(*)
Consider?
Feasibility
Estimated
Cost
Estimated
Savings
Anticipated
Reduction Qty
(*) Type = Source Reduction, Recycling, Treatment, or Disposal
11/93
-------
Worksheet 4S
This summary sheet serves as a method to record and evaluate the options that have been
identified during brainstorming sessions or other option generating techniques.
1. Title or PPOA ID Code{s): List the PPOA Title or PPOA ID Code given on Worksheet 1S.
2. Option : Options generated should be numbered consecutively. Briefly describe each
option, affected materials, waste streams, upstream/downstream impacts if
implemented, and anticipated reduction quantity if implemented.
3. Type: Indicate whether the option is source reduction, recycling, treatment, or disposal.
4. Consider?: If the option is worth further consideration, enter YES. If not, enter NO and
briefly indicate in the Option Description why not.
5. Feasibility: Provide a brief description. (Excellent, good, fair, poor)
6. Estimated Cost: Estimate an implementation cost.
7. Estimated Cost Savings: Estimate the cost savings.
8. Anticipated Reduction Qty.: Estimate the weight or volume of the waste that will be
reduced.
Note: Typically, it is difficult to estimate the anticipated waste reduction or cost avoidance in
the initial phases of implementation because of many factors. However, for some options,
especially in cases where the option provides complete elimination of a hazardous material
or waste stream, these estimates can be accurately completed.
The process by which options are identified should occur in an environment that encourages
creativity and independent thinking. Brainstorming sessions are effective ways for
individuals to generate options. To make these sessions beneficial, research is often
necessary. Provided below is a fishbone diagram that will help the team generate ideas.
Pollution
Prevention
Options
-------
Level II
Date:
Page of.
Pollution Prevention Opportunity Assessment
Final Summary
Title:
PPOA ID Code(s):
Assessment:
Conclusions:
Recommendations:
-------
Worksheet 5S
This sheet provides a brief summary of other pertinent information about the activity
being assessed. Its purpose is to document how this assessment was performed,
the conclusions reached by the team, and the recommendations for further actions.
1. Date: List the date this sheet was completed,
2. Title: List the title given on Worksheet 1S.
3. PPOA ID Code(s): List the ID Code(s) given on Worksheet 1S.
4. Assessment: Briefly describe the approach (methodology) used to complete this
assessment and any assumptions made.
5, Conclusions: Briefly describe the waste streams or input material to be
minimized, benefits achieved from this assessment, and any concerns
(environmental or health risks) associated with the material or operation.
6. Recommendations: Briefly describe any actions that should or will be taken in
respect to this assessment.
-------
APPENDIX H
REFERENCES
1. U.S. Department of Energy, General Environmental Protection Program, DOE
Order 5400.1 (November 9, 1988).
2. U.S. Department of Energy, Hazardous and Radioactive Mixed Waste Program,
DOE Order 5400.3 (February 22, 1989).
3. U.S. Department of Energy, Radioactive Waste Management, DOE Order
5820.2A (September 26, 1988).
4. U.S. Department of Energy, Environmental Restoration and Waste Management
Five-Year Plan, DOE/S-0070 (1989).
5. U.S. Department of Energy, Applied Research Development, Demonstration,
Testing and Evaluation Plan (Draft) (November 1989).
6. U.S. Department of Energy, Model Waste Minimization and Pollution Prevention
Awareness Plan (1990).
7. U.S. Department of Energy, Process Waste Assessment Guidance (ISO).
8. U.S. Environmental Protection Agency, Facility Pollution Prevention Guide
EPA/600/R-92/088 (May 1992).
9. M.I. Baker and F.E. Kosinski, Process Waste Assessments for Waste Minimization
Planning, U.S. Department of Energy, Oak Ridge Y-12 Plant, Y/DZ-532
(November 21, 1989).
10. E.A. Kjeldgaard, J.H. Saloio, and G.B. Varnado, Development and Test Case
Application of a Waste Minimization Project Evaluation Method, U.S. Department
of Energy, Sandia National Laboratories, SAND90-1178 (August 1990).
11. H.M. Freeman, Hazardous Waste Minimization, McGraw-Hill Publishing
Company (1990).
12. U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation
and Office of Solid Waste, Pollution Prevention Benefits Manual, October 1990.
13. U.S. Department of Energy/Defense Program's, Office of Production Facilities
-------
iPA/625/7-88/003
July 1988
Waste Minimization
Opportunity Assessment Manual
Hazardous Waste Engineering Research Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
-------
Notice
This report has been reviewed by the Hazardous Waste Engineering Research
Laboratory, U.S. Environmental Protection Agency, and approved for publication.
Approval does not signify that the contents necessarily reflect the views and policies of
the U.S. Environmental Protection Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.
Users are encouraged to duplicate those portions of the manual as needed to implement
a waste minimization program. Organizations interested in publishing and distributing the
entire manual should contact the Alternative Technologies Division, Hazardous Waste
Engineering Research Laboratory, U.S. Environmental Protection Agency, Cincinnati,
Ohio 45268, to obtain a reproducible master.
-------
Foreword
The term, "waste minimization" Is heard increasingly at meetings and conferences of
individuals working in the field of hazardous waste management. Waste minimization is an
umbrella term that includes the first two categories of the EPA's preferred hazardous
waste management strategy which is shown below:
1. Source Reduction: Reduce the amount of waste at the source, through changes in
industrial processes.
2, Recycling: Reuse and recycle wastes for the original or some other purpose, such
as materials recovery or energy production.
3. Incineration/Treatment: Destroy, detoxify, and neutralize wastes into less harmful
substances.
4. Secure Land Disposal: Deposit wastes on land using volume reduction,
encapsulation, leachate containment, monitoring, and controlled air and
surface/subsurface waste releases.
In carrying out its program to encourage the adoption of waste minimization, the
Hazardous Waste Engineering Research Laboratory has supported the development of a
recommended procedure for identifying waste minimization applications. This manual
describes that procedure and will be of interest to those responsible for reducing waste
streams, and to those interested in learning about waste minimization in general.
-------
Contents
Page
Foreword iii
Acknowledgments vif
1. Introduction 1
2. Planning and Organization 6
3. Assessment Phase 10
4. Feasibility Analysis 19
5. Implementing Waste Minimization Options 24
Appendices
A. Waste Minimization Assessment Worksheets A-1
B. Simplified Waste Minimization Assessment Worksheets B-1
C. Example Waste Minimization Assessment C-1
D. Causes and Sources of Waste D-1
E. Waste Minimization Techniques E-1
F, Government Technical/Financial Assistance Programs F-1
G. Option Rating: Weighted Sum Method G-1
H. Economic Evaluation Example H-1
-------
List of Worksheets
Page
Appendix A
1. Assessment Overview A-3
2. Program Organization A-4
3. Assessment Team Make-up A-5
4. Site Description A-6
5. Personnel A-7
6, Process Information A-8
7. Input Materials Summary A-9
8. Products Summary A-10
9. Individual Waste Stream Characterization A-11
10. Waste Stream Summary A-15
11. Option Generation A-16
12. Option Description A-17
13. Options Evaluation by Weighted Sum Method A-18
14. Technical Feasibility A-19
15. Cost Information A-25
16. Profitability Worksheet #1: Payback Period A-31
17. Profitability Worksheet #2: Cash Flow for NPV and IRR A-32
18. Project Summary A-33
19, Option Performance A-34
Appendix B
S1. Assessment Overview B-2
S2. Site Description B-3
S3. Process Information B-4
S4. Input Materials Summary B-5
S5. Products Summary B-6
S6. Waste Stream Summary B-7
S7. Option Generation B-8
S8. Option Description 8-9
S9. Profitability B-10
-------
Acknowledgments
The following people are members of the advisory committee that contributed valuable
comments and insights to the preparation of this manual:
Denny J. Beroiz
General Dynamics Pomona Division
Elaine Eby
Office of Solid Waste
US Environmental Protection Agency
John Frick, PhD
Directorate of Supply Operations
Defense Logistics Agency
Kevin Qashlin
Hazardous Waste Assistance Program
New Jersey Department of Environmental Protection
Gregory J. Hollod, PhD
Petrochemicals Department
E.I. DuPont de Nemours & Co.
Gary Hunt
Pollution Prevention Pays Program
North Carolina Department of Environmental
Management
John S. Hunter, III, PhD
3M Corporation
Michael Overcash, PhD
Department of Chemical Engineering
North Carolina State University
Robert Pojasek, PhD
ChemCycle Corporation
Dennis Redington
Monsanto Co
Michael E. Resch
Waste Disposal Engineering Division
US Army Environmental Hygiene Agency
Jack Towers
Waste Reduction Services
Chemical Waste Management
David Wigglesworth
Waste Reduction Assistance Program
Alaska Health Project
Kathleen Wolf, PhD
Source Reduction Research Partnership
Harry M. Freeman of the U.S. Environmental Protection Agency. Office of Research and
Development, Hazardous Waste Engineering Research Laboratory, was the project
officer responsible for the preparation of this manual. Special acknowledgment is given to
Myles Morse of the U.S. Environmental Protection Agency, Office of Solid Waste, for his
assistance and comments. James Lounsbury and Roger Sehecter of the EPA Office of
Solid Waste are also acknowledged for their assistance in the preparation of this manual.
This manual was developed by the Hazardous and Toxic Materials Division of Jacobs
Engineering Group as a subcontractor to Versar, Inc. Marvin Drabkin was the project
manager for Versar. Participating in the preparation of this manual for Jacobs were
Gregory A. Lorton, Carl H. Fromm, Michael P. Meltzer, Deborah A. Hanlon, Sally
Lawrence, Michael S. Callahan, and Srinivas Budaraju.
-------
Section 1
Introduction
Waste minimization (WM) has been successful for
many organizations. By following the procedures
outlined in this manual, a waste generator can:
• Save money by reducing waste treatment and
disposal costs, raw material purchases, and other
operating costs.
* Meet state and national waste minimization policy
goals.
* Reduce potential environmental liabilities.
• Protect public health ami worker health and safety.
* Protect the environment.
Waste minimization is a policy specifically mandated by
the U. S. Congress in the 1984 Hazardous and Solid
Wastes Amendments to the Resource Conservation
and Recovery Act {RCRA), This mandate, coupled
with other RCRA provisions that have led to
unprecedented increases in the costs of waste
management, have heightened general interest in
waste minimization. A strong contributing factor has
been a desire on the part of generators to reduce their
environmental impairment liabilities under the
provisions of the Comprehensive Environmental
Response, Compensation, and Liabilities Act
(CERCLA, or "Superfund"). Because of these
increasing costs and liability exposure, waste
minimization has become more and more attractive
economically.
The following terms, used throughout this manual, are
defined below:
Waste Minimization (WM). In the working definition
currently used by EPA, waste minimization consists of
source reduction and recycling. This concept of waste
minimization is presented in Figure 1*1. Of the two
approaches, source reduction is usually preferable to
recycling from an environmental perspective. Source
reduction and recycling each are comprised of a
number of practices and approaches which are
illustrated in Figure 1-2.
The present focus of WM activities is on hazardous
wastes, as defined in RCRA. However, tt is important
that all pollutant emissions into air, water and land be
considered as part of a waste minimization program.
The transfer of pollutants from one medium to another
is not waste minimization. For example, the removal of
organics from wastewater using activated carbon, in
and of itself, is not waste minimization, since the
pollutants are merely transferred from one medium
(wastewater} to another (carbon, as solid waste).
Waste (ninimization program (WMP). The RCRA
regulations require that generators of hazardous waste
"have a program in place to reduce the volume and
toxicity of waste generated to the extent that is
economically practical." A waste minimization program
is an organized, comprehensive, and continual effort
to systematically reduce waste generation. Generally,
a program is established for the organization as a
whole. Its components may include specific waste
minimization projects and may use waste minimization
assessments as a tool for determining where and how
waste can be reduced. A waste minimization program
should reflect the goals and policies for waste
minimization set by the organization's management.
Also, the program should be an ongoing effort and
should strive to make waste minimization part of the
company's operating philosophy. While the main goal
of a waste minimization program is to reduce or
eliminate waste, it may also bring about an
improvement in a company's production efficiency.
EPA will publish separate guidance on the elements
of effective waste minimization programs. This
guidance will discuss the following elements likely to
be found in an effective WM program:
Top management support
Explicit program scope and objectives
Accurate waste accounting
Accurate cost accounting
Pervasive waste minimization philosophy
Technology transfer
Waste minimization Assessment (WMAL A waste
minimization assessment is a systematic planned
procedure with the objective of identifying ways to
reduce or eliminate waste. The steps involved in
conducting a waste minimization assessment are
outlined in Figure 1-3. The assessment consists of a
careful review of a plant's operations and waste
streams, and the selection of specific areas to assess.
After a specific waste stream or area is established as
the WMA focus, a number of options with the potential
to minimize waste are developed and screened. Third,
the technical and economic feasibility of the selected
options are evaluated. Finally, the most promising
options are selected for implementation.
-------
WASTE MINIMIZATION
J
SOURCE REDUCTION 1
RECYCLING 1
^^ ORDER OF EXPLORATION _, _
FIRST imfwraiMNimMiHHHNniiinimra^^ LAST
HIGH
RELATIVE ENVIRONMENTAL DESIRABILITY
\blLIIY ifo.
HtllBHIIIIIIIHHtWIIIIHIIIl|p^ LOW
WASTE MINIMIZATION
The reduction, to the extent feasible, of hazardous waste that is generated or subsequently treated, stored or
disposed of. It includes any source reduction or recycling activity undertaken by a generator that results in
either (1) the reduction of total volume or quantity of hazardous waste or (2) the reduction of toxidty of the
hazardous waste, or both, so long as such reduction is consistent with the goal of minimizing present and
future threats to human health and the environment (ERA'S Report to Congress, 1986, EPA/530-SW-86-033).
SOURCE REDUCTION
Any activity that reduces or eliminates the generation of hazardous waste at the source, usually within a
process (op. cit,).
RECYCLING
A material Is 'recycled' B it is used, reused, or reclaimed (40 CFR 261.1 (c) (7)). A material is "used or reused*
if ft is either (1) employed as an ingredient (including its use as an intermediate) to make a product; however a
material will not satisfy this condition if distinct components of the material are recovered as separate end
products (as when metal* are recovered from metal containing secondary materials) or (2) employed in a
particular function as an effective substitute for a commercial product (40 CFR 261.1 (c) (5)). A material is
"reclaimed* if It is processed to recover a useful product or if it is regenerated. Examples Include the recovery
of lead values from spent batteries and the regeneration of spent solvents (40 CFR 261.1 (c) (4)).
Figure 1-1. Waste Minimization Definitions
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WASTE MINIMIZATION TECHNIQUES
RECYCLING
(ONSITE AND OFFSITE)
SOURCE REDUCTION
PRODUCT CHANGES
RECLAMATION
SOURCE CONTROL
USE AND REUSE
- Processed for
resource recovery
- Processed as a
by-product
- Product substitution
- Product conservation
- Change in product
composition
- Return to original process
- Raw material substitute
for another process
INPUT MATERIAL
CHANGES
GOOD OPERATING
PRACTICES
TECHNOLOGY
CHANGES
Process changes
Equipment, piping, or
layout changes
Additional automation
Changes in operational
settings
Material purification
Material substitution
Procedural measures
Loss prevention
Management practices
Waste stream segregation
Material handling
improvements
Production scheduling
Figure 1-2. Waste Minimization Techniques
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Figure 1-3. Tht Waste Minimization Assessment Procedure
The recognized need to minimize waste
i
PLANNING AND ORGANIZATION
* Get management commitment
* Set overall assessment program goals
* Organize assessment program task force
Assessment organization
and commitment to proceed^ r
ASSESSMENT PHASE
* Collect process and facility data
* Prioritize and select assessment targets
* Select people for assessment teams
* Review data and inspect site
• Generate options
* Screen and select options for further study
Select new
assessment target*
and reevaluate
previous options
Assessment report of
selected options ^
FEASIBILITY ANALYSIS PHASE
* Technical evaluation
» Economic evaluation
• Select opttons for implementation
Final report, including
recommended options <
IMPLEMENTATION
Justify projects and obtain funding
Installation (equipment)
Implementation (procedure)
Evaluate performance
Repeat the process
Successfully implemented
waste minimization projects
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Incentives for Waste Minimization
Thera are a number of compelling incentives for
minimizing waste. Table 1-1 summarizes some of
these incentives.
Table 1-1. Wast* Minimization Incantlvt*
Economics
* Landfill disposal cost increases.
* Costly alternative treatment technologies.
• Savings in raw material and manufacturing costs.
Regulations
* Certification of a WM program on the hazardous waste
manifest.
* Biennial WM program reporting.
* Land disposal restrictions and bans.
* Increasing permitting requirements for waste handling
and treatment
Liability
• Potential reduction in generator liability for environmental
problems at both onsite and offsrle treatment, storage,
and disposal facilities.
* Potential reduction in liability for worker safety.
Public Image and Environmental Concern
* Improved image in the community and from employees.
• Concern for improving the environment.
EPA intends to publish a manual entitled "Waste
Minimization Benefits Handbook* which will discuss in
detail the cost/benefit analyses of WM options.
About this manual
This manual has been prepared for those responsible
for planning, managing, and implementing waste
minimization activities at the plant and corporate levels.
The manual concentrates on procedures that motivate
people to search, screen, and put into practice
measures involving administrative, material, or
technology changes that result in decreased waste
generation. It is also a source of concepts and ideas
for developing and implementing a waste minimization
program.
The manual is organized as follows:
• Section 2 outlines the planning and organizational
aspects that provide a necessary foundation for a
waste minimization assessment.
* Section 3 describes the assessment phase,
including collecting information, selecting
assessment targets, selecting assessment teams,
and identifying potential WM options.
* Section 5 describes the implementation of attractive
options: obtaining funding, installation and
implementation, and measuring the effectiveness
of implemented options.
A set of worksheets useful in carrying out assessments
is included in Appendix A. Because individual
generators' circumstances and needs vary widely,
users of this manual are encouraged to modify the
procedures and worksheets to fit their unique
requirements. The manual is intended to serve as a
point of departure, rather than as a set of rigid
requirements. Accordingly, Appendix B presents a
simplified set of worksheets that are designed to assist
generators who are interested in performing only
preliminary assessments. These worksheets also
provide a useful framework for conducting
assessments for small businesses and small quantity
generators.
A sample assessment is presented in Appendix C.
Appendix D describes waste streams from common
industrial operations. Appendix E is a catalog and brief
description of waste minimization techniques
applicable in a number of common waste-intensive
operations. Appendix F is a list of addresses and
telephone numbers of state programs for technical
assistance in waste minimization. Appendix Q
presents describes a method for screening and rating
potential waste minimization options for further study.
Finally, an example of an economic feasibility analysis
of a large waste minimization project is presented in
Appendix H.
Section 4 discusses the methods for evaluating
options for technical and economic feasibility.
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Section 2
Planning and Organization
The recognized need to minimize waste
PLANNING AND ORGANIZATION
Get management commitment
Set overall assessment program goals
Organize assessment program task force
Assessment
Phase
Feasibility
Analysis Phase
Implementation
Successfully Implemented
waste minimization projects
This section discusses factors that are important to the
success of a waste minimization program. Because a
comprehensive WM program affects many functional
groups within a company, the program needs to bring
these different groups together to reduce wastes.
The formality of the program depends upon the size
and complexity of the organization and its waste
problems. The program structure must be flexible
enough to accommodate unforeseen changes. The
developmental activities of a WM program include:
* getting management commitment
• setting WM goals
• staffing the program task force
Getting Management Commitment
The management of a company will support a waste
minimization program if it is convinced that the benefits
of such a program will outweigh the costs. The
potential benefits include economic advantages,
compliance with regulations, reduction in liabilities
associated with the generation of wastes, improved
public image, and reduced environmental impact.
The objectives of a WM program are best conveyed to
a company's employees through a formal policy
statement or management directive. A company's
upper management is responsible for establishing a
formal commitment throughout all divisions of the
organization. The person in charge of the company's
environmental affairs is responsible to advise
management of the Importance of waste minimization
and the need for this formal commitment. An example
of a formal policy statement follows:
CORPORATE ENVIRONMENTAL POLICY
[A major chemical company]..."is committed to continue
excellence, leadership, and stewardship in protecting the
environment. Environmental protection is a primary
management responsibility, as well as the responsibility of
every employee.
In keeping with this policy, our objective as a company is to
reduce waste and achieve minimal adverse impact on the air,
water, and land through excellence in environmental control.
The Environmental Guidelines include the following points:
* Environmental protection is a line responsibility and an
important measure of employee performance. In addi-
tion, every employee Is responsible for environmental
protection in the same manner he or she is for safety.
* Minimizing or eliminating the generation of waste has
been and continues to be a prime consideration in
research, process design, and plant operations; and is
viewed by management like safety, yield, and loss
prevention.
• Reuse and recycling of materials has been and will
continue to be given first consideration prior to
classification and disposal of waste,*
Involve Employees
Although management commitment and direction are
fundamental to the success of a waste minimization
program, commitment throughout an organization is
necessary in order to resolve conflicts and to remove
barriers to the WM program. Employees often cause
the generation of waste, and they can contribute to the
overall success of the program. Bonuses, awards,
plaques, and other forms of recognition are often used
to provide motivation, and to boost employee
cooperation and participation. In some companies,
meeting the waste minimization goals is used as a
measure for evaluating the job performance of
managers and employees.
-------
Cause Champions
Any WM program needs one or more people to
champion the cause. These "cause champions" help
overcome the inertia present when changes to an
existing operation are proposed. They also lead the
WM program, either formally or informally. An
environmental engineer, production manager, or plant
process engineer may be a good candidate for this
role. Regardless of who takes the lead, this cause
champion must be given enough authority to
effectively carry out the program.
Organizing a WM Program:
The Program Task Force
The WM program will affect a number of groups within a
company. For this reason, a program task force should
be assembled. This group should Include members of
any group or department in the company that has a
significant interest in the outcome of the program.
Table 2-4 at the end of this section and Worksheet 3 in
Appendix A lists departments or groups of a typical
manufacturing company that should be Involved in the
program.
The formality or informality of the WM program will
depend on the nature of the company. The program in
a large highly structured company will probably
develop to be quite formal, in contrast to a small
company, or a company in a dynamic industry, where
the organizational structure changes frequently.
Table 2-1 lists the typical responsibilities of a WM
program task force. It will draw on expertise within the
company as required. The scope of the program will
determine whether full-time participation is required by
any of the team members.
Tabl* 2-1. Responsibilities of the WM Program
Task Fore*
• Get commitment and a statement of policy from
management.
* Establish overall WM program goals.
* Establish a waste tracking system.
* Prioritize the waste streams or facility areas for
assessment.
• Select assessment teams.
• Conduct (or supervise) assessments.
* Conduct (or monitor) technical/economic feasibility
analyses of favorable options.
* Select and justify feasible options for Implementation.
• Obtain funding and establish schedule for
implementation.
• Monitor (and/or direct) implementation progress.
• Monitor performance of the option, once it is operating.
In a small company, several people at most will be all
that are required to implement a WM program. Include
the people with responsibility for production, facilities,
maintenance, quality control, and waste treatment and
disposal on the team. It may be that a single person,
such as the plant manager, has all of these
responsibilities at a small facility. However, even at a
small facility, at least two people should be involved to
get a variety of viewpoints and perspectives.
Some larger companies have developed a system in
which assessment teams periodically visit different
facilities within the company. The benefits result
through sharing the ideas and experiences with other
divisions. Similar results can be achieved with periodic
in-house seminars, workshops, or meetings. A large
chemical manufacturer held a corporate-wide
symposium in 1986 dealing specifically with waste
minimization. The company has also developed other
programs to increase company-wide awareness of
waste minimization, including an internally published
newsletter and videotape.
Setting Goals
The first priority of the WM program task force is to
establish goals that are consistent with the policy
adopted by management. Waste minimization goals
can be qualitative, for example, "a significant reduction
of toxic substance emissions into the environment."
However, it is better to establish measurable,
quantifiable goals, since qualitative goals can be
interpreted ambiguously. Quantifiable goals establish
a clear guide as to the degree of sucess expected of
the program. A major chemical company has adopted a
corporate-wide goal of 5% waste reduction per year. In
addition, each facility within the company has set its
own waste minimization goals.
As part of its general policy on hazardous waste, a large
defense contractor has established an ambitious
corporate-wide goal of zero discharge of hazardous
wastes from its facilities by the end of 1988. Each
division within the corporation is given the
responsibility and freedom to develop its own program
(with intermediate goals) to meet this overall goal. This
has resulted in an extensive investigation of
procedures and technologies to accomplish source
reduction, recycling and resource recovery, and onsrte
treatment.
Table 2-2 lists the qualities that goals should possess.
It is Important that the company's overall waste
minimization goals be incorporated into the appropriate
individual departmental goals.
The goals of the program should be reviewed
periodically. As the focus of the WM program becomes
more defined, the goals should be changed to reflect
any changes. Waste minimization assessments are not
intended to be a one-time project. Periodic
reevaluation of goals is recommended due to
changes, for example, in available technology, raw
-------
Table 2-2. Attributes of Effective Goals
ACCEPTABLE to those who will work to achieve them.
FLEXIBLE and adaptable to changing requirements.
MEASURABLE over time.
MOTIVATIONAL
SUITABLE to the overall corporate goals and mission.
UNDERSTANDABLE.
ACHIEVABLE with a practical level of effort.
Source: Pearce and Robinson, Strategic Management
(1985)
material supplies, environmental regulations, and
economic climate.
Overcoming Barriers
As it sets goals for waste minimization and then defines
specific objectives that can be achieved, the program
task force should recognize potential barriers.
Although waste minimization projects can reduce
operating costs and improve environmental
compliance, they can lead to conflicts between
different groups within the company. Table 2-3 lists
examples of jurisdictional conflicts that can arise during
the implementation of a waste minimization project.
In addition to jurisdictional conflicts related to these
objective barriers, there are attitude-related barriers
that can disrupt a WM program. A commonly held
attitude is "If it ain't broke, don't fix it!" This attitude
sterns from the desire to maintain the status quo and
avoid the unknown. It is also based on the fear that a
new WM option may not work as advertised. Without
the commitment to carefully conceive and implement
the option, this attitude can become a self-fulfilling
prophecy. Management must declare that "It is broke!"
Another attitude-related barrier is the feeling that "It
just won't work!" This response Is often given when a
person does not fully understand the nature of the
proposed option and its impact on operations. The
danger here is that promising options may be dropped
before they can be evaluated. One way to avoid this is
to use idea-generating sessions (e.g., brainstorming).
This encourages participants to propose a large
number of options, which are individually evaluated on
their merits.
An often-encountered barrier is the fear that the WM
option will diminish product quality. This is particularly
common in situations where unused feed materials are
recovered from the waste and then recycled back to
the process. The deterioration of product quality can
be a valid concern if unacceptable concentrations of
waste materials build up In the system. The best way to
allay this concern is to set up a small-scale
demonstration in the facility, or to observe the
particular option in operation at another facility.
Tabls 2-3. Examples of Barriers to Waste
Minimization
Production
* A new operating procedure will reduce waste but may also
be a bottleneck that decreases the overall production
rate.
• Production will be stopped while the new process
equipment is installed.
• A new piece of equipment has not been demonstrated in a
similar service. It may not work here.
Facil'nies/Maintenanco
* Adequate space is not available for the installation of new
equipment.
• Adequate utilities are not available for the new
equipment.
* Engineering or construction manpower will not be
available in time to meet the project schedule.
* Extensive maintenance may be required.
Quality Control
• More intensive QC may be needed.
* More rework may be required
Client Relations/Marketing
• Changes in product characteristics may affect customer
acceptance.
Inventory
* A program to reduce inventory (to avoid material
deterioration and reprocessing) may lead to stockouts
during high product demand.
Finance
• There Is not enough money to fund the project
Purchasing
* Existing stocks (or binding cdntracts) will delay the
replacement of a hazardous material with a non-
hazardous substitute.
Environmental
* Accepting another plant's waste as a feedstock may
require a lengthy resolution of regulatory issues.
Waste Treatment
• Use of a new nonhazardous raw material will adversely
impact the existing wastewater treatment facilrty.
Planning and Organization Summary
Table 2-4 provides a summary of the steps involved in
planning and organizing a waste minimization program.
Assessment Worksheets
Appendix A includes a set of worksheets for use in
planning and carrying out a waste minimization
assessment, and implementing the selected options.
Worksheet 1 summarizes the entire assessment
procedure. Worksheets 2 and 3 are used to record the
organization of the WM program task force and the
8
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individual assessment teams, respectively. Worksheet
3 includes a list of functions and departments that
should be considered when organizing the
assessment teams.
Table 2-4. Planning and Organization Activities
Summary
SETTING UP THE PROGRAM
Oat management commitment to:
* Establish waste minimization as a company goal.
* Establish a waste minimization program to meet this
goal,
* Give authority to the program task force to
Implement this program.
Set overall goals for the program. These goals should be:
• ACCEPTABLE to those who will work to achieve
them.
FLEXIBLE to adapt to changing requirements.
MEASURABLE over time.
MOTIVATIONAL
SUITABLE to the overall corporate goals.
UNDERSTANDABLE
ACHIEVABLE with a practical level of effort.
STAFFING THE PROGRAM TASK FORCE
Find a "cause champion", with the following attributes:
* Familiar with the facility, its production processes,
and its waste management operations.
• Familiar with the people.
• Familiar with quality control requirements.
* Good rapport with management.
* Familiar with new production and waste
management technology.
* Familiar with WM principles and techniques, and
environmental regulations.
• Aggressive managerial style.
Get people who know the facility, processes, and
procedures.
Get people from the affected departments or groups.
Production.
Facilities/Maintenance.
Process Engineering.
Quality Control.
Environmental.
Research and Development.
Safety/Health.
Marketing/Client Relations.
Purchasing.
Material Control/Inventory.
Legal.
Finance/Accounting.
Information Systems.
GETTING COMPANY-WIDE COMMITMENT
Incorporate the company's WM goats into departmental
goals.
Solicit employee cooperation and participation.
Devebp incentives and/or awards for managers and
employees.
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Section 3
Assessment Phase
The recognized need to minimize waste
i
Planning and
Organization
ASSESSMENT PHASE
Collect process and facility data
Prioritize and select assessment targets
Select people for assessment teams
Review data and inspect site
Generate options
Screen and select options for further study
±
Feasibility
Analysis Phase
Implementation
Successfully implemented
waste minimization projects
The purpose of the assessment phase is to develop a
comprehensive set of waste minimization options, and
to identify the attractive options that deserve
additional, more detailed analysis, tn order to develop
these WM options, a detailed understanding of the
plant's wastes and operations is required. The
assessment should begin by examining information
about the processes, operations, and waste
management practices at the facility.
Collecting and Compiling Data
The questions that this information gathering effort will
attempt to answer include the following:
• What are the waste streams generated from the
plant? And how much?
• Which processes or operations do these waste
streams come from?
* Which wastes are classified as hazardous and which
are not? What makes them hazardous?
• What are the input materials used that generate the
waste streams of a particular process or plant area?
• How much of a particular input material enters each
waste stream?
• How much of a raw material can be accounted for
through fugitive tosses?
• How efficient is the process?
* Are unnecessary wastes generated by mixing
otherwise recyclable hazardous wastes with other
process wastes?
• What types of housekeeping practices are used to
limit the quantity of wastes generated?
* What types of process controls are used to improve
process efficiency?
Table 3-1 lists information that can be useful in
conducting the assessment. Reviewing this
information will provide important background for
understanding the plant's production and
maintenance processes and will allow priorities to be
determined. Worksheets 4 through 10 in Appendix A
can be used to record the information about site
characteristics, personnel, processes, input materials,
products, and waste streams. Worksheets S2 through
S6 in Appendix B are designed to record the same
information, but in a more simplified approach.
Waste Stream Records
One of the first tasks of a waste minimization
assessment is to identify and characterize the facility
waste streams. Information about waste streams can
come from a variety of sources. Some information on
waste quantities is readily available from the completed
hazardous waste manifests, which include the
description and quantity of hazardous waste shipped
to a TSDF. The total amount of hazardous waste
shipped during a one-year period, for example, is a
convenient means of measuring waste generation and
waste reduction efforts. However, manifests often lack
such information as chemical analysis of the waste,
specific source of the waste, and the time period
during which the waste was generated. Also,
manifests do not cover wastewater effluents, air
emissions, or nonhazardous solid wastes.
Other sources of information on waste str earns include
biennial reports and NPOES (National Pollutant
-------
Table 3-1. Facility Information for WM
Assessments
Design Information
* Process flow diagrams
* Material and heat balances (both design balances and
actual balances) for
production processes
pollution control processes
Operating manuals and process descriptions
Equipment lists
Equipment specifications and data sheets
Piping and instrument diagrams
Plot and elevation plans
Equipment layouts and work flow diagrams
Environmental Information
Hazardous waste manifests
Emission inventories
Biennial hazardous waste reports
Waste analyses
Environmental audit reports
Permits and/or permit applications
Raw Material/Production Information
Product composition and batch sheets
Material application diagrams
Material safety data sheets
Product and raw material inventory records
Operator data logs
Operating procedures
Production schedules
Economic Information
• Waste treatment and disposal costs
• Product, utility, and raw material costs
• Operating and maintenance costs
• Departmental cost accounting reports
Other Information
» Company environmental policy statements
* Standard procedures
« Organization charts
Discharge Elimination System) monitoring reports.
These NPDES monitoring reports will include the
volume and constituents of wastewaters that are
discharged. Additionally, toxic substance release
inventories prepared under the "right to know"
provisions of SARA Title III, Section 313 (Superfund
Amendment and Rtauthorization Act) may
provldevaluable information on emissions into all
environmental media (land, water, and air).
Analytical test data available from previous waste
evaluations and routine sampling programs can be
helpful if the focus of the assessment is a particular
chemical within a waste stream.
Flow Diagrams and Material Balances
Flow diagrams provide the basic means for identifying
and organizing information that is useful for the
assessment. Flow diagrams should be prepared to
identify important process steps and to identify
sources where wastes are generated. Flow diagrams
are also the foundation upon which material balances
are built.
Material balances are important for many WM projects,
since they allow for quantifying losses or emissions
that were previously unaccounted for Also, material
balances assist in developing the following
information:
* baseline for tracking progress of the WM efforts
* data to estimate the size and cost of additional
equipment and other modifications
* data to evaluate economic performance
In its simplest form, the material balance is represented
by the mass conservation principle:
Mass in = Mass out + Mass accumulated
The material balance should be made individually for all
components that enter and leave the process. When
chemical reactions take place in a system, there is an
advantage to doing "elemental balances" for specific
chemical elements in a system.
Material balances can assist in determining
concentrations of waste constituents where analytical
test data is limited. They are particularly useful where
there are points in the production process where it is
difficult (due to inaccessibility) or uneconomical to
collect analytical data. A material balance can help
determine if fugitive losses are occurring. For
example, the evaporation of solvent from a parts
cleaning tank can be estimated as the difference
between solvent put into the tank and solvent
removed from the tank.
To characterize waste streams by material balance can
require considerable effort. However, by doing so, a
more complete picture of the waste situation results.
This helps to establish the focus of the WM activities
and provides a baseline for measuring performance.
Appendix D lists potential sources of waste from
specific processes and operations.
Sources of Material Balance Information
By definition, the material balance includes both
materials entering and leaving a process. Table 3-2
lists potential sources of material balance information.
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Table 3-2. Sources of Material Balance
Information
* Samples, analyses, and flow measurements of feed
stocks, products, and waste streams
Raw material purchase records
Material inventories
Emission inventories
Equipment cleaning and validation procedures
Batch make-up records
Product specifications
Design material balances
Production records
Operating logs
Standard operating procedures and operating manuals
Waste manifests
Material balances are easier, more meaningful, and
more accurate when they are done for individual units,
operations, or processes. For this reason, It is
important to define the material balance envelope
properly. The envelope should be drawn around the
specifc area of concern, rather than a larger group of
areas or the entire facility. An overall material balance
for a facility can be constructed from individual unit
material balances. This effort will highlight
interrelationships between units and will help to point
out areas for waste minimization by way of cooperation
between different operating units or departments.
Pitfalls In Preparing Material Balances
There are several factors that must be considered
when preparing material balances in order to avoid
errors that could significantly overstate or understate
waste streams. The precision of analytical data and
flow measurements may not allow an accurate measure
of the stream. In particular, in processes with very large
inlet and outlet streams, the absolute error in
measurement of these quantities may be greater in
magnitude than the actual waste stream itself. In this
case, a reliable estimate of the waste stream cannot be
obtained by subtracting the quantity of hazardous
material in the product from that in the feed.
The time span is important when constructing a
material balance. Material balances constructed over a
shorter time span require more accurate and more
frequent stream monitoring in order to close the
balance. Material balances performed over the
duration of a complete production run are typically the
easiest to construct and are reasonably accurate. Time
duration also affects the use of raw material purchasing
records and onsite inventories for calculating input
material quantities. The quantities of materials
purchased during a specific time period may not
necessarily equal the quantity of materials used in
production during the same time period, since
purchased materials can accumulate in warehouses or
stockyards.
Developing material balances around complex
processes can be a complicated undertaking,
especially if recycle streams are present. Such tasks
are usually performed by chemical engineers, often
with the assistance of computerized process
simulators.
Material balances will often be needed to comply with
Section 313 of SARA (Superfund Amendment and
Reauthorization Act of 1986) in establishing emission
inventories for specific toxic chemicals. EPA's Office
of Toxic Substances (OTS) has prepared a guidance
manual entitled Estimating Releases and Waste
Treatment Efficiencies for the Toxic Chemicals
Inventory Form (EPA 560/4-88-02). The OTS manual
contains additional information for developing material
balances for the listed toxic chemicals. The information
presented in this manual applies to a WM assessment
when the material balances are for individual
operations being assessed rather than an overall
facility, when the variations in flow over time is
accounted for, and when the data is used from
separate streams rather than from aggregate streams.
Tracking Wastes
Measuring waste mass flows and compositions Is
something that should be done periodically. By
tracking wastes, seasonal variations in waste flows or
single large waste streams can be distinguished from
continual, constant flows. Indeed, changes in waste
generation cannot be meaningfully measured unless
the information is collected both before and after a
waste minimization option is implemented.
Fortunately, it is easier to do material balances the
second time, and gets even easier as more are done
because of the "learning curve" effect. In some larger
companies, computerized database systems have
been used to track wastes. Worksheets 9 and 10 in
Appendix A (and Worksheet S6 in Appendix B)
provide a means of recording pertinent waste stream
characteristics.
Prioritizing Waste Streams and/or
Operations to Assess
Ideally, all waste streams and plant operations should
be assessed. However, prioritizing the waste streams
and/or operations to assess is necessary when
available funds and/or personnel are limited. The WM
assessments should concentrate on the most
important waste problems first, and then move on to
the lower priority problems as the time, personnel, and
budget permit.
Setting the priorities of waste streams or facility areas to
assess requires a great deal of care and attention,
since this step focuses the remainder of the
-------
assessment activity. Table 3-3 lists important criteria to
consider when setting these priorities.
Table 3-3. Typical Considerations for
Prioritizing Waste Streams to Assess
• Compliance with currant and future regulations.
• Costs of waste management (treatment and disposal).
• Potential environmental and safety liability.
• Quantity of waste.
• Hazardous properties of the waste (including toxicity,
flammability, corrosivity, and reactivity).
* Other safety hazards to employees.
« Potential for (or ease of) minimization.
• Potential for removing bottlenecks in production or waste
treatment.
• Potential recovery of valuable by-products.
• Available budget for the waste minimization assessment
program and projects.
Worksheet 10 in Appendix A (Worksheet S6 in
Appendix B) provides a means for evaluating waste
stream priorities for the remainder of the assessment.
Small businesses, or large businesses with only a few
waste generating operations should assess their entire
facility. It is also beneficial to look at an entire facility
when there are a large number of similar operations.
Similarly, the implementation of good operating
practices that involve procedural or organizational
measures, such as soliciting employee suggestions,
awareness-building programs, better inventory and
maintenance procedures, and internal cost accounting
changes, should be Implemented on a facility-wide
basis. Since many of these options do not require
jarge capital expenditures, they should be
implemented as soon as practical.
Selecting the Assessment Teams
The WM program task force is concerned with the
whole plant. However, the focus of each of the
assessment teams is more specific, concentrating on a
particular waste stream or a particular area of the plant.
Each team should include people with direct
responsibility and knowledge of the particular waste
stream or area of the plant. Table 3-4 presents four
examples of teams for plants of various sizes in
different industries.
In addition to the internal staff, consider using outside
people, especially in the assessment and
implementation phases. They may be trade
association representatives, consultants, or experts
from a different facility of the same company. In large
multi-division companies, a centralized staff of experts
at the corporate headquarters may be available. One
or more "outsiders" can bring in new ideas and provide
an objective viewpoint. An outsider also is more likely
to counteract bias brought about by "inbreeding", or
Tabl* 3-4, Examples of WM Assessment Teams
1. Metal finishing department in a large defense contractor.
» Metal finishing department manager
» Process engineer responsible for metal finishing
processes
• Facilities engineer responsible for metal finishing
department*
* Wastewater treatment department supervisor
* Staff environmental engineer
2. Small pesticide formulator.
« Production manager*
• Environmental manager
* Maintenance supervisor
* Pesticide industry consultant
3. Cyanide plating operation at a military facility.
• Internal assessment team
- Environmental coordinator*
- Environmental engineer
- Electroplating facility engineering supervisor
- Metallurgist
- Materials science group chemist
* Outside assessment team
- Chemical engineers (2)
- Environmental engineering consultant
- Plating chemistry consultant
4. Large offset printing facility.
* Internal assessment team
- Plant vice president
- Film processing supervisor
- Pressroom supervisor
* Outside assessment team
- Chemical engineers (2)*
- Environmental scientist
- Printing industry technical consultant
* - Team leader
the "sacred cow" syndrome, such as when an old
process area, rich in history, undergoes an
assessment.
Outside consultants can bring a wide variety of
experience and expertise to a waste minimization
assessment. Consultants may be especially useful to
smaller companies who may not have in-house
expertise in the relevant waste minimization
techniques and technologies.
Production operators and line employees must not be
overlooked as a source of WM suggestions, since they
possess firsthand knowledge and experience with the
process. Their assistance is especially useful in
assessing operational or procedural changes, or in
equipment modifications that affect the way they do
their work.
"Quality circles" have been instituted by many
companies, particularly in manufacturing industries, to
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improve product quality and production efficiency.
These quality circles consist of meetings of workers
and supervisors, where improvements are proposed
and evaluated. Quality circles are beneficial in that they
involve the production people who are closely
associated with the operations, and foster participation
and commitment to improvement. Several large
companies that have quality circles have used them as
a means of soliciting successful suggestions for waste
minimization.
Site Inspection
With a specific area or waste stream selected, and with
the assessment team in place, the assessment
continues with a visit to the site. In the case where the
entire assessment team is employed at the plant being
assessed, the team should have become very familiar
with the specific area in the process of collecting the
operating and design data. The members of the
assessment team should familiarize themselves with
the site as much as possible. Although the collected
information is critical to gaining an understanding of the
processes involved, seeing the site is important in
order to witness the actual operation. For example, in
many instances, a process unit is operated differently
from the method originally described in the operating
manual. Modifications may have been made to the
equipment that were not recorded in the flow diagrams
or equipment lists.
When people from outside of the plant participate in
the assessment, it is recommended that a formal site
inspection take place. Even when the team is made up
entirely of plant employees, a site inspection by all
team members is helpful after the site information has
been collected and reviewed. The inspection helps to
resolve questions or conflicting data uncovered during
the review. The site inspection also provides
additional information to supplement that obtained
earlier.
When the assessment team includes members
employed outside of the plant, the team should
prepare a list of needed information and an inspection
agenda. The list can be presented in the form of a
checklist detailing objectives, questions and issues to
be resolved, and/or further information requirements.
The agenda and information list are given to the
appropriate plant personnel in the areas to be
assessed early enough before the visit to allow them to
assemble the information in advance. Of course, it may
be that the assessment team members themselves are
in the best position to collect and compile much of the
data. By carefully thinking out the agenda and needs
list, important points are less likely to be overlooked
during the inspection. Table 3-5 presents useful
guidelines for the site inspection.
Tabl* 3*5. Guidelines for the Slta Inspection
* Prepare an agenda in advance that covers all points that
still require clarification. Provide staff contacts in the
area being assessed with the agenda several days
before the inspection.
* Schedule the inspection to coincide with the particular
operation that is of interest (e.g., make-up chemical
addition, bath sampling, bath dumping, start-up,
shutdown, etc.).
* Monitor the operation at different times during the shift,
and if needed, during all three shifts, especially when
waste generation is highly dependent on human
involvement (e.g., in painting or parts cleaning
operations).
* Interview the operators, shift supervisors, and foremen in
the assessed area. Do not hesitate to question more
than one person if an answer is not forthcoming. Assess
the operators' and their supervisors' awareness of the
waste generation aspects of the operation. Note their
familiarity (or lack thereof) with the impacts their
operation may have on other operations.
• Photograph the area of interest, if warranted.
Photographs are valuable in the absence of plant layout
drawings. Many details can be captured in photographs
that otherwise could be forgotten or inaccurately recalled
at a later date.
* Observe the "housekeeping" aspects of the operation.
Check for signs of spills or leaks. Visit the maintenance
shop and ask about any problems in keeping the
equipment leak-free. Assess the overall cleanliness of
the site. Pay attention to odors and fumes.
* Assess the organizational structure and level of
coordination of environmental activities between various
departments.
• Assess administrative controls, such as cost accounting
procedures, material purchasing procedures, and waste
collection procedures.
In performing the site inspection the assessment team
should follow the process from the point where raw
materials enter the area to the point where the
products and the wastes leave the area. The team
should identify the suspected sources of waste. This
may include the production process; maintenance
operations; storage areas for raw materials, finished
product, and work-in-process. Recognize that the
plant's waste treatment area itself may also offer
opportunities to minimize waste. This inspection often
results in forming preliminary conclusions about the
causes of waste generation. Full confirmation of these
conclusions may require additional data collection,
analysis, and/or site visits.
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Generating WM Options
Once the origins and causes of waste generation are
understood, the assessment process enters the
creative phase. The objective of this step is to
generate a comprehensive set of WM options for
further consideration. Following the collection of data
and site inspections, the members of the team will
have begun to identify possible ways to minimize
waste in the assessed area. Identifying potential
options relies both on the expertise and creativity of
the team members. Much of the requisite knowledge
may come from their education and on-the-job
experience, however, the use of technical literature,
contacts, and other sources is always helpful. Some
sources of background information for waste
minimization techniques are listed in Table 3-6.
Tabl* 3-6. Sources of Background Information
on WM Options
Trade associations
As part of their overall function to assist companies
within their industry, trade associations generally
provide assistance and information about environmental
regulations and various available techniques for
complying with these regulations. The information
provided is especially valuable since it Is industry-
specific.
Plant engineers and operators
The employees that are intimately familiar with a facility's
operations are often the best source of suggestbns for
potential WM options.
Published literature
Technical magazines, trade journals, government
reports, and research briefs often contain information
that can be used as waste minimization options.
State and local environmental agencies
A number of states and local agendas have, or are
developing, programs that include technical assistance,
information on industry-specific waste minimization
techniques, and compiled bibliographies. Appendix E
provides a list of addresses for state and federal
programs for WM assistance.
Equipment vendors
Meetings with equipment vendors, as well as vendor
literature, are particularly useful in Identifying potential
equipment-oriented options. Vendors are eager to assist
companies in implementing projects. Remember, though,
that the vendor's job is to sell equipment
Consultants
Consultants can provide information about WM
techniques. Section 2 discusses the use of consultants
in WM programs. A consultant with waste minimization
experience in your particular Industry is most desirable.
Waste Minimization Options
The process for identifying options should follow a
hierarchy in which source reduction options are
explored first, followed by recycling options. This
hierarchy of effort stems from the environmental
desirability of source reduction as the preferred means
of minimizing waste. Treatment options should be
considered only after acceptable waste minimization
techniques have been identified.
Recycling techniques allow hazardous materials to be
put to a beneficial use. Source reduction techniques
avoid the generation of hazardous wastes, thereby
eliminating the problems associated with handling
these wastes. Recycling techniques may be
performed onsite or at an offsite facility designed to
recycle the waste.
Source reduction techniques are characterized as
good operating practices, technology changes,
material changes, or product changes. Recycling
techniques are characterized as use/reuse techniques
and resource recovery techniques. • These techniques
are described below:
Source Reduction: Good Operating
Practices
Good operating practices are procedural,
administrative, or institutional measures that a company
can use to minimize waste. Good operating practices
apply to the human aspect of manufacturing
operations. Many of these measures are used in
industry largely as efficiency improvements and good
management practices. Good operating practices can
often be implemented with little cost and, therefore,
have a high return on investment. These practices can
be implemented in all areas of a plant, including
production, maintenance operations, and in raw
material and product storage. Good operating
practices include the following:
Waste minimization programs
Management and personnel practices
Material handling and inventory practices
Loss prevention
Waste segregation
Cost accounting practices
Production scheduling
Management and personnel practices include
employee training, incentives and bonuses, and other
programs that encourage employees to
conscientiously strive to reduce waste. Material
handling and inventory practices include programs to
reduce loss of input materials due to mishandling,
expired shelf life of time-sensitive materials, and
proper storage conditions. Loss prevention minimizes
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wastes by avoiding leaks from equipment and spills.
Waste segregation practices reduce the volume of
hazardous wastes by preventing the mixing of
hazardous and nonhazardous wastes. Cost
accounting practices include programs to allocate
waste treatment and disposal costs directly to the
departments or groups that generate waste, rather
than charging these costs to general company
overhead accounts. In doing so, the departments or
groups that generate the waste become more aware of
the effects of their treatment and disposal practices,
and have a financial incentive to minimize their waste.
By judicious scheduling of batch production runs, the
frequency of equipment cleaning and the resulting
waste can be reduced.
Example: Good Operating Practice®
A large consumer product company in California
adopted a corporate policy to minimize the
generation of hazardous waste. In order to
implement the policy, the company mobilized
quality circles made up of employees representing
areas within the plant that generated hazardous
wastes. The company experienced a 75%
reduction in the amount of wastes generated by
instituting proper maintenance procedures
suggested by the quality circle teams. Since the
team members were also line supervisors and
operators, they made sure the procedures were
followed.
Source Reduction: Technology Changes
Technology changes are oriented toward process and
equipment modifications to reduce waste, primarily in a
production setting. Technology changes can range
from minor changes that can be Implemented in a
matter of days at low cost, to the replacement of
processes involving large capital costs. These
changes include the following:
* Changes in the production process
• Equipment, layout, or piping changes
• Use of automation
• Changes in process operating conditions, such as
- Flow rates
- Temperatures
- Pressures
- Residence times
Example: Technology Changes
A manufacturer of fabricated metal products
cleaned nickel and titanium wire in an alkaline
chemical bath prior to using the wire in their product.
In 1986, the company began to experiment with a
mechanical abrasive system. The wire was passed
through the system which uses silk and carbide
pads and pressure to brighten the metal. The
system worked, but required passing the wire
through the unit twice for complete cleaning. In
1987. The company bought a second abrasive unit
and installed it in series with the first unit. This
system allowed the company to completely
eliminate the need for the chemical cleaning bath.
Source Reduction: Input Material Changes
Input material changes accomplish waste minimization
by reducing or eliminating the hazardous materials that
enter the production process. Also, changes in input
materials can be made to avoid the generation of
hazardous wastes within the production processes.
Input material changes include:
* Material purification
• Material substitution
Example: Input Material Changes
An electronic manufacturing facility of a large
diversified corporation originally cleaned printed
ciruit boards with solvents. The company found that
by switching from a solvent-based cleaning system
to an aqueous-based system that the same
operating conditions and workloads could be
maintained. The aqueous-based system was found
to clean six times more effectively. This resulted in a
lower product reject rate, and eliminated a
hazardous waste.
Source Reduction: Product Changes
Product changes are performed by the manufacturer
of a product with the intent of reducing waste resulting
from a product's use. Product changes include:
• Product substitution
• Product conservation
• Changes in product composition
Example: Product changes
In the paint manufacturing industry, water-based
coatings are finding increasing applications where
solvent-based paints were used before. These
products do not contain toxic or flammable solvents
that make solvent-based paints hazardous when
they are disposed of. Also, cleaning the applicators
with solvent is not necessary. The use of water-
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based paints Instead of solvent-based paints also
greatly reduces volatile organic compound
emisstons to the atmosphere.
Recycling: Use and Reuse
Recycling via use and/or reuse involves the return of a
.waste material either to the originating process as a
substitute for an input material, or to another process
as an input material.
Example: Reuse
A printer of newpaper advertising in California
purchased an ink recycling unit to produce black
newspaper ink from its various waste inks. The unit
blends the different colors of waste ink together
with fresh black ink and black toner to create the
black ink. This ink is then filtered to remove flakes of
dried ink. This ink is used in place of fresh black ink,
and eliminates the need for the company to ship
waste ink off site for disposal. The price of the
recycling unit was paid off in 18 months based only
on the sayings in fresh black ink purchases. The
payback improved to 9 months when the costs for
disposing of ink as a hazardous waste are included.
Recycling: Reclamation
Reclamation Is the recovery of a valuable material from
a hazardous waste. Reclamation techniques differ
from use and reuse techniques in that the recovered
material is not used in the facility, rather it is sold to
another company.
Example: Reclamation
A photoprocessing company uses an electrolytic
deposition cell to recover silver out of the rinsewater
from film processing equipment. The silver is then
sold to a small recyder. By removing the silver from
this wastewater, the wastewater can be discharged
to the sewer without additional pretreatment by the
company. This unit pays for itself in less than two
years with the value of silver recovered.
The company also collects used film and sells it to
the same recyder. The recyder burns the film and
collects the silver from the the residual ash. By
removing the silver from the ash, the ash becomes
nonhazardous.
Appendix E lists many WM techniques and concepts
applicable to common waste-generating operations
(coating, equipment cleaning, parts cleaning, and
materials handling). Additionally, a list of good
operating practices is provided.
Methods of Generating Options
The process by which waste minimization options are
identified should occur in an environment that
encourages creativity and independent thinking by the
members of the assessment team. While the individual
team members will suggest many potential options on
their own, the process can be enhanced by using
some of the common group decision techniques.
These techniques allow the assessment team to
identify options that the individual members might not
have come up with on their own. Brainstorming
sessions with the team members are an effective way
of developing WM options. Most management or
organizational behavior textbooks describe group
decision techniques, such as brainstorming or the
nominal group technique.
Worksheet 11 in Appendix A is a form for listing
options that are proposed during an option generation
session. Worksheet 12 in Appendix A is used to
briefly describe and document the options that are
proposed. Worksheets S7 and 88 in Appendix B
perform the same function in the simplified set of
worksheets.
Screening and Selecting Options for Further
Study
Many waste minimization options will be identified in a
successful assessment. At this point, it is necessary to
identify those options that offer real potential to
minimize waste and reduce costs. Since detailed
evaluation of technical and economic feasibility is
usually costly, the proposed options should be
screened to identify those that deserve further
evaluation. The screening procedure serves to
eliminate suggested options that appear marginal,
impractical, or inferior without a detailed and more
costly feasibility study.
The screening procedures can range from an informal
review and a decision made by the program manager or
a vote of the team members, to quantitative decision-
making tools. The informal evaluation is an
unstructured procedure by which the assessment
team or WM program task force selects the options that
appear to be the best. This method is especially useful
in small facilities, with small management groups, or in
situations where only a few options have been
generated. This method consists of a discussion and
examination of each option.
The weighted sum method is a means of quantifying
the important factors that affect waste management at a
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particular facility, and how each option will perform with
respect to these factors. This method is
recommended when there are a large number of
options to consider. Appendix Q presents the
weighted sum method in greater detail, along with an
example. Worksheet 13 in Appendix A is designed to
screen and rank options using this method.
The assessment procedure is flexible enough to allow
common group decision-making techniques to be
used here. For example, many large corporations
currently use decision-making systems that can be
used to screen and rank WM options.
No matter what method is used, the screening
procedure should consider the following questions.
* What is the main benefit gained by implementing
this option? (e.g., economics, compliance, liability,
workplace safety, etc.)
• Does the necessary technology exist to develop
the option?
• How much does ft cost? Is it cost effective?
• Can the option be implemented within a reasonable
amount of time without disrupting production?
• Does the option have a good "track record"? If not,
is there convincing evidence that the option will
work as required?
* Does the option have a good chance of success?
(A successfully initiated WM program will gain wider
acceptance as the program progresses.)
• What other benefits will occur?
The results of the screening activity are used to
promote the successful options for technical and
economic feasibility analyses. The number of options
chosen for the feasibility analyses depends on the
time, budget, and resources available for such a study.
Some options (such as procedural changes) may
involve no capital costs and can be implemented
quickly with little or no further evaluation. The
screening procedure should account for ease of
implementation of an option. If such an option is clearly
desirable and Indicates a potential cost savings, ft
should be promoted for further study or outright
implementation.
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Section 4
Feasibility Analysis
The recognized need to minimize waste
Planning and
Organization
Assessment
Phase
FEASIBILITY ANALYSIS PHASE
• Technical evaluation
• Economic evaluation
• Select options for implementation
Implementation
Successfully implemented
waste minimization projects
The final product of the assessment phase is a list of
WM options for the assessed area. The assessment
will have screened out the impractical or unattractive
options. The next step is to determine if the remaining
options are technically and economically feasible.
Technical Evaluation
The technical evaluation determines whether a
proposed WM option will work in a specific application.
The assessment team should use a "fast-track"
approach in evaluating procedural changes that do not
involve a significant capital expenditure. Process
testing of materials can be done relatively quickly, if the
options do not involve major equipment installation or
modifications.
For equipment-related options or process changes,
visits to see existing installations can be arranged
through equipment vendors and industry contacts.
The operator's comments are especially important and
should be compared with the vendor's claims. Bench-
scale or pilot-scale demonstration is often necessary.
Often it is possible to obtain scale-up data using a
rental test unit for bench-scale or pilot-scale
experiments. Some vendors will install equipment on a
trial basis, with acceptance and payment after a
prescribed time, if the user is satisfied.
The technical evaluation of an option also must
consider facility constraints and product requirements,
such as those described in Table 4-1. Although an
inability to meet these constraints may not present
insurmountable problems, correcting them will likely
add to the capital and/or operating costs.
Table 4-1. Typical Technical Evaluation Criteria
• Is the system safe for workers?
• * Will product quality be maintained?
• Is space available?
• Is the new equipment, materials, or procedures
compatible with production operating procedures, work
flow, and production rates?
• Is additional labor required?
• Are utilitities available? Or must they be installed,
thereby raising capital costs?
• How long will production be stopped in order to install the
system?
• Is special expertise required to operate or maintain the
new system?
• Does the vendor provide acceptable service?
• Does the system create other environmental problems?
All affected groups in the facility should contribute to
and review the results of the technical evaluation. Prior
consultation and review with the affected groups (e.g.,
production, maintenance, purchasing) is needed to
ensure the viability and acceptance of an option. If the
option calls for a change in production methods or
input materials, the project's effects on the quality of
the final product must be determined. If after the
technical evaluation, the project appears infeasible or
impractical, it should be dropped. Worksheet 14 in
Appendix A is a checklist of important items to consider
when evaluating the technical feasibility of a WM
option.
Economic Evaluation
The economic evaluation is carried out using standard
measures of profitability, such as payback period,
return on investment, and net present value. Each
organization has its own economic criteria for selecting
projects for implementation. In performing the
economic evaluation, various costs and savings must
be considered. As in any projects, the cost elements
of a WM project can be broken down into capital costs
and operating costs. The economic analysis described
in this section and in the associated worksheets
represents a preliminary, rather than detailed, analysis.
For smaller facilities with only a few processes, the
entire WM assessment procedure will tend to be much
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Table 4-2. Capital Investment for a Typical
Large WM Project
Direct Capital Costs
Site Development
Demolition and alteration work
Site clearing and grading
Walkways, roads, and fencing
Process Equipment
All equipment listed on flow sheets
Spare parts
Taxes, freight, insurance, and duties
Materials
Piping and ducting
Insulation and painting
Electrical
Instrumentation and controls
Buildings and structures
Connections to Existing Utilities and Services (water,
HVAC, power, steam, refrigeration, fuels, plant air
and Inert gas, lighting, and fire control}
New Utility and Service Facilities (same items as above)
Other Non-Process Equipment
Construction/Installation
Construction/Installation labor salaries and burden
Supervision, accounting, timekeeping, purchasing,
safety, and expediting
Temporary facilities
Construction tools and equipment
Taxes and insurance
Building permits, field tests, licenses
Indirect Capital Costs
In-house engineering, procurement, and other home
office costs
Outside engineering, design, and consulting Services
Permitting costs
Contractors' fees
Start-up costs
Training costs
Contingency
Interest accrued during construction
TOTAL FIXED CAPITAL COSTS
Working Capital
Raw materials inventory
Finished product inventory
Materials and supplies
TOTAL WORKING CAPITAL
TOTAL CAPITAL INVESTMENT
Source: Adapted from Perry, Chemical Engineer's
Handbook (1985); and Peters and Timmerhaus, Plant Design
and Economics for Chemical Engineers (1980).
less formal. In this situation, several obvious WM
options, such as installation of flow controls and good
operating practices may be implemented with little or
no economic evaluation. In these instances, no
complicated analyses are necessary to demonstrate
the advantages of adopting the selected WM options.
A proper perspective must be maintained between the
magnitude of savings that a potential option may offer,
and the amount of manpower required to do the
technical and economic feasibility analyses.
Capital Costa
Table 4-2 is a comprehensive list of capital cost Hems
associated with a large plant upgrading project. These
costs include not only the fixed capital costs for
designing, purchasing, and installing equipment, but
also costs for working capital, permitting, training, start-
up, and financing charges.
With the increasing level of environmental regulations,
initial permitting costs are becoming a significant
portion of capital costs for many recycling options (as
well as treatment, storage, and disposal options).
Many source reduction techniques have the
advantage of not requiring environmental permitting in
order to be implemented.
Operating Costa and Savings
The basic economic goal of any waste minimization
project is to reduce (or eliminate) waste disposal costs
and to reduce input material costs. However, a variety
of other operating costs (and savings) should also be
considered. In making the economic evaluation, it Is
convenient to use incremental operating costs in
comparing the existing system with the new system
that incorporates the waste minimization option.
("Incremental operating costs" represent the
difference between the estimated operating costs
associated with the WM option, and the actual
operating costs of the existing system, without the
option.) Table 4-3 describes incremental operating
costs and savings and incremental revenues typically
associated with waste minimization projects.
Reducing or avoiding present and future operating
costs associated with waste treatment, storage, and
disposal are major elements of the WM project
economic evaluation. Companies have tended to
ignore these costs in the past because land disposal
was relatively inexpensive. However, recent regulatory
requirements imposed on generators and waste
management facilities have caused the costs of waste
management to increase to the point where ft is
becoming a significant factor in a company's overall
cost structure. Table 4-4 presents typical external
costs for offsite waste treatment and disposal. In
addition to these external costs, there are significant
internal costs, including the labor to store and ship out
wastes, liability insurance costs, and onsite treatment
costs.
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Table 4-3. Operating Costs and Savings
Associated with WM Projects
Reduced waste management costs.
This includes reductions in costs for:
Offsite treatment, storage, and disposal fees
State fees and taxes on hazardous waste generators
Transportation costs
Onsite treatment, storage, and handling costs
Permitting, reporting, and recordkeeping costs
Input material cost savings.
An option that reduces waste usually decreases the
demand for input materials.
Insurance and liability savings.
A WM option may be significant enough to reduce a
company's insurance payments. It may also lower a
company's potential liability associated with remedial
clean-up of TSDFs and workplace safety. (The
magnitude of liability savings is difficult to determine).
Changes in costs associated with quality.
A WM option may have a positive or negative effect on
product quality. This could result in higher (or lower)
costs for rework, scrap, or quality control functions.
Changes in utilities costs.
Utilities costs may increase or decrease. This includes
steam, electricity, process and cooling water, plant air,
refrigeration, or inert gas.
Changes in operating and maintenance labor, burden, and
benefits.
An option may either Increase or decrease labor
requirements. This may be reflected in changes in
overtime hours or in changes in the number of
employees. When direct labor costs change, then the
burden and benefit costs will also change, in large
projects, supervision costs will also change.
Changes in operating and maintenance supplies,
An option may result increase or decrease the use of
O&M supplies.
Changes in overhead costs.
Large WM projects may affect a facility's overhead
costs.
Changes in revenues from increased (or decreased)
production.
An option may result in an increase in the productivity of
a unit. This will result in a change in revenues. (Note that
operating costs may also change accordingly.)
Increased revenues from by-products,
A WM option may produce a by-product that can be sold
to a recycler or sold to another company as a raw
material. This will increase the company's revenues.
Table 4-4. Typical Costs of Offsite Industrial
Waste Management*
Disposal
Drummed hazardous waste**
Solids $75 to $110 per drum
Liquids $65 to $120 per drum
Bulk waste
Solids $120 per cubic yard
Liquids $0.60 to $2.30 per gallon
Lab packs $110 per drum
Analysis (at disposal site)
Transportation
$200 to $300
$65 to $85 per hour @ 45 miles
per hour (round trip)
* - Does not include internal costs, such as taxes and fees,
and labor for manifest preparation, storage, handling, and
recordkeeping.
**- Based on 55 gallon drums. These prices are for larger
quantities of drummed wastes. Disposal of a small
number of drums can be up to four times higher per
drum.
For the purpose of evaluating a project to reduce
waste quantities, some types of costs are larger and
more easily quantified. These include:
disposal fees
transportation costs
predisposal treatment costs
raw materials costs
operating and maintenance costs.
ft is suggested that savings in these costs be taken
Into consideration first, because they have a greater
effect on project economics and involve less effort to
estimate reliably. The remaining elements are usually
secondary in their direct impact and should be
included on an as-needed basis in fine-tuning the
analysis.
Profitability Analysis
A project's profitability is measured using the estimated
net cash flows (cash incomes minus cash outlays) for
each year of the project's life. A profitability analysis
example in Appendix H includes two cash flow tables
(Figure H-3 and H-4).
if the project has no significant capital costs, the
project's profitability can be judged by whether an
operating cost savings occurs or not. If such a project
reduces overall operating costs, it should be
implemented as soon as practical.
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For projects with significant capital costs, a more
detailed profitability analysis is necessary. The three
standard profitability measures are:
» Payback period
* Internal rate of return (IRR)
• Net present value
The payback period for a project is the amount of time ft
takes to recover the Initial cash outlay on the project.
The formula for calculating the payback period on a
pretax basis is the following:
Payback period
(in years)
Capital investment
Annual operating cost savings
For example, suppose a waste generator installs a
piece of equipment at a total cost of $120,000. If the
piece of equipment is expected to save $48,000 per
year, then the payback period is 2.5 years.
Payback periods are typically measured in years.
However, a particularly attractive project may have a
payback period measured in months. Payback periods
in the range of three to four years are usually
considered acceptable for low-risk investments. This
method is recommended for quick assessments of
profitability, if large capital expenditures are involved, it
is usually followed by more detailed analysis.
The internal rate of return (IRR) and the net present
value (NPV) are both discounted cash flow techniques
for determining profitability. Many companies use
these methods for ranking capital projects that are
competing for funds. Capital funding for a project may
well hinge on the ability of the project to generate
positive cash flows beyond the payback period to
realize acceptable return on investment. Both the
NPV and IRR recognize the time value of money by
discounting the projected future net cash flows to the
present. For investments with a low level of risk, an
aftertax IRR of 12 to 15 percent is typically acceptable.
Most of the popular spreadsheet programs for
personal computers will automatically calculate IRR and
NPV for a series of cash flows. Refer to any financial
management, cost accounting, or engineering
economics text for more information on determining
the IRR or NPV. Appendix H presents a profitability
analysis example for a WM project using IRR and NPV.
Adjustments for Risks and Liability
As mentioned earlier, waste minimization projects may
reduce the magnitude of environmental and safety
risks for a company. Although these risks can be
identified, it is difficult to predict if problems occur, the
nature of the problems, and their resulting magnitude.
One way of accounting for the reduction of these risks
is to ease the financial performance requirements of
the project. For example, the acceptable payback may
be lengthened from four to five years, or the required
internal rate of return may be lowered from 15 percent
to 12 percent. Such adjustments reflect recognition of
elements that affect the risk exposure of the company,
but cannot be included directly in the analyses. These
adjustments are judgmental and necessarily reflect the
individual viewpoints of the people evaluating the
project for capital funding. Therefore, it is important
that the financial analysts and the decision makers in
the company be aware of the risk reduction and other
benefits of the WM options. As a policy to encourage
waste minimization, some companies have set tower
hurdle rates for WM projects.
While the profitability is important in deciding whether
or not to implement an option, environmental
regulations may be even more important. A company
operating in violation of environmental regulations can
face fines, lawsuits, and criminal penalties for the
company's managers. Ultimately, the facility may even
be forced to shut down. In this case the total cash flow
of a company can hinge upon implementing the
environmental project.
Worksheets for Economic Evaluation
Worksheets 15 through 17 in Appendix A are used to
determine the economic evaluation of a WM option.
Worksheet 15 is a checklist of capital and operating
cost items. Worksheet 16 is used to find a simple
payback period for an option that requires capital
investment. Worksheet 17 is used to find the net
present value and internal rate of return for an option
that requires capital investment. Worksheet 89 in
Appendix B is used to record estimated capital and
operating costs, and to determine the payback period
in the simplified assessment procedure.
Final Report
The product of a waste minimization assessment is a
report that presents the results of the assessment and
the technical and economic feasibility analyses. The
report also containes recommendations to implement
the feasible options.
A good final report can be an important tool for getting
a project implemented. It is particularly valuable in
obtaining funding for the project. In presenting the
feasibility analyses, it is often useful to evaluate the
project under different scenarios. For example,
comparing a projects's profitability under optimistic and
pessimistic assumptions (such as increasing waste
disposal costs) can be beneficial. Sensitivity analyses
that indicate the effect of key variables on profitability
are also useful.
-------
The report should include not only how much the
project will cost and its expected performance, but also
how it will be done. H is important to discuss:
* whether the technology is established, with
mention of succesful applications;
• the required resources and how they will be
obtained;
* estimated construction period;
* estimated production downtime;
• how the performance of the project can be
evaluated after it is implemented.
Before the report is finalized, it is important to review
the results with the affected departments and to solicit
their support. By having department representatives
assist in preparing and reviewing the report, the
chances are increased that the projects will be
implemented. In summarizing the results, a qualitative
evaluation of intangible costs and benefits to the
company should be included. Reduced liabilities and
improved image in the eyes of the employees and the
community should be discussed.
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Section 5
Implementing Waste Minimization Options
The recognized need to minimize waste
Planning and
Organization
Assessment
Phase
Feasibility
Analysis Phase
IMPLEMENTATION
Justify projects and obtain funding
Installation (equipment)
Implementation (procedure)
Evaluate performance
Successfully implemented
waste minimization projects
The WM assessment report provides the basis for
obtaining company funding of WM projects. Because
projects are not always sold on their technical merits
alone, a clear description of both tangible and
intangible benefits can help edge a proposed project
past competing projects for funding.
The champions of the WM assessment program
should be flexible enough to develop alternatives or
modifications. They should also be committed to the
point of doing background and support work, and
should anticipated potential problems in implementing
the options. Above all, they should keep in mind that
an idea will not sell if the sponsors are not sold on it
themselves.
Obtaining Funding
Waste reduction projects generally involve
improvements in process efficiency and/or reductions
in operating costs of waste management. However, an
organization's capital resources may be prioritized
toward enhancing future revenues (for example,
moving into new lines of business, expanding plant
capacity, or acquiring other companies), rather than
toward cutting current costs. If this is the case, then a
sound waste reduction project could be postponed
until the next capital budgeting period. It is then up to
the project sponsor to ensure that the project is
reconsidered at that time.
Knowing the level within the organization that has
approval authority for capital projects will help in
enlisting the appropriate support. In large
corporations, smaller projects are typically approved at
the plant manager level, medium-size projects at the
divisional vice president level, and larger projects at the
executive committee level.
An evaluation team made up of financial and technical
personnel can ensure that a sponsor's enthusiasm is
balanced with objectivity. It can also serve to quell
opposing "cant be done" or "if it aint broke, don't fix it"
attitudes that might be encountered within the
organization. The team should review the project in
the context of:
• past experience in this area of operation
• what the market and the competition are doing
• how the implementation program fits Into the
company's overall business strategy
• advantages of the proposal in relation to competing
requests for capital funding
Even when a project promises a high interal rate of
return, some companies will have difficulty raising
funds internally for capital investment. In this case, the
company should look to outside financing. The
company generally has two major sources to consider:
private sector financing and government-assisted
funding.
Private sector financing includes bank loans and other
conventional sources of financing. Government
financing is available in some cases. It may be
worthwhile to contact your state's Department of
Commerce or the federal Small Business
Administration for information regarding loans for
pollution control or hazardous waste disposal projects.
Some states can provide technical and financial
assistance. Appendix F includes a list of states
providing this assistance and addresses to get
information.
-------
Installation
Waste minimization options that involve operational,
procedural, or materials changes (without additions or
modifications to equipment) should be implemented
as soon as the potential cost savings have been
determined. For projects involving equipment
modifications or new equipment, the installation of a
waste minimization project is essentially no different
from any other capital improvement project. The
phases of the project include planning, design,
procurement, and construction.
Worksheet 18 is a form for documenting the progress
of a WM project through the implementation phase.
Demonstration and Follow-up
After the waste minimization option has been
implemented, it remains to be seen how effective the
option actually turns put to be. Options that don't
measure up to their original performance expectations
may requre rework or modifications. It is important to
get warranties from vendors prior to installation of the
equipment.
The documentation provided through a follow-up
evaluation represents an important source of
information for future uses of the option in other
facilities. Worksheet 19 is a form for evaluating the
performance of an implemented WM option. The
experience gained in implementing an option at one
facility can be used to reduce the problems and costs
of implementing options at subsequent facilities.
Measuring Waste Reduction
One measure of effectiveness for a WM project is the
project's effect on the organization's cash flow. The
project should pay for itself through reduced waste
management costs and reduced raw materials costs.
However, it is also important to measure the actual
reduction of waste accomplished by the WM project.
The easiest way to measure waste reduction is by
recording the quantities of waste generated before
and after a WM project has been implemented. The
difference, dividied by the original waste generation
rate, represents the percentage reduction in waste
quantity. However, this simple measurement ignores
other factors that also affect the quantity of waste
generated.
In general, waste generation is directly dependent on
the production rate. Therefore, the ratio of waste
generation rate to production rate is a convenient way
of measuring waste reduction.
Expressing waste reduction in terms of the ratio of
waste to production rates is not free of problems,
however. One of these problems is the danger of
using the ratio of infrequent large quantities to the
production rate. This problem is illustrated by a
situation where a plant undergoes a major overhaul
involving equipment cleaning, paint stripping, and
repainting. Such overhauls are fairly infrequent and
are typically performed every three to five years. The
decision to include this intermittent stream in the
calculation of the waste reduction index, based on the
ratio of waste rate to product rate, would lead to an
increase in this index. This decision cannot be
justified, however, since the infrequent generation of
painting wastes is not a function of production rate. In
a situation like this, the waste reduction progress
should be measured in terms of the ratio of waste
quantity or materials use to the square footage of the
area painted. In general, a distinction should be made
between production- related wastes and maintenance-
related wastes and clean-up wastes.
Also, a few waste streams may be inversely
proportional to production rate. For example, a waste
resulting from outdated input materials is likely to
increase if the production rate decreases. This is
because the age-dated materials in inventory are more
likely to expire when their use in production
decreases.
For these reasons, care must be taken when
expressing the extent of waste reduction. This
requires that the means by which wastes are
generated be well understood.
In measuring waste reduction, the total quantity of an
individual waste stream should be measured, as well as
the individual waste components or characteristics.
Many companies have reported substantial reduction
in the quanitites of waste disposed. Often, much of
the reduction can be traced to good housekeeping
and steps taken to concentrate a dilute aqueous
waste. Although concentration, as such, does not fall
within the definition of waste minimization, there are
practical benefits that result from concentrating
wastewater streams, including decreased disposal
costs. Concentration may render a waste stream easier
to recycle, and is also desirable if a facility's current
wastewater treatment system is overloaded.
Obtaining good quality data for waste stream quanities,
flows, and composition can be costly and time
consuming. For this reason, it may be practical, in
some instances, to express waste reduction indirectly
in terms of the ratio of input materials consumption to
production rate. These data are easier to obtain,
although the measure is not direct.
-------
Measuring waste minimization by using a ratio of waste
quantity to material throughput or product output is
generally more meaningful for specific units or
operations, rather than for an entire facility. Therefore,
it is important to preserve the focus of the WM project
when measuring and reporting progress. For those
operations not involving chemical reactions, it may be
helpful to measure WM progress by using the ratio of
input material quantity to material throughput or
production rate.
Waste Minimization Assessments for
New Production Processes
This manual concentrates on waste minimization
assessments conducted in existing facilities.
However, jt is important that waste minimization
principles be applied to new projects. In general, it is
easier to avoid waste generation during the research
and development or design phase than to go back and
modify the process after it has already been installed.
The planning and design team for a new product,
production process, or operation should address
waste generation aspects early on. The assessment
procedure in this manual can be modified to provide a
WM review of a product or process in the planning or
design phase. The earlier the assessment is
performed, the less likely it is that the project will
require expensive changes. All new projects should
be reviewed by the waste minimization program task
force.
A better approach than a pre-project assessment is to
include one or more members of the WM program task
force on any new project that will generate waste. In
this way, the new project will benef.it from the "built-in*
presence of a WM champion and his or her influence to
design the process to minimize waste At a California
facility of a major defense contractor, all new projects
and modifications to existing facilities and equipment
are reviewed by the WM program team. All projects
that have no environmental impact are quickly
screened and approved. Those projects that do have
an environmental impact are assigned to a team
member who participates in the project kick-off and
review meetings from inception to implementation.
Ongoing Waste Minimization Program
The WM program is a continuing, rather than a one-
time effort. Once the highest priority waste streams
and facility areas have been assessed and those
projects have been implemented, the assessment
program should look to areas and waste streams with
lower priorities. The ultimate goal of the WM program
should be to reduce the generation of waste to the
maximum extent achievable. Companies that have
eliminated the generation of hazardous waste should
continue to look at reducing industrial wastewater
discharges, air emissions, and solid wastes.
The frequency with which assessments are done will
depend on the program's budget, the company's
budgeting cycle (annual cycle in most companies), and
special circumstances. These special circumstances
might be:
• a change in raw material or product requirements
• higher waste management costs
• new regulations
• new technology
• a major event with undesirable environmental
consequences (such as a major spill)
Aside from the special circumstances, a new series of
assessments should be conducted each fiscal year.
To be truly effective, a philosophy of waste
minimization must be developed in the organization.
This means that waste minimization must be an integral
part of the company's operations. The most
successful waste minimization programs to date have
all developed this philosophy within their companies.
-------
Appendix A
Waste Minimization Assessment Worksheets
The worksheets that follow are designed to facilitate the WM assessment procedure. Table A-1 lists the worksheets,
according to the particular phase of the program, and a brief description of the purpose of the worksheets.
Appendix B presents a series of simplified worksheets for small businesses or for preliminary assessments.
Table A-1. List of Waste Minimization Assessment Worksheets
Phase Number and Title
Purpose/Remarks
1. Assessment Overview
Planning and Organization
(Section 2)
2. Program Organization
3. Assessment Team Make-up
Assessment Phase
(Section 3)
4. Site Description
5. Personnel
6. Process Information
7. Input Materials Summary
8. Products Summary
9. Individual Waste Stream
Characterization
10. Waste Stream Summary
Summarizes the overall assessment procedure.
Records key members in the WMA program task force and the WM
assessment teams. Also records the relevant organization.
Lists names of assessment team members as well as duties. Includes
a list of potential departments to consider when selecting the teams.
Lists background information about the facility, including location,
products, and operations.
Records information about the personnel who work in the area to be
assessed.
This is a checklist of useful process information to look for before
starting the assessment.
Records input material information for a specific production or process
area. This includes name, supplier, hazardous component or
properties, cost, delivery and shelf-life information, and possible
substitutes.
Identifies hazardous components, production rate, revenues, and
other information about products.
Records source, hazard, generation rate, disposal cost, and method
of treatment or disposal for each waste stream.
Summarizes all of the information collected for each waste stream.
This sheet is also used to prioritize waste streams to assess.
(continued)
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.Tabls A-1. Ll»t of Wast* Minimization Assessment Worksheets (contlnuad)
Phaaa
Number and Tltla
Purpoaa/Ramarka
Aaaaaamant Phaaa (contlnuad)
(Saetlon 3)
11, Option Generation
12. Option Description
13. Options Evaluation by
Weighted Sum Method
Faaalblilty Analysis Phasa
(Saetlon 4)
14. Technical Feasibility
15. Cost Information
16. Profitability Worksheet #1
Payback Period
17. Profitability Worksheet #2
Cash Row for NPV and 1RR
Records options proposed during brainstorming or nominal group
technique sessions. Includes the rationale for proposing each option.
Descrfoes and summarizes information about a proposed option. Also
notes approval of promising options.
Used for screening options using the weighted sum method.
Detailed checklist for performing a technical evaluation of a WM option.
This worksheet is divided into sections for equipment-related options,
personnel/procedural-related options, and materials-related options.
Detailed list of capital and operating cost information for use in the
economic evaluation of an option.
Based on the capital and operating cost information developed from
Worksheet 15, this worksheet is used to calculate the payback period.
This worksheet is used to develop cash flows for calculating NPV or IRR.
Implementation
(Section 5)
18. Project Summary
Summarizes important tasks to be performed during the
implementation of an option. This includes deliverable, responsible
person, budget, and schedule.
19. Option Performance
Records material balance information for evaluating the
performance of an implemented option.
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Firm.
Site.
Date.
Waste Minimization Assessment
Worksheets
Proj. No,
Prepared By
Checked By
Sheet _1_ of _1_ Page of
WORKSHEET
1
ASSESSMENT OVERVIEW
&EPA
Begin the Waste Minimization
Assessment Program
I
Worksheets used
PLANNING AND ORGANIZATION
* Get management commitment
* Set overall assessment program goals
* Organize assessment program task force
I
Assessment organization
and commitment to proceed
Select new
assessment targets
and reevaluate
previous options
ASSESSMENT PHASE
* Compile process and facility data
• Prioritize and select assessment targets
* Select people for assessment teams
* Review data and inspect site
* Generate options
« Screen and select options for further study
I
Assessment report of
selected options
FEASIBILITY ANALYSIS PHASE
• Technical evaluation
• Economic evaluation
• Select options for implementation
i
Final report, including
recommended options
IMPLEMENTATION
Repeat the process
> Justify projects and obtain funding
> Installation (equipment)
> Implementation (procedure)
' Evaluate performance
Successfully operating
waste minimization projects
4,6,7.8,9,10
10
3
11,12
13
14
15,16,17
18
18
19
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Firm
Site
Date
Waste Minimization Assessment
Proj. No.
Prepared By
Checked By
Sheet J_ of J_ Page of
WORKSHEET
2
PROGRAM ORGANIZATION
SEPA
FUNCTION
NAME
LOCATION
TELEPHONE*
Program Manager
Site Coordinator
Assessment Team Leader
Organization Chart
(sketch)
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Firm
Site
Date
WORKSHEET
3
Waste Minimization Assessment
Proj No.
Pre
Ch
Shi
ASSESSMENT
TEAM MAKE-UP
tpared By
ecked By
9et 1 of 1 Page of
<>EPA
Function/Department
Assessment Team
Leader
Site Coordinator
Operations
Engineering
Maintenance
Scheduling
Materials Control
Procurement
Shipping/Receiving
Facilities
Quality Control
Environmental
Accounting
Personnel
R&D
Legal
Management
Contractor/Consultant
Safety
Name
Location/
Telephone #
Man hours
Required
Duties
Lead
Support
Review
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Firm
Site
Date
Waste Minimization Assessment
PTOJ.NO.
Prepared By
Checked By
Sheet J_ of J_ Page of
WORKSHEET
4
&EPA
Firm:
Plant:
Department:
Area:
Street Address:
City:
State/ZIP Code:
Telephone: (
Major Products;
SIC Codes:
EPA Generator Number
Major Unit or;
Product or:
Operations:
Facilities/Equipment Age;
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Firm
Site
Hate
Waste Minimization Assessment
Pro) No
Prepared By
Checked By
Sheet 1 of 1 Page of
WORKSHEET
5
SEPA
Attribute
Overall
Department/Area
Total Staff
Direct Supv. Staff
Management
Average Age, yrs.
Annual Turnover Rate %
Seniority, yrs.
Yrs. of Formal Education
Training, hrsJyr.
Additional Remarks
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Firm
Sits
Date
Waste Minimization Assessment
Praj No
Prepared By
Checked By
Sheet 1 of 1 Page of
WORKSHEET
6
PROCESS INFORMATION
SEPA
Process Unit/Operation:.
Operation Type: HI
Continuous HH Discrete
D Batch or Semi-Batch D Other—
Document
Process Flow Diagram
Material/Energy Balance
Design
Operating
Flow/Amount Measurements
Stream
Analyses/ Assays
Stream
Process Description
Operating Manuals
Equipment List
Equipment Specifications
Piping & Instrument Diagrams
Plot and Elevation Plan(s)
Work Flow Diagrams
Hazardous Waste Manifests
Emission Inventories
Annual/Biennial Reports
Environmental Audit Reports
Permit/Permit Applications
Batch Sheet(s)
Materials Application Diagrams
Product Composition Sheets
Material Safety Data Sheets
Inventory Records
Operator Logs
Production Schedules
Status
Complete?
(Y/N)
Current?
(Y/N)
Last
Revision
Used In this
Report (Y/N)
Document
Number
Location
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Firm
Site
Date
WORKSHEET
7
Waste Minimization Assessment
Praj. No.
P«
Ch
Shi
ipared By
ecked By
set J_ of _l_ Page of
vvEPA
Attribute
Name/ID
Source/Supplier
Component/Attribute of Concern
Annual Consumption Rate
Overall
Component(s) of Concern
Purchase Price, $ per
Overall Annual Cost
Delivery Mode2
Shipping Container Size & Type*
Storage Mode4
Transfer Mode8
Empty Container Disposal/Management*
Shelf Life
Supplier Would
- accept expired material (Y/N)
- accept shipping containers (Y/N)
* revise expiration date (Y/N)
Acceptable Substltute(s), if any
Alternate Suppliers)
Description1
Stream No.
Stream No._
Stream No.
1 stream numbers, If applicable, should correspond to those used on process flow diagrams.
* e.g., pipeline, tank car, 1 00 bbl. tank truck, truck, etc.
* e.g., 55 gal. drum, 1 00 Ib. paper bag, tank, etc.
4 e.g., outdoor, warehouse, underground, aboveground, etc.
1 e.g., pump, forkllft, pneumatic transport, conveyor, etc.
* e.g., crush and landfill, clean and recycle, return to supplier, etc.
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Firm
Site
Date
Waste Minimization Assessment
Proj. No.
Prepared By
Checked By
Sheet J_ of 1 Page of
WORKSHEET
8
PRODUCTS SUMMARY
Attribute
Name/ID
Component/Attribute of Concern
Annual Production Rate
Overall
Component(s) of Concern
Annual Revenues, $
Shipping Mode
Shipping Container Size & Type
Onslte Storage Mode
Containers Returnable (Y/N)
Shelf Life
Rework Possible (Y/N)
Customer Would
• relax specification (Y/N)
- accept larger containers (Y/N)
Description1
Stream No.
Stream No.
Stream No.
stream numbers, if applicable, should correspond to those used on process flow diagrams.
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Firm
Site
Date
Waste Minimization Assessment
Proj. No.
Prepared By
Checked By ___
Sheet JL of 4 Page
of
WORKSHEET
9a
SEPA
1. Waste Stream Name/ID:.
Process Unit/Operation
Stream Number.
Waste Characteristics (attach additional sheets with composition data, as necessary.)
n
gas
CU liquid Cl solid CD
mixed phase
Density, Ib/cuft
Viscosity/Consistency
pH .Flash Point.
High Heating Value, Btu/lb
.; % Water
Waste Leaves Process as:
LJ air emission LJ waste water LJ solid waste LJ hazardous waste
4. Occurrence
I—I contlnuous-
I I discrete -
discharge triggered by I—I chemical analysis
LJ other (describe)
Type: LJ periodic length of period:
sporadic (irregular occurrence)
non-recurrent
S. Generation Rate
Annual
Maximum -
Average -
Frequency-
Batch Size-
Ibs per year
Ibsper
IDS per
batches per
average
range
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Firm
Site
Date
WORKSHEET
9b
Waste Minimization Assessment
Proc Unit/Qp0r
Proj. No.
Pi
C
SI
INDIVIDUAL WASTE STREAM
CHARACTERIZATION
•epared By
locked By
leet 2 of 4 Page of
x>EPA
6. Waste Origins/Sources
Fill out this worksheet to Identify the origin of the waste. If the waste Is a mixture of waste
streams, fill out a sheet for each of the Individual waste streams.
Is the waste mixed with other wastes? LJ Yes I I No
Describe how the waste Is generated.
Example: Formation and removal of an undesirable compound, removal of an uncon-
verted Input material, depletion of a key component (e.g., drag-out), equip-
ment cleaning waste, obsolete Input material, spoiled batch and production
run, spill or leak cleanup, evaporative loss, breathing or venting losses, etc.
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Firm
Site
Date
Waste Minimization Assessment
Proc. Unit/Oper
Proj. No.
Prepared By
Checked By
Sheet _3_ of 4 Page
of
WORKSHEET
9c
Waste Stream
&EPA
(continued)
7. Management Method
Leaves site In
EH bulk
D roll off bins
[~1 55 gal drums
I I other (describe)
Disposal Frequency
Applicable Regulations1
Regulatory Classification2
Managed
Recycling
D
onsite
commercial TSDF
own TSDF
[_J other (describe)
direct use/re-use
I I energy recovery
D redistilled
LJ other (describe)
EH offsite
reclaimed material returned to site?
LJ Yes LJ No [I used by others
residue yield
residue disposal/repository
Note1 list federal, state & local regulations, (e.g., RCRA, TSCA, etc.)
Notez list pertinent regulatory classification (e.g., RCRA - Listed K011 waste, etc.)
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Firm
Site
Date
Waste Minimization Assessment
Proc. Unit/Oper
Proj. No, ,
Prepared By
Checked By
Sheet j4_ of j4_ Page
of
WORKSHEET
9d
7.
EPA
(continued)
Waste Stream
Management Method (continued)
Treatment
I I biological
I I oxidation/reduction
I I incineration
I I pH adjustment
LJ precipitation
solidification
other (describe)
residue disposal/repository
Final Disposition
Costs as of
landfill
I _ I pond
I _ I lagoon
LJ deep well
I J ocean
LJ other (describe)
(quarter and year)
Cost Element:
Onsite Storage & Handling
Pretreatment
Container
Transportation Fee
Disposal Fee
Local Taxes
State Tax
Federal Tax
Total Disposal Cost
Unit Price
$ per
Reference/Source:
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Firm
Site
Date
Waste Minimization Assessment
PfOC Unit/Qper
Proj. No.
Pre
Ch
Sh<
WORKSHEET
10
;illill||||llill^
pared By
ecked By
set 1 of 1 Page of
<>EPA
Attribute
Waste ID/Name;
Source/Origin
Component/or Property of Concern
Annual Generation Rate (units )
Overall
Component(s) of Concern
Cost of Disposal
Unit Cost ($ per: )
Overall (per year)
Method of Management2
Priority Rating Criteria3
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Relative
Wt.(W
Sum of Priority Rating Scores
Priority Rank
Description1
Stream No.
Rating (R)
I(RxW)
RxW
Stream No.
Rating (R)
E(RxW)
RxW
Stream No.
Rating (R)
I(RxW)
RxW
Notes: 1. Stream numbers, if applicable, should correspond to those used on process flow diagrams.
2. For example, sanitary landfill, hazardous waste landfill, onslte recycle, Incineration, combustion
with heat recovery, distillation, dewaterlng, etc.
3. Rate each stream in each category on a scale from 0 (none) to 10 (high).
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WORKSHEET
11
Waste Minimization Assessment
Pmc. Unit/Qpar.
Pmj. No.
Pr<
Ch
Sh
OPTION GENERATION
spared By
ecked By
eet 1 of 1 Page of
£ EPA
Meeting format (e.g., bralnstormlng, nominal group technique)
Meeting Coordinator
Meeting Participants
List Suggested Options
Rationale/Remarks on Option
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Date
WORKSHEET
12
Ootlon Name:
Waste Minimization Assessment
Prac. Unit/Oper.
Pro). No.
OPTION DESCRIPTION
Prepared By
Checked By
Sheet 1 of 1 Page of
vv EPA
Briefly describe the option
Waste Stream(s) Affected:
input Materlal(s) Affected:
Product(s) Affected:
indicate Type:
Source Reduction
Equipment-Related Change
Personnel/Procedure-Related Change
Materials-Related Change
LJ Recycling/Reuse
Onslte
Offslte
Material reused for original purpose
Material used for a lower-quality purpose
Material sold
Material burned for heat recovery
Originally proposed by:
Reviewed by:
Approved for study?—
Date:
Date:
yes
no, by:
Reason for Acceptance or Rejection
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Waste Minimization Assessment
Proc. Unit/Oper .
Proj. No.
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Sheet _L of _1 Page 1 of 1
WORKSHEET
13
OPTIONS EVALUATION BY
WEIGHTED SUM METHOD
Criteria
Reduction in waste's hazard
Reduction of treatment/disposal costs
Reduction of safety hazards
Reduction of input material costs
Extent of current use In Industry
Effect on product quality (no effect = 10)
Low capital cost
Low O & M cost
Short Implementation period
Ease of Implementation
Final
Evaluation
Weight
(W)
Sum of Weighted Ratings I (WxR)
Option Ranking
Feasibility Analysis Scheduled for (Date)
Options Rating (R)
#1 Option
R
RxW
#2 Option
R
RxW
#3 Option
R
RxW
#4 Option
R
RxW
#5 Option
R
RxW
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Proc. Unit/Oper
Proj. No.
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Checked By
Sheet 1 of 6 Page of
WORKSHEET
14a
4>EPA
WM Option Description
1. Nature of WM Option
I I Equipment-Related
LJ Personnel/Procedure-Related
CD Materials-Related
2. If the option appears technically feasible, state your rationale for this.
Is further analysis required? LJ YesLJ No.
worksheet. If not, skip to worksheet 15.
3. Equipment - Related Option
Equipment available commercially?
Demonstrated commercially?
In similar application?
Successfully?
Describe closest industrial analog
If yes, continue with this
YES
D
D
D
n
D
D
D
Describe status of development
Prospective Vendor
Working Installation(s)
Contact Person(s)
Date Contacted 1.
1. Also attach filled out phone conversation notes, Installation visit report, etc.
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WORKSHEET
14b
Waste Minimization Assessment
Prop Unif/Opfir
Proj. No.
Pi
Cl
SI
Jl
'epared By
lecked By
leet 2_ of 6 Page of
&EPA
(continued)
WM Option Description
3. Equipment-Related Option (continued)
Performance Information required (describe parameters):
Scaleup Information required (describe):
Testing Required: I I yes
Scale: I I bench LJ pilot
Test unit available? I I yes
Test Parameters (list)
n
no
no
Number of test runs:
Amount of materlal(s) required:
Testing to be conducted: [jj In-plant
Facility/Product Constraints:
Space Requirements
Possible locations within facility
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Proc. UnR/Oper.
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Sheet _a_ of J_ Page of
WORKSHEET
14c
(continued)
WM Option Description
2. Equipment-Related Option (continued)
Utility Requirements:
Electric Power
Process Water
Volts (AC or DC)
Flow
kW
Pressure
Cooling Water
Quality (tap, demln, etc.)
Flow Pressure.
Temp. In
Coolant/Heat Transfer Fluid —
Temp. Out
Temp. In
Duty
Temp. Out
Steam
Pressure
Duty
Temp.
_ Flow
4»EPA
Fuel
Plant Air
Inert Gas
Type
Flow.
Duty-
Flow
Flow
Estimated delivery time (after award of contract).
Estimated Installation time
Installation dates
Estimated production downtime.
Will production be otherwise affected? Explain the effect and Impact on production.
Will product quality be affected? Explain the effect on quality.
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Firm
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Date
WORKSHEET 1|§
14d •
Waste Minimization Assessment
Pipn Unlt/Oper
Pmj No
X.vt;Wv^>^W^v,:.>v,v.;.;.x-^^ :•:•::•: '.'.'.'.-".
Pi
Cl
SI
B
(continued)
WM Option Description
epared By
lecked By
wet 4 of 6 Page of
SEPA
3. Equipment-Related Option (continued)
Will modifications to work flow or production procedures be required? Explain..
Operator and maintenance training requirements
Number of people to be trained
L-1 OnsRe
d Offslte
Duration of training
Describe catalyst, chemicals, replacement parts, or other supplies required.
Item
Rate or Frequency
of Replacement
Supplier, Address
Does the option meet government and company safety and health requirements?
Yes I I No Explain
How Is service handled (maintenance and technical assistance)? Explain
What warranties are offered?
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Proc. Unit/Oper
Proj. No
Prepared By
Checked By
Sheet J5_ of JL Page of
WORKSHEET
14e
*mmrnmmmmgmmmm: -gmmw vv
(continued)
4>EPA
WM Option Description
3. Equipment-Related Option (continued)
Describe any additional storage or material handling requirements.
Describe any additional laboratory or analytical requirements.
Personnel/Procedure-Related Changes
Affected Departments/Areas
Training Requirements
Operating Instruction Changes. Describe responsible departments.
Materials-Related Changes (Note; If substantial changes In equipment are required, then handle the
option as an equipment-related one.) XfiS
D
D
Has the new material been demonstrated commercially?
In a similar application?
Successfully?
Describe closest application.
D D
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Waste Minimization Assessment
Proc. Unit/Oper
Proj. No.
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Checked By
Sheet _6_ of 6 Page of
WORKSHEET
14f
TECHNICAL FEASIBILITY
EPA
(continued)
WM Option Description
4. Materials-Related Changes (continued)
Affected Departments/Areas
Will production be affected? Explain the effect and Impact on production.
Will product quality be affected? Explain the effect and the Impact on product quality.
Will additional storage, handling or other ancillary equipment be required? Explain.
Describe any training or procedure changes that are required.
Decribe any material testing program that will be required.
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Date
Waste Minimization Assessment
Prnn. Unif/Opar
Proj. No.
Pre
Ch
Sh(
WORKSHEET
15a
COST INFORMATION
(pared By
ecked By
set 1 of 6 Paae of
&EPA
WM Option Description.
CAPITAL COSTS - Include all costs as appropriate.
I I Purchased Process Equipment
Price (fob factory)
Taxes, freight, Insurance
Delivered equipment cost
Price for Initial Spare Parts inventory
LJ Estimated Materials Cost
Piping —
Electrical —
Instruments —
Structural —
Insulation/Piping _
TOTALS
Estimated Costs for utility Connections and New Utility Systems
Electricity
Steam
Cooling Water
Process Water
Refrigeration
Fuel (Gas or Oil)
Plant Air
Inert Gas
LJ Estimated Costs for Additional Equipment
Storage & Material Handling —
Laboratory/Analytical —
Other _
I—I Site Preparation
(Demolition, site clearing, etc.)
Estimated Installation Costs
Vendor _
Contractor _
In-house Staff —
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Waste Minimization Assessment
Proc.
Proj. No.
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Sheet _2_ of _6_ Page of
WORKSHEET
15b
TconT!nued7
SEPA
CAPITAL COSTS (Cont.)
I I Engineering and Procurement Costs (In-house & outside)
Planning
Engineering
Procurement
Consultants
TOTALS
Start-up Costs
Vendor
Contractor
In-house
L_J Training Costs
Permitting Costs
Fees
In-house Staff Costs
Initial Charge of Catalysts and Chemicals
Item #1
Item #2
LJ Working Capital [Raw Materials, Product, Inventory, Materials and Supplies (not elsewhere specified}].
Hem #1.
Item #2.
Item f3.
Item #4.
Estimated Salvage Value (If any)
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Date
WORKSHEET
15c
'<•'.'•','•:'•:'•:
Waste Minimization Assessment
ProR. yntt/Oper.
Proj. No.
jjjgjjjjjjji\ot§
Prepared By
Checked By
Sheet 3 of 6 Page of
&EPA
(continued)
CAPITAL COST SUMMARY
Cost Item
Purchased Process Equipment
Materials
Utility Connections
Additional Equipment
Site Preparation
Installation
Engineering and Procurement
Start-up Cost
Training Costs
Permitting Costs
Initial Charge of Catalysts and Chemicals
Fixed Capital Investment
Working Capital
Total Capital Investment
Salvage Value
Cost
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Waste Minimization Assessment
Prnr tlnit/Opflr
Proj. No.
Prepared By
Checked By
Sheet 4 of 6 Page of
WORKSHEET
(continued)
PxEPA
LJ Estimated Decrease (or Increase) In Utilities
Utility
Electricity
Steam
Cooling Process
Process Water
Refrigeration
Fuel (Gas or Oil)
Plant Afr
inert Air
Unit Cost
$ per unit
Decrease (or Increase) In Quantity
Unit per time
Total Decrease (or Increase)
$ per time
INCREMENTAL OPERATING COSTS - Include all relevant operating savings. Estimate these costs on an incre-
mental basis (i.e., as decreases or increases over existing costs).
LJ BASIS FOR COSTS Annual _ Quarterly _ Monthly
Dally
LJ Estimated Disposal Cost Saving
Decrease In TSDF Fees
Decrease In State Fees and Taxes
Decrease In Transportation Costs
Decrease in Onslte Treatment and Handling
Decrease In Permitting, Reporting and Recordkeeplng
Total Decrease in Disposal Costs
LJ Estimated Decrease In Raw Materials Consumption
Materials
Unit Cost
$ per unit
Reduction In Quantity
Units per time
Decrease In Cost
$ per time
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Waste Minimization Assessment
Proc. Unlt/Oper
Proj. No.
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Sheet 5_ of J_ Page of
WORKSHEET
15e
(continued)
Estimated Decrease {or Increase) In Ancillary Catalysts and Chemicals
Catalyst/Chemical
Unit Cost
$ per unit
Decrease (or Increase) In Quantity
Unit per time
Total Decrease (or Increase)
$ per time
D
Estimated Decrease (or Increase) in Operating Costs and Maintenance Labor Costs
(Include cost of supervision, benefits and burden).
Estimated Decrease (or Increase) In Operating and Maintenance Supplies and Costs.
D
Estimated Decrease (or Increase) In Insurance and Liability Costs (explain).
D
Estimated Decrease (or Increase) In Other Operating Costs (explain).
INCREMENTAL REVENUES
Estimated Incremental Revenues from an Increase (or Decrease) In Production or Marketable
By-products (explain).
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Waste Minimization Assessment
Proc. Unit/Oper
Proj. No.
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Sheet _6_ of 6 Page of
WORKSHEET
15f
COST INFORMATION
(continued)
&EPA
INCREMENTAL OPERATING COST AND REVENUE SUMMARY (ANNUAL BASIS}
Decreases In Operating Cost or Increases In Revenue are Positive.
Increases In Operating Cost or Decrease In Revenue are Negative.
Operating Cost/Revenue Item
Decrease in Disposal Cost
Decrease In Raw Materials Cost
Decrease (or Increase) In Utilities Cost
Decrease (or Increase) in Catalysts and Chemicals
Decrease (or Increase) In O & M Labor Costs
Decrease (or Increase) In O & M Supplies Costs
Decrease (or Increase) In insurance/Liabilities Costs
Decrease (or Increase) In Other Operating Costs
Incremental Revenues from Increased (Decreased) Production
Incremental Revenues from Marketable By-products
Net Operating Cost Savings
$ per year
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Date
Waste Minimization Assessment
Proc.
Proj. No.
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Sheet J__ of J_ Page
of
WORKSHEET
16
iHiiliiMiliiiiililiiii
&EPA
Total Capital Investment ($) (from Worksheet I5c)
Annual Net Operating Cost Savings ($ per year) (from Worksheet 15f)_
Payback Period (In years) =
Total Capital Investment
Annual Net Operating Cost Savings
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Date
Waste Minimization Assessment
Proc. Unit/Oper
Proj. No
Prepared By
Checked By
Sheet J_ of J_ Page
of
WORKSHEET
17
4vEPA
Cash Incomes (such as net operating cost savings and salvage value) are shown as positive.
Cash outlays (such as capital Investments and Increased operating costs} are shown as negative.
Line
A Rxed Capital Investment
B 4 Working Capital
C Total Capital Investment
D Salvage Value2
E Nat Operating Costs Savings
F - Interest on Loans
G - Depreciation
H Taxable Income
I - Income Tax*
J Aftertax Profit*
K + Depreciation
L - Repayment of Loan Principal
M - Capital Investment (line C}
N + Salvage Value (line D)
0 Cash Flow
P Present Value of Cash Flow4
Q Net Present Value (NPV)*
Present Worth* (5% discount)
1.0000
0.9524
0.9070
0.8638
0.8227
0.783S
0.7462
0.7107
0.6768
(10% discount)
1.0000
0.9091
0.8264
0.7513
0.6830
0.6209
0.5645
0.5132
0.46Q5
(15% discount)
1.0000
0.8696
0.7561
0.6575
0.5718
0.4972
0.4323
0.3759
0.3269
(20% discount)
1.0000
0.8333
0.6944
0.5787
0.4823
0.4019
0.3349
0.2791
0.2326
(25% discount)
1.0000 0.8000 0.6400 0.5120 0.4096 0.3277
0.2621
0.2097
0.1678
1 Adjust table as necessary if the anticipated project life Is less than or more than 8 years.
2 Salvage value Includes scrap value of equipment plus sale of working capital minus demo-
lition costs.
3. The worksheet Is used for calculating an aftertax cash flow. For pretax cash flow, use an Income tax rate of 0%.
4 The present value of the cash flow Is equal to the cash flow multiplied by the present worth factor.
5 The net present value Is the sum of the present value of the cash flow for that year and all of the proceeding years.
6 The formula for the present worth factor Is 1 where n Is years and r Is the discount rate.
(1+ry
7 The Internal rate of return (IRR) Is the discount rate (r) that results In a net present value of zero over the life of the
project.
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Firm
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Date
Goals/0
WORKSHEET
18
bjectlves
Waste Minimization Assessment
Proc. Un'rt/Oper.
Proj. No.
Prepared By
Checked By
Sheet 1 of 1 Page of
PROJECT SUMMARY 4? EPA
Task
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
Deliverable
Task Leader
TOTALS
Manhours
Budget
Duration
Wks
Start
Finish
Reference
Approval By
Authorization By
Project Started (Date)
Date.
Date
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Firm
Site
Date
WORKSHEIT
19
Waste Minimization Assessment
PfOC Unif/Qp0r.
Proj. No.
Pre
Ch
Sh(
:::::::::::::x:::::: *:::::::::-:: :: :- :- : :;>; •:-; :: :; :; : ::x i: ': •:;:;:;X:::.'::::::'>x::r>ft;>:::-:\>;::: ;::;:: : : : ": •: • : '•?£ '$yf%f^£fi-£5^:^^
pared By
ecked By
set 1 of 1 Page of
&EPA
WM Option Description
LJ Baseline
(without option)
D
Projected
(a)
(b)
(c)
Period Duration
From
Production per Period
Units (
Input Materials Consumption per Period
Material
Pounds
Actual
.To
Pounds/Unit Product
(d) Waste Generation per Period
Waste Stream
Pounds
Pounds/Unit Product
(e) Substance(s) of Concern - Generation Rate per Period
Waste Stream
Substance
Pounds
Pounds/Unit Product
-------
Appendix B
Simplified Waste Minimization Assessment Worksheets
The worksheets that follow are designed to facilitate a simplified WM assessment procedure. Table B-1 lists the
worksheets, according to the particular phase of the program, and a brief description of the purpose of the
worksheets. The worksheets here are presented as supporting only a preliminary effort at minimizing waste,
or in a situation where a more formal rigorous assessment is not warranted.
Table B-1. List of Simplified WM Assessment Worksheets
Phase Number and Title
Purpose/Remarks
S1. Assessment Overview
Assessment Phase
(Section 3}
82. Site Description
S3. Process Information
S4. Input Materials Summary
SS. Products Summary
86. Waste Stream Summary
S7. Option Generation
S8. Option Description
Feasibility Analysis Phase
(Section 4)
S9. Profitability
Summarizes the overall assessment procedure.
Lists background information about the facility, including location,
products, and operations.
This is a checklist of useful process information to look for before
starting the assessment.
Records input material information for a specific production or process
area. This includes name, supplier, hazardous component or
properties, cost, delivery and shelf-life information, and possible
substitutes.
Identifies hazardous components, production rate, revenues, and
other information about products.
Summarizes all of the information collected for each waste stream.
This sheet Is also used to prioritize waste streams to assess.
Records options proposed during brainstorming or nominal group
technique sessions. Includes the rationale for proposing each option.
Describes and summarizes information about a proposed option. Also
notes approval of promising options.
This worksheet is used to identify capital and operating costs and to
calculate the payback period.
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Firm
Site
Date
Waste Minimization Assessment
Simplified Worksheets
Proi. No.
Prepared Bv
Checked Bv
Sheet 1 of 1 Paae of
WORKSHEET
S1
ASSESSMENT OVERVIEW
SEPA
Begin the Waste Minimization
Assessment Program
I
Worksheets used
PLANNING AND ORGANIZATION
Get management commitment
Set overall assessment program goals
Organize assessment program task force
Assessment organization
and commitment to proceed
Select new
assessment targets
and reevaluate
previous options
ASSESSMENT PHASE
• Compile process and facility data
• Prioritize and select assessment targets
• Select people for assessment teams
• Review data and inspect site
• Generate options
• Screen and select options for further study
S5
S2.S3.S4
S6
S7.S8
S8
S3
I
Assessment report of
selected options
FEASIBILITY ANALYSIS PHASE
• Technical evaluation
• Economic evaluation
• Select options for implementation
S9
I
Final report, including
recommended options
IMPLEMENTATION
Repeat the process
• Justify projects and obtain funding
' Installation (equipment)
' Implementation (procedure)
' Evaluate performance
Successfully operating
waste minimization projects
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Date
Waste Minimization Assessment
Simplified Worksheet!
Proj, No.
Prepared By
Checked By
Sheet J_ of J_ Page of
WOBKSHifT
S2
SITE DESCRIPTION
&EPA
Firm:
Plant:
Department:
Area:
Street Address:
City:
State^IP Code:
Telephone: {
Major Products:
SIC Codes:
EPA Generator Number
Major Unit or;
Product or:
Operations:
Facilities/Equipment Age;
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Firm
Site
Date
Waste Minimization Assessment
Simplified Worksheet*
Pmj No-
Prepared By
Checked By
Sheet 1 of 1 Paae of
wo
CxEPA
Process Unit/Operation:
Operation Type: C
Continuous
Batch or Semi-latch
D Discrete
EH other—
Document
Process Flow Diagram
Material/Energy Balance
Design
Operating
Flow/Amount Measurements
Stream
Analyses/ Assays
Stream
Process Description
Operating Manuals
Equipment List
Equipment Specifications
Piping & Instrument Diagrams
Plot and Elevation Plan(s)
Work Flow Diagrams
Hazardous Waste Manifests
Emission Inventories
Annual/Biennial Reports
Environmental Audit Reports
Permit/Permit Applications
Batch Sheet(s)
Materials Application Diagrams
Product Composition Sheets
Material Safety Data Sheets
Inventory Records
Operator Logs
Production Schedules
Status
Complete?
(Y/N)
Current?
(Y/N)
Last
Revision
Used In this
Report (Y/N)
Document
Number
Location
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Date
WORKSHEET
S4
Waste Minimization Assessment
Simplified Worksheets
Proj. No.
Prt
Ch
Sh
INPUT MATERIALS SUMMARY
(pared By
ecked By
set 1 of 1 Page of
SEPA
Attribute
Name/ID
Source/Supplier
Component/ Attribute of Concern
Annual Consumption Rate
Overall
Component(s) of Concern
Purchase Price, $ per
Overall Annual Cost
Delivery Mode1
Shipping Container Size & Type2
Storage Mode1
Transfer Mode4
Empty Container Disposal/Management*
Shelf Life
Supplier Would
- accept expired material (Y/N)
- accept shipping containers (Y/N)
- revise expiration date (Y/N)
Acceptable Substltute(s), If any
Alternate Suppller(s)
Description
Stream No.
Stream No.
Stream No.
1 e.g., pipeline, tank car, 1 00 bbl. tank truck, truck, etc.
2 e.g., 55 gal. drum, 100 Ib. paper bag, tank, etc.
' e.g., outdoor, warehouse, underground, aboveground, etc.
4 e.g., pump, forkllft, pneumatic transport, conveyor, etc.
* e.g., crush and landfill, clean and recycle, return to supplier, etc.
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Date
WORKSHEET
35
Waste Minimization Assessment
Simplified Worksheets
Prnj No
Pre
Ch
Shi
ipared By
sckedBy
set J_ of j_ Page of
&EPA
Attribute
Name/ID
Component/Attribute of Concern
Annual Production Rate
Overall
Component(s) of Concern
Annual Revenues, $
Shipping Mode
Shipping Container Size & Type
Onslte Storage Mode
Containers Returnable (Y/N)
Shelf Life
Rework Possible (Y/N)
Customer Would
- relax specification (Y/N)
• accept larger containers (Y/N)
Description
Stream No.
- -
Stream No.
Stream No.
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Firm
Site
Data
WORKSHEET
S6
Waste Minimization Assessment
Simplified Worksheet*
Pmc llritJOpar
Pmj No
Pr€
Ch
Sh
WASTE STREAM SUMMARY
spared By
ecked By
set 1 of 1 Page of
SEPA
Attribute
Waste ID/Name:
Source/Origin
Component/or Property of Concern
Annual Generation Rate (units )
Overall
Component(s) of Concern
Cost of Disposal
Unit Cost (S per: )
Overall (per year)
Method of Management1
Priority Rating Criteria2
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
-Potential By-product Recovery
Relative
Wt.fW
Sum of Priority Rating Scores
Priority Rank
Description
Stream Ho. „
Rating (R)
Z(RxW)
RxW
Stream No.
Rating (R)
KRxW)
RxW
Stream No.
Rating (R)
I(RxW)
RxW
Notes: 1 . For example, sanitary landfill, hazardous waste landfill, onsite recycle, Incineration, combustion
with heat recovery, distillation, dewaterlng, etc.
2. Rate each stream in each category on a scale from 0 (none) to 10 (high).
-------
Firm
Site
Data
Waste Minimization Assessment
Simplified Worksheets
Pffy? iJnWGpf
Pmj No.
Prepared By
Checked By
Sheet 1 of 1 Rape of
WORKSHEET
S7
(IlliIIIliillliiiB
EPA
Meeting format (e.g., bralnstormlng, nominal group technique)
Meeting Coordinator
Meeting Participants
List Suggested Options
Rationale/Remarks on Option
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Firm
Site
Date
i
WORKSHEET
S8
Dotlon Name:
Waste Minimization Assessment
Simplified Worksheets
PrQC~ pnit/Qper,
Proj. No.
Wi*s:::S" •: :•&<< : -: ••; \ :- "-. •. ; ;:&** s ?•• - : ssssx^iiir •:•. ^<&fm
Prepared By
Checked By
Sheet 1 of 1 Page of
&EPA
Briefly describe the option
Waste Stream(s) Affected:
Input Materials) Affected;
Product(s) Affected:
Indicate Type:
LJ Source Reduction
L....,...,_ Equipment-Related Change
Personnel/Procedure-Related Change
Materials-Related Change
I I Recycling/Reuse
Onslte
Offslte
Material reused for original purpose
Material used for a lower-quality purpose
Material sold
Material burned for heat recovery
Originally proposed by:
Reviewed by:
Approved for study?—
Date:
Date:
yes
no, by:
Reason for Acceptance or Rejection
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Firm
Site
Date
Waste Minimization Assessment
Simplified Worksheets
Prop Unit/Oper
Proj. No.
Prepared By
Checked By
Sheet 1 of 1 Page of
WORKSHEET
S9
PROFITABILITY
&EPA
Capital Costs
Purchased Equipment
Materials
Installation
Utility Connections-
Engineering
Start-up and Training.
Other Capital Costs -
Total Capital Costs
Incremental Annual Operating Costs
Change In Disposal Costs —
Change In Raw Material Costs
Change In Other Costs
Annual Net Operating Cost Savings
Total Capital Costs
Payback Period (In years) = Annuai Net Operating Cost Savings
-------
Appendix C
Waste Minimization Assessment Example
Amalgamated Metal Reflnlshlng Corporation
The following case study is an example of a waste
minimization assessment of a metal plating operation.
This example is reconstructed from an actual
assessment, but uses fictitious names. The example
presents the background process and facility data, and
then describes the waste minimization options that are
identified and recommended for this facility.
Amalgamated Metal Refinishing Corporation is in the
business of refinishing decorative items. The
corporation owns and operates a small facility in
Beverly Hills, California. The principal metals plated at
this facility are nickel, brass, silver, and gold.
Preparing for the Assessment
Since the facility is a small one with a rather small
number of employees, an assessment team was
assembled that included both company personnel and
outside consultants. The team was made up of the
following people:
Plant manager (assessment team leader)
First shift plating supervisor
Corporate process engineer
Plating chemistry consultant
Environmental engineering consultant
The assessment team chose to look at all of the plating
operations, rather than focusing on one or two specific
plating processes.
The assessment began by collecting recent
production records, input material information,
equipment layout drawings and flow diagrams, waste
records, and plant operator instructions. After each of
the team members had reviewed the information, a
comprehensive inspection of the plating room was
carried out. The following process, layout, and waste
descriptions summarize the information that was
collected for the assessment.
Process Description
items brought in for refinishing are cleaned,
electroplated and polished The basic operations
include paint stripping, cleaning, electroplating, drying,
and polishing.
In silver plating, the original plated metal is stripped off
the item by dipping it into a sodium cyanide solution
with the system run in reverse current. This is followed
by an acid wash in a 50% muriatic acid solution. The
item is then polished to a bright finish. The polished
item is then cleaned with caustic solution to remove
dirt, rinsed with a 5% sulfuric acid solution to neutralize
any remaining caustic solution on the item, and rinsed
with water. The item is now ready for electroplating.
After the item is immersed in the plating tank for the
required amount of time, it is rinsed in a still rinse tank,
followed by a continuous water rinse. Tap water is
used for both the still and continuous rinsing steps.
Solution from the still rinse tank is used as make-up for
the plating baths.ln places where two still rinse tanks
are used, water from the second tank is used to-
replenish the first still rinse tank. Overflow from the
continuous rinse tank is discharged as wastewater.
The item is polished following the plating step.
Gold plating generally does not require stripping. After
the initial cleaning operation, the item is electroplated.
Nickel and brass plating are also done in a similar
manner. Vapor degreasing using 1,1,1-
trichloroethane is often perfomed on brass- and nickel-
plated items to remove oil and grease. In some cases,
items are first nickel-plated and then plated with gold,
silver, or brass.
For electroplating operations, the constituents of the
cyanide solutions must be kept at an optimum
concentration. The solutions are analyzed twice a
month by an outside laboratory. A representative
sample from a tank is obtained by dipping a tube to the
bottom of the plating tank. The sample is analyzed and
recommendations for make-up are made based on the
test results. Table C-1 shows a typical analysis for
brass and nickel electroplating solutions, respectively.
This table also shows the optimum concentrations for
each constituent in the baths, as well as the
recommended make-up and/or dilution requirements.
AH plating operations at the facility are performed
manually. The facility operates one shift per day and
employs eight operators.
Equipment Layout Description
All plating, cleaning, and rinse tanks are located in one
room at the plating shop, while an adjacent room
houses all equipment used for buffing and polishing.
-------
Table C-1. Electroplating Solution Analyses
Table C-2. Wastewater characteristics
Concentrations
Brass Plating
Copper metal
Zinc metal
Sodium cyanide
Sodium hydroxide
Copper cyanide
Zinc cyanide
Rochelle salts
Optimum
0.3 oz/gal
6.0
8.0
10.0
0.5
2.0
Actual
7.52 oz/gal
0.80
3.54
7.50
10,60
1.45
3.59
Nickel Plating
Nickel metal
Nickel chloride
Boric acid
Nickel sutfate
A-5
SA-1
pH
-
8.0 oz/gal
6.0
40.0
2.5%
1.2%
4.0
16.65 oz/gal
15.66
6.92
57.26
2.86%
1.38%
4.5
Figure C-1 is a plan of the facility. The area north of the
buffing room is used for drying and storage purposes.
Finished goods, as well as raw materials, are stored in
the front of the building.
Thirty tanks are used in cleaning and electroplating
operations. Figure C-1 includes the names and normal
working volumes of these tanks. The configuration of
a typical plating unit includes a plating bath, followed by
one ore two still tanks and a continuous rinse tank.
Except for nickel plating, all plating and stripping
solutions used at the facility are cyanide-based.
Waste Stream Description
Cyanide waste is generated from silver stripping; from
silver, gold, brass, and copper electroplating; ami from
the associated rinsing operations. The principal waste
streams are wastewater from the continuous rinse
tanks and from floor washings, and plating tank filter
waste.
Aqueous streams generated from paint stripping, from
metal stripping and electroplating, and from floor
washings are routed to a common sump. This sump
discharges to the sanitary sewer. Table C-2 presents
the results of a typical analysis on the wastewater.
Metal sludges accumulate in the plating tanks. This
sludge is filtered out of the plating solution once a
month using a portable dual cartridge fitter. Two filter
cartridges are used for each plating tank. Cartridges
are typically replaced every two to three months.
The sump is pumped out and disposed of as
hazardous waste once every six months. When
pumped out the sump usually contains 300 to 400
Sampling date
Sampling location
Type of sample
Reporting period
Total flow in
Total flow out
Peakf tow
August 8,1987
Clarifier Sample Box
Time Composite
July '87 to August '87
322galon8
290 gallons
1.5 gallons per minute
Suspended solids
pH
Total cyanide
Total chromium
Copper
Nickel
Silver
Oil and grease
Temperature
1.0mg/L
7.5
1.0 mg/L
0.42 mg/L
1.30 mg/L
0.93 mg/L
<0.05 mg/L
0.2 mg/L
TOT
gallons of sludge comprised of dirt, stripped paint, and
a solution containing cyanide and heavy metals.
Proposed Waste Minimization Options
After the site inspection was completed and additional
information was reviewed, the team held a
brainstorming session to identify potential waste
minimization options for the facility. The following
options were proposed during the meeting:
* Reduce solution drag-out from the plating tanks by:
- Proper positioning of workpiece on the plating
rack.
- Increasing plating solution temperatures.
- Lowering the concentration of plating solution
constituents.
- Increase the recovery of drag-out with drain
boards.
* Extend plating solution bath life by:
- Reducing drag-in by better rinsing.
- Using deionized make-up water.
- Using purer anodes.
- Returning spent solutions to the suppliers.
* Reduce the use of rinse water by:
- Using multiple countereurrent rinse tanks.
- Using still rinsing.
- Using spray or fog rinsing.
« Prevent dust from the adjacent buffing and
polishing room from entering the plating room and
contaminating the plating baths.
* Segregate cyanide wastes from the rinse tanks from
other wastewater streams, such as floor washings
and paint stripping wastes.
-------
HIM*
70g«l
W«*r
Rn»*
50 j»!
Copper Cy*nM*
156 gallon*
d*in«r
Mgdkm
/
\
\
••. J
Buffing and Polishing Room
Two-Stag*
Cl«rll«r/8ump
Storage Area
North
Figure C-1. PLANT LAYOUT
Amalgamated Metal Refinishing Corporation
Worldwide Headquarters and Production Facilities
Beverly Hills, California
-------
The team members each independently reviewed the
options and then met to decide which options to study
further. The team chose the following options for the
feasibility analysis:
* Reduce drag-out by using drain boards.
• Extend bath life using deionized water for make-up.
* Use spray rinsing to reduce rinsewater usage.
• Segregate hazardous waste from nonhazardous
waste.
Feasibility Analysis
The assessment team conducted technical and
economic feasibility analyses on each of the four
options.
Segregate Hazardous Wastes
The assessment team recognized that segregating
hazardous wastes from nonhazardous wastes could be
implemented at virtually no cost and would save money
immediately. There were no identified technical
problems.
Use Drain Boards to Reduce Drag-out
Drain boards are used to collect plating solution that
drips off the rack and the workplace after they are
pulled out of the plating tank. The plating solution
drains back into the plating tank. This option reduces
the amount of dilute rinse water waste, but impurities
build up faster in the plating solution. Since drag-out is
reduced, make-up chemical consumption is reduced.
The purchase price of drain boards is estimated at
$115, with installation costs of $200, for a total capital
cost of $315. This option is expected to reduce rinse
water disposal costs by $500 per year, and reduce
make-up chemicals costs by $400 per year. The
resulting payback period is 0.35 years, or about 4
months.
Use Deionized Water for Make-up Solutions
and Rinse Water
Using Dl water will reduce the build-up of impurities in
the plating solutions. In particular, the build-
uphardness minerals from tap water will be avoided.
This, in turn, will avoid the precipitation of carbonates in
the plating tanks.
The assessment team decided to combine the
evaluation of this option with the previous option of
using drain boards. The initial purchase and installation
of the deionizer was $267. When adding the cost of
the drain boards, the total capital cost of this option is
$582. The deionizer is rented and serviced by an
outside water treating service company for $450 per
year. The savings in disposal costs and make-up
chemical costs is $900 per year. Therefore, the annual
net operating cost savings is $450 per year. The
payback period is 1.3 years.
Install Spray Rinses
Installing spray rinses will reduce the amount of rinse
water required to clean the items. With spray rinse
nozzles and controls, rinsing can be done on demand.
Rinse water usage was estimated to be reduced by
50%. The resulting rinse wastewater is more
concentrated and some can be returned to the plating
tanks as a water make-up.
The assessment team determined that four spray rinse
units would cost $2,120, plus an additional $705 for
piping, valves, and installation labor. The total capital
cost was $2825. The reduction In disposal costs were
estimated at $350 per year, based on a 50% reduction
in rinse wastewater. This resulted in a payback of over
8 years.
Implementation
The procedures for segregating hazardous wastes
from nonhazardous wastes was implemented before
the feasibility analysis was completed for the other
three options. The installation of drain boards and the
purchase of a water deionizer were made shortly after
the feasibility analysis was completed. The Dl water
system was online two months later. The assessment
team decided not to implement the spray rinse option
because of the long payback period.
Future WM Assessments
During the next cycle of waste minimization
assessments, the assessment team will review
previously suggested options in the plating area and
will look at ways to reduce the generation of metallic
dust in the buffing and polishing area. In the
meantime, the assessment team will continue to look
for additional opportunities to reduce waste
throughout the facility.
-------
Appendix D
Typical Causes and Sources of Waste
In order to develop a comprehensive list of waste minimization options for a facility, it is necessary to
understand the sources, causes, and controlling factors that influence waste generation. The tables
In this Appendix list this information for common industrial operations.
Table D-1. Typical Wastes from Plant Operations
Table D-2. Causes and Controlling Factors of Waste Generation
Tabl* D-1. Typical Wastes from Plant Operations
Plant Function Location/Operation
Potential Waste Material
Material Receiving
Raw Material and
Product Storage
Production
Support Services
Loading docks, incoming
pipelines, receiving areas
Tanks, warehouses, drum
storage yards, bins,
storerooms
Melting, curing, baking,
distilling, washing, coating,
formulating, reaction
Laboratories
Maintenance shops
Garages
Powerhouses/boilers
Cooling towers
Packaging materials, off-spec materials, damaged containers,
inadvertant spills, transfer hose emptying
Tank bottoms; off-spec and excess materials; spill residues;
leaking pumps, valves, tanks, and pipes; damaged containers,
empty containers
Washwater; rinse water; solvents; still bottoms; off-spec
products; catalysts;empty containers; sweepings; ductwork
clean-out; additives; oil; filters; spill residue; excess materials;
process solution dumps; leaking pipes, valves, hoses, tanks,
and process equipment
Reagents, off-spec chemicals, samples, empty sample and
chemical containers
Solvents, cleaning agents, decreasing sludges, sand-blasting
waste, caustic, scrap metal, oils, greases
Oils, filters, solvents, acids, caustics, cleaning bath sludges,
batteries
Fly ash, slag, tube clean-out material, chemical additives, oil
empty containers, boiler blowdown, water-treating chemical
wastes
Chemical additives, empty containers, cooling tower bottom
sediment, cooling tower blowdown, fan lube oils
Source: adapted from Gary Hunt and Roger Schecter, "Minimization of Hazardous Waste Generation",
Standard Handbook of Hazardous Waste Management, Harry Freeman, editor, McGraw-Hill, New York (currently in press).
-------
Tabla D-2. Causes and Controlling Factor* In Waste Generation
Waste/Origin Typical Causes Operational Factors
Design Factors
Chemical Reaction
Contact between
aqueous and
organic phases
Process equipment
cleaning
Heat exchanger
cleaning
Metal parts
cleaning
Metal surface
treating
Disposal of
unusable raw
materials or
off-spec products
Clean-up of spills
and leaks
* Incomplete conversion
* By-product formation
* Catalyst deactivation
(by poisoning or sintering)
* Condensate from steam
jet ejectors
* Presence of water as a
reaction by-product
* Use of water for product
rinse
* Equipment cleaning
• Spill clean-up
* Presence of cling
* Deposit formation
* Use of filter aids
* Use of chemical cleaners
* Presence of cling (process
side) or scale (cooling
water side)
«Deposit formation
* Use of chemical cleaners
* Disposal of spent solvents,
spent cleaning solution, or
cleaning sludge
> Dragout
• Disposal of spent treating
solution
• Obsolete raw materials
• Off-spec products caused
by contamination, improper
reactant controls, inadequate
pre-cleaning of equipment or
workplace, temperature or
pressure excursions
• Manual material transfer and
handling operations
• Leaking pump seals
> Leaking flange gaskets
1 Inadequate temperature control
' Inadequate mixing
1 Poor feed flow control
1 Poor feed purity control
' Indiscriminate use of water for
cleaning or washing
' Drainage prior to cleaning
1 Production scheduling to
reduce cleaning frequency
1 Inadequate cooling water
treatment
1 Excessive cooling water
temperature
Indiscriminate use of solvent
or water
* Poor rack maintenance
• Excessive rinsing with water
• Fast removal of workplace
• Poor operator training or
supervision
• Inadequate quality control
* Inadequate production planning
and inventory control of
feedstocks
> Inadequate maintenance
> Poor operator training
> Lack of attention by operator
> Excessive use of water in
cleaning
• Proper reactor design
• Proper catalyst selection
• Choice of process
• Choice of reaction conditions
• Vacuum pumps instead of
steam jet ejectors
• Choice of process
* Use of reboilers instead of
steam stripping
1 Design reactors or tanks
wiper blades
1 Reduce ding
> Equipment dedication
' Design for lower film temperature
and high turbulence
• Controls to prevent cooling
water from overheating
1 Choice between cold dip tank or
vapor degreasing
' Choice between solvent or
aqueous cleaning solution
> Countercurrent rinsing
> Fog rinsing
• Dragout collection tanks or trays
> Use of automation
> Maximize dedication of
equipment to a single function
• Choice of gasketing materials
• Choice of seals
• Use of welded or seal-welded
construction
Source: Jacobs Engineering Group
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Appendix E
Waste Minimization Techniques
The tables in this appendix lists techniques and practices for waste reduction in operations that are
applied in a wide range of industries. Most of the techniques listed here are source reduction techniques.
Table E-1. Waste Minimization Options for Coating Operations
Table E-2. Waste Minimization Options for Equipment Cleaning Operations
Table E-3. Waste Minimization through Good Operating Practices
Table E-4. Waste Minimization Options in Materials Handling, Storage, and Transfer
Table E-5. Waste Minimization Options for Parts Cleaning Operations
Source: Jacobs Engineering Group
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Table E-1. Waste Minimization Options for Coating Operations
Waste
Source/Origin
Waste Reduction Measures
Remarks
References
Coating overspray
Coating material that fails
to reach the object being
coated
Maintain 50% overlap between spray pattern
Maintain 6* - 8* distance between spray gun
and the workplace
Maintain a gun speed of about 250 feet/minute
Hold gun perpendicular to the surface
Trigger gun at the beginning and end of each
pass
Proper training of operators
Use robots for spraying
Avoid excessive air pressure for coating
atomization
Recycle overspray
Use electrostatic spray systems
Use air-assisted airless spray guns in place of
air-spray guns
The coated object does not look
streaked, and wastage of coating
material is avoided. If the spray
gun is arched 45°, the overspray
can be as high as 65%,
By air pressure adjustment,
overspray can be reduced to 40%.
Overspray can be reduced by 40%.
Increases transfer efficiency.
1,2
2
2
2
3
4
4
Stripping wastes
Coating removal from parts
before applying a new coat
Solvent emissbns
Equipment cleanup
wastes
Evaporative losses from
process equipment and
coated parts
Process equipment cleaning
with solvents
Overall
Avoid adding excess thinner
Use abrasive media stripping
Use bead-blasting for paint stripping
Use cryogenic stripping
Use caustic stripping solutions
Clean coating equipment after each use
Keep solvent soak tanks away from heat sources
Use high-solids formulations
Use powder coatings
Use water-based formulations
Light-to-dark batch sequencing
Produce large batches of similarly coated
objects instead of small batches of differently
coated Hems
Isolate solvent-based paint spray booths from
water-based paint spray booths
Reuse cleaning solution/solvent
Standardize solvent usage
Reexamine the need for coating, as well as
available alternatives
Reduces stripping wastes due to rework.
Solvent usage is eliminated.
Solvent usage is eliminated.
Solvent usage is eliminated.
Solvent usage is eliminated.
Lower usage of solvents.
Avoids solvent usage.
Avoids solvent usage.
6
7
8
1
9
10,11
4,12
13
20
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Table E-2. Waste Minimization Options for Equipment Cleaning Operations
Waste
Source/Origin
Waste Reduction Measures
Remarks
References
Spent solvent- or
inorganic-based
cleaning solutbns
Tank cleaning operatbns
• Maximize dedication of process equipment
• Use squeegees to recover cling of product
prior to rinsing
* Avoid unnecessary cleaning
* Closed storage and transfer systems
* Provide sufficient drain time for liquids
* Lining the equipment to prevent cling
* "Pigging" process lines
« Use high-pressure spray nozzles
* Use countercurrent rinsing
* Use clean-in-place systems
• Clean equipment immediately after use
• Reuse cleanup solvent
• Rework cleanup solvent into useful products
* Segregate wastes by solvent type
• Standardize solvent usage
* Reclaim solvent by distillation
* Schedule production to lower cleaning
frequency
Scaling and drying up can be prevented.
Minimizes leftover material.
Reduces ding.
Minimizes solvent consumption.
Prevents hardening of scale that requires
more severe cleaning.
18
19
Wastewater
sludges, spent
acidic solutions
Heat exchanger cleaning
Use bypass control or pumped recycle to
maintain turbulence during turndown
Use smooth heat exchange surfaces
Use on-stream cleaning techniques
Use hydroblasting over chemical cleaning
where possible
Onsite or offsite recycling.
Electroplated or Tefbn® tubes.
"Superscrubber", for example.
20
21
-------
Table E-3. Waste Minimization through Good Operating Practices
Good Operating Practice
Program Ingredients
Remarks
References
Waste minimization assessments
Environmental audits/reviews
Loss prevention programs
Waste Segregation
Preventive maintenance programs
Form a team of qualified individuals
Establish practical short-term and long-term goals
Allocate resources and budget for the program
Establish assessment targets
Identify and select options to minimize waste
Periodically monitor the program's effectiveness
Assemble pertinent documents
Conduct environmental process reviews
Carry out a site inspection
Report on and follow up on the findings
Establish Spill Prevention, Control, and
Countermeasures (SPCC) plans
Conduct hazard assessment in the design and
operating phases
Prevent mixing of hazardous wastes with
non-hazardous wastes
Isolate hazardous wastes by contaminant
Isolate liquid wastes from solid wastes
Use equipment data cards on equipment location,
characteristics, and maintenance
Maintain a master preventive maintenance (PM)
schedule
Deferred PM reports on equipment
Maintain equipment history cards
Maintain equipment breakdown reports
Keep vendor maintenance manuals handy
Maintain a manual or computerized repair history file
These programs are conducted to reduce
waste in a facility.
22
These audits are conducted to monitor
compliance with regulations.
SPCC plans are required by law for oil
storage facilities.
These measures can result in lower waste
haulage volumes and easier disposal of
the hazardous wastes.
These programs are conducted to cut
production costs and decrease
equipment downtime, in addition
to preventing waste releases due
to equipment failure.
23,24
3,25,26
27,28,29
-------
Table E-3. Waste Minimization through Good Operating Practices (continued)
Good Operating Practice
Program Ingredients
Remarks
References
Training/Awareness-building
programs
Effective supervision
Employee participation
Production scheduling/planning
Cost accounting/allocation
Provide training for
- Safe operation of the equipment
- Proper materials handling
- Economic and environmental ramif icatbns of
hazardous waste generation and disposal
- Detecting releases of hazardous materials
- Emergency procedures
- Use of safety gear
Closer supervision may improve production efficiency
and reduce inadvertent waste generation
Management by objectives (MBO), with goals for
waste reduction
"Quality circles" (free forums between employees
and supervisors) can identify ways to reduce waste
Solicit employee suggestions for waste reduction ideas
Maximize batch size
Dedicate equipment to a single product
Alter batch sequencing to minimize cleaning frequency
(light-to-dark batch sequence, for example)
Schedule production to minimizing cleaning frequency
Cost accounting done for all waste streams leaving
the facilities
Allocate waste treatment and disposal costs to the
operations that generate the waste
These programs are conducted to reduce
occupational health and safety
hazards, in addition to reducing
waste generation due to operator
or procedural errors.
Increased opportunity for early detection
of mistakes.
Better coordination among the various
parts of an overall operation.
Employees who intimately understand the
operations can identify ways to reduce
waste.
Altering production schedule can have a
major impact on waste minimization.
Allocating costs to the waste-producing
operations will give them an incentive
to cut their wastes.
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Table E-4. Waste Minimization Options in Materials Handling, Storage, and Transfer
Waste/Source
Waste Reduction Measures
Remarks
References
Material/waste tracking and
inventory control
Avoid over-purchasing
Accept raw material only after inspection
Ensure that inventory quantity does not go to
waste
Ensure that no containers stay in inventory
longer than a specified period
Review material procurement specifications
Return expired material to supplier
Validate shelf-life expiration dates
Test outdated material for effectiveness
Eliminate shelf-life requirements for stable
compounds
Conduct frequent inventory checks
Use computer-assisted plant inventory system
Conduct periodic materials tracking
Proper labeling of all containers
Set up manned stations for dispensing
chemicals and collecting wastes
These procedures are employed to find
areas where the waste minimization
efforts are to be concentrated.
30,31
Loss prevention programs
Use properly designed tanks and vessels only for
their intended purposes
Install overflow alarms for all tanks and vessels
Maintain physical integrity of all tanks and vessels
Set up written procedures for all loading/unloading
and transfer operations
Install secondary containment areas
Forbid operators to bypass interlocks, alarms, or
significantly alter setpoints without authorization
Isolate equipment or process lines that leak or are
not in service
Use seal-less pumps
Use bellows-seal valves
Document all spillage
Perform overall material balances and estimate
the quantity and dollar value of all losses
Use floating-roof tanks for VOC control
Use conservation vents tin fixed roof tanks
Use vapor recovery systems
-------
Table E-4. Waste Minimization Options in Materials Handling, Storage, and Transfer (continued)
Waste/Source Waste Reduction Measures Remarks References
Spills and leaks * Store containers in such a way as to albw for
visual inspection for corrosion and leaks
• Stack containers in a way to minimize the chance
of tipping, puncturing, or breaking
• Prevent concrete "sweating* by raising the
drum off storage areas
• Maintain MSDSs to correctly handle spill
situations
* Provide adequate lighting in the storage area
• Maintain a clean, even surface in transportation
areas
• Keep aisles clear of obstruction
» Maintain distance between incompatible chemicals
* Maintain distance between different types of
chemicals to prevent cross-contamination
• Avoid stacking containers against process
equipment
* Follow manufacturers' suggestions on the storage
and handling of all raw materials
* Insulation and inspection of electric circuitry for
corrosion and potential sparking
Cling * Use large containers instead of small containers
whenever possible
* Use containers with height-to-diameter ratio equal
to one to minimize wetted area
* Empty drums and containers thoroughly before
cleaning or disposal
-------
Table E-S. Waste Minimization Options for Parts Cleaning Operations
Waste
Source/Origin
Waste Reduction Measures
Remarks
References
Spent solvent
Contaminated solvent from
parts cleaning operations
Use water-soluble cutting fluids instead
of oil-based fluids
Use peel coatings in place of protective oils
Use aqueous cleaners
Use aqueous paint stripping solutions
Use cryogenic stripping
Use bead blasting for paint stripping
Use multi-stage countercurrent cleaning
Prevent cross-contamination
Prevent drag-in from other processes
Prompt removal of sludge from the tank
Reduce the number of different solvents
used
This could eliminate the need for solvent
cleaning.
A single, larger waste that is more
amenable to recycling.
8
7
6
Air emissions
Solvent toss from
degreasers and cold tanks
Use roll-type covers, not hinged covers
Increase freeboard height
Install freeboard chillers
Use silhouette entry covers
Proper equipment layout
Avoid rapid insertion and removal of items
Avoid inserting oversized objects into
the tank
Allow for proper drainage before removing
item
Avoid water contamination of solvent
in degreasers
24 to 50% reduction in emissions.
39% reduction in solvent emissions.
The speed that items are put into the
tank should be less than 11 feet/min.
Cross-sectional area of the item should
be less that 50% of tank area to reduce
piston effect.
15
15
15
16
17
Rinse water
Water rinse to remove
solvent carried out with
the parts leaving the
cleaning tank
Reduce solvent dragout by proper design and
operation of rack system
Install air jets to blow parts dry
Use fog nozzles on rinse tanks
Proper design and operation of barrel system
Use countercurrent rinse tanks
Use water sprays on rinse tanks
The dragout can be 0.4 gal/1000 sqft,
versus 24 gal/1000 sqft for poorly
drained parts.
More efficient rinsing is achieved.
15
15
15
15
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Appendix E
References
1, Kohl, J., J. Pearson, and P. Wright. Managing and Recycling Solvents In the Furniture Industry.
North Carolina State University, Raleigh, 1986.
2, Lenckus, D. "Increasing productivity". Finishing Wood and Wood Products Magazine. Vol. 87, No.
4, May 1982, pp 44-66.
3. Campbell, M. E., and W. M. Glenn. Profit from Pollution Prevention. The Pollution Probe
Foundation. Toronto, Canada, 1982.
4. Kohl, J., P. Moses, and B. Triplett. Managing and Recycling Solvents: North Carolina Practices.
Facilities, and Regulations. North Carolina State University, Raleigh, 1984.
5. Durney, J. J. "How to improve your paint stripping". Product Finishing. December 1982, pp 52-53.
6. Higgins, T. E. Industrial process Modifications to Reduce Generation of Hazardous Waste at POP
Facitities: Phase I Report. CH2M Hill, Washington, D.C., 1985.
7. "Cryogenic paint stripping". Product Finish. December 1982.
8. Mallarnee, W. M. "Paint and varnish removers". Klrk-Qthmer Encyclopedia of Chemical Technology.
3rd edition, Volume 16, pp 762-767,1981.
9. Sandberg, J. Final Report on the Internship served at Gage Tool Company. Minnesota Technical
Assistance Program, Minnesota Waste Management Board, Minnesota, 1985.
10. Powder Coatings institute. Information brochure. Washington, P. C., 1983.
11. Cole, G. E. "VOC emission reduction and other benefits achieved by major powder coating
operations". Paper No. 84-38.1 presented at the Air Pollution Control Association. June 25,1984.
12. California State Department of Health Services. Alternative Technology for Recycling and.Treatmjnj
of Hazardous Waste. 3rd Biennial Report. Sacramento, 1986.
13. California State Department of Health Services. Guide to Solvent Waste Reduction Alternatives.
October 1986, pp 4-25 to 4-49.
14. Kenson, R. E. "Recovery and reuse of solvents from VOC air emissions". Environmental Progress.
August 1985, pp 161-165.
15. Dumey, L. J., editor. Electroplating Engineering Handbook. 4th edition. Van Nostrand Reinhold,
New York, 1984.
16. American Society of Testing Materials. Handbook of Vapor Degreasing. Special Technical
Publication 310-A., ASTM, Philadelphia, April 1976.
17. Smith, C. Troubleshooting vapor degreasers". Product .Fjnjsjrt. November 1981.
18. Loucks, C. M. "Boosting capacities with chemicals*. Chemical Engineering Deskbook Issue. Vol.
80, No. 5, pp 79-84, 1973.
19. 3M Corporation. Ideas - A Compendium of 3M Success Stories. St. Paul, MN.
-------
20. Fromm, C. H., S. Budaraju, and S. A. Cordery. "Minimization of process equipment cleaning waste".
Conference proceedings of HAZTECH International, Denver, August 13-15,1986, pp 291-307.
21. Versar, Inc. and Jacobs Engineering Group. Waste Minimization: Issues and Options. Vol. II. U. S.
Environmental Protection Agency, Washington, D. C., October 1986.
22. Fromm, C. H. and M. S. Callahan. "Waste reduction audit procedure". Conference proceedings of
the Hazardous Materials Control Research Institute. Atlanta, 1986, pp 427-435.
23. North Carolina Pollution Prevention Pays Program. Environmental Auditing. North Carolina
Department of Environmental Health. 1985.
24. Baumer, R. A. Making environmental audits". Chemical Engineering. Vol. 89, No. 22. November 1,
1982,p 101.
25. Kletz, T. A. "Minimize your product spillage". Hydrocarbon Processing. Vol. 61, No. 3,1982, p 207.
26. Sarokin, D. "Reducing hazardous wastes at the source: Case studies of organic chemical plants in
New Jersey. Paper presented at Source Reduction of Hazardous Waste Conference, Rutgers
University, August 22,1985.
27. Singh, J. B. and R. M. Allen. "Establishing a preventive maintenance program". Plant Engineering.
February 27,1986, p 46.
28. Rimberg, D. "Minimizing maintenance makes money". Pollution Engineering. Vol. 12, No. 3,
December 1983, p 46.
29. Parker, N. H. "Corrective maintenance and performance optimization". Chemical Engineering. Vol.
91, No. 7, April 16,1984, p93.
30. Geltenan, E. "Keeping chemical records on track". Chemical Business. Vol. 6, No. 11,1984, p 47.
31. Hickman, W. E. and W. D. Moore. "Managing the maintenance dollar". Chemical Engineering. Vol.
93, No. 7, April 24,1986, p 68.
-------
Appendix F
Government Technical/Financial Assistance Programs
The EPA's Office of Solid Waste and Emergency Response has set up a telephone call-in service to answer
questions regarding RCRA and Superfund (CERCLA):
(800) 424-9346 (outside the District of Columbia)
(202) 382-3000 (in the District of Columbia)
The following states have programs that offer technical and/or financial assistance in the areas of waste
minimization and treatment.
Alabama
Hazardous Material Management and Resource
Recovery Program
University of Alabama
P.O. Box 6373
Tuscaloosa, AL 35487-6373
(205) 348-8401
Alaska
Alaska Health Project
Waste Reduction Assistance Program
431 West Seventh Avenue, Suite 101
Anchorage, AK 99501
(907)276-2864
Arkansas
Arkansas Industrial Development Commission
One State Capitol Mall
Little Rock, AR 72201
(501)371-1370
California
Alternative Technology Section
Toxic Substances Control Division
California State Department of Health Services
714/744 P Street
Sacramento, CA 94234-7320
(916)324-1807
Connecticut
Connecticut Hazardous Waste Management Service
Suite 360
900 Asylum Avenue
Hartford, CT 06105
(203) 244-2007
Connecticut Department of Economic Development
210 Washington Street
Hartford CT 06106
(203)566-7196
Georgia
Hazardous Waste Technical Assistance Program
Georgia Institute of Technology
Georgia Technical Research Institute
Environmental Health and Safety Division
O'Keefe Building, Room 027
Atlanta, GA 30332
(404)894-3806
Georgia (continued)
Environmental Protection Division
Georgia Department of Natural Resources
Royd Towers East, Suite 1154
205 Butler Street
Atlanta, CA 30334
(404) 656-2833
Illinois
Hazardous Waste Research and Information Center
Illinois Department of Energy and Natural Resources
1808 Woodfield Drive
Savoy, IL61874
(217)333-8940
Illinois Waste Elimination Research Center
Pritzker Department of Environmental Engineering
Alumni Building, Room 102
Illinois Institute of Technology
3200 South Federal Street
Chicago, IL 60616
(312)567-3535
Indiana
Environmental Management and Education Program
Young Graduate House, Room 120
Purdue University
West Lafayette, IN 47907
(317)494-5036
Indiana Department of Environmental Management
Office of Technical Assistance
P.O. Box 6015
105 South Meridian Street
Indianapolis, IN 46206-6015
(317)232-8172
Iowa
Iowa Department of Natural Resources
Air Quality and Solid Waste Protection Bureau
Wallace State Office Building
900 East Grand Avenue
Des Moines, IA 50319-0034
(515)281-8690
Center for Industrial Research and Service
205 Engineering Annex
Iowa State University
Ames, IA 50011
(515) 294-3420
-------
Kansas
Bureau of Waste Management
Department of Health and Environment
Forbes Field, Building 730
Topeka, KS 66620
(913)296-1607
Kentucky
Division of Waste Management
Natural Resources and Environmental Protection Cabinet
18 Reilly Road
Frankfort, KY 40601
(502)564-6716
Louisiana
Department of Environmental Quality
Office of Solid and Hazardous Waste
P.O. Box 44307
Baton Rouge, LA 70804
(504)342-1354
Maryland
Maryland Hazardous Waste Facilities Siting Board
60 West Street, Suite 200A
Annapolis, MD 21401
(301)974-3432
Maryland Environmental Service
2020 Industrial Drive
Annapolis, MD 21401
(301)269-3291
(800) 492-9188 (in Maryland)
Massachusetts
Office of Safe Waste Management
Department of Environmental Management
100 Cambridge Street, Room 1094
Boston, MA
(617)727-3260
Source Reduction Program
Massachusetts Department of Environmental Quality
Engineering
1 Winter Street
Boston, MA 02108
(617)292-5982
Michigan
Resource Recovery Section
Department of Natural Resources
P.O. Box 30028
Lansing, Ml 48909
(517)373-0540
Minnesota
Minnesota Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Road
St. Paul, MN 55155
(612)296-6300
Minnesota (continued)
Minnesota Technical Assistance Program
W-140 Boynton Health Service
University of Minnesota
Minneapolis, MN 55455
(612) 625-9677
(800) 247-0015 (in Minnesota)
Minnesota Waste Management Board
123 Thorson Center
7323 Fifty-Eighth Avenue North
Crystal, MN 55428
(612)536-0816
Missouri
State Environmental Improvement and Energy
Resources Agency
P.O. Box 744
Jefferson City, MO 65102
(314)751-4919
New Jersey
New Jersey Hazardous Waste Facilities Siting
Commission
Room 614
28 West State Street
Trenton, NJ 08608
(609)292-1459
(609)292-1026
Hazardous Waste Advisement Program
Bureau of Regulation and Classification
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
Risk Reduction Unit
Office of Science and Research
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
New York
New York State Environmental Facilities Corporation
50 Wolf Road
Albany, NY 12205
(518) 457-3273
North Carolina
Pollution Prevention Pays Program
Department of Natural Resources and Community
Development
P.O. Box 27687
512 North Salisbury Street
Raleigh, NC 27611
(919)733-7015
Governor's Waste Management Board
325 North Salisbury Street
Raleigh, NC 27611
(919) 733-9020
-------
North Caroling (continued)
Technical Assistance Unit
Solid and Hazardous Waste Management Branch
North Carolina Department of Human Resources
P.O. Box 2091
306 North Wilmington Street
Raleigh. NC 27602
(919)733-2178
Ohio
Division of Solid and Hazardous Waste Management
Ohio Environmental Protection Agency
P.O. Box 1049
1800 WaterMark Drive
Columbus, OH 43266-1049
(614)481-7200
Ohio Technology Transfer Organization
Suite 200
65 East State Street
Columbus, OH 43266-0330
(614)466-4286
Oklahoma
Industrial Waste Elimination Program
Oklahoma State Department of Health
P.O. Box 53551
Oklahoma City, OK 73152
(405)271-7353
Oregon
Oregon Hazardous Waste Reduction Program
Department of Environmental Quality
811 Southwest Sixth Avenue
Portland, OR 97204
(503)229-5913
Pennsylvania
Pennsylvania Technical Assistance Program
501 F. Orvis Keller Building
University Park, PA 16802
(814)865-0427
Bureau of Waste Management
Pennsylvania Department of Environmental Resources
P.O. Box 2063
Fulton Building
3rd and Locust Streets
Harrisburg, PA17120
(717)787-6239
Center of Hazardous Material Research
320 William Pitt Way
Pittsburgh, PA 15238
(412)826-5320
Rhode Island
Ocean State Cleanup and Recycling Program
Rhode Island Department of Environmental Management
9 Hayes Street
Providence, Rl 02908-5003
(401)277-3434
(800) 253-2674 (in Rhode Island)
Rhode Island (continued)
Center of Environmental Studies
Brown University
P.O. Box 1943
135 Angell Street
Providence, RI02912
(401)863-3449
Tennessee
Center for Industrial Services
102 Alumni Hall
University of Tennessee
Knoxvilie, TN 37996
(615) 974-2456
Virginia
Office of Policy and Planning
Virginia Department of Waste Management
11th Floor, Monroe Building
101 North 14th Street
Richmond, VA 23219
(804) 225-2667
Washington
Hazardous Waste Section
Mail Stop PV-11
Washington Department of Ecology
Olympia, WA 98504-8711
(206)459-6322
Wisconsin
Bureau of Solid Waste Management
Wisconsin Department of Natural Resources
P.O. Box 7921
101 South Webster Street
Madison, WI53707
(608) 266-2699
Wyoming
Solid Waste Management Program
Wyoming Department of Environmental Quality
Herschler Building, 4th Floor, West Wing
122 West 25th Street
Cheyenne, WY 82002
(307) 777-7752
-------
Appendix G
Option Rating
Weighted Sum Method
The Weighted Sum Method is a quantitative method
for screening and ranking waste minimization options.
This method provides a means ol quantifying the
important criteria that affect waste management in a
particular facility. This method involves three steps.
1. Determine what the important criteria are in terms
of the WM assessment program goals a
constraints, and the overall corporate goats an
constraints. Examples of criteria are the following:
* Reduction in waste quantity
• Reduction in waste hazard (e.g., toxiclty,
flammabilrty, reactivity, corrosivity, etc.)
• Reduction in waste treatment/disposal costs
• Reduction in raw material costs
• Reduction in liability and insurance costs
« Previous successful use within the company
» Previous successful use in Industry
» Not detrimental to product quality
• Low capital cost
• Low operating and maintenance costs
* Short implementation period (and minimal
disruption of plant operations)
• Ease of implementation
The weights (on a scale of 0 to 10, for example) are
determined for each of the criteria in relation to
their importance.For example, if reduction in waste
treatment and disposal costs are very important,
while previous successful use within the company
is of minor importance, then the reduction in waste
costs is given a weight of 10 and the previous use
within the company is given a weight of 1 or 2.
Criteria that are not important are not included (or
given a weight of 0).
2. Each option is then rated on each of the criteria.
Again, a scale of 0 to 10 can be used (0 for low and
10 for high).
3. Finally, the rating of each option from particular
criteria is multiplied by the weight of the criteria. An
option's overall rating is the sum of the products of
rating times the weight of the criteria.
The options with the best overall ratings are then
selected for the technical and economic feasibility
analyses. Worksheet 13 in Appendix A is used to rate
options using the Weighted Sum method. Table Q-1
presents an example using the Weighted Sum Method
for screening and ranking options.
Tabla G-1. Sample Calculation using the
Weighted Sum Method
ABC Corporation has determined that reduction in waste
treatment costs is the most important criterion, with a weight
factor of 10. Other significant criteria include reduction in
safety hazard (weight of 8), reduction in liability (weight of 7),
and ease of implementation (weight of 5). Options X, Y, and
Z are then each assigned effectiveness factors. For
example, option X is expected to reduce waste by nearly
80%, and is given an rating of 8. tt is given a rating of 6 for
reducing safety hazards, 4 for reducing liability, and
because it is somewhat difficult to implement, 2 for ease of
implementation. The table below shows how the options are
rated overall, with effectiveness factors estimated for
options Y and Z.
Patinas for each cotton
Rating Criteria
Reduce treatment costs
Reduce safety hazards
Reduce liability
Ease of implementation
Sum of weight times ratings
Weight
10
8
7
5
X Y Z
863
638
445
228
166 122 169
From this screening, option Z rates the highest with a score
of 169. Option X's score is 166 and option Y's score is 122.
In this case, option Z and option X should both be selected
for further evaluation because both of their scores are high
and relatively close to each other.
-------
Appendix H
Economic Evaluation Example
The following example presents a profitability analysis
for a relatively large hypothetical waste minimization
project. This project represents the installation of a
package unit that improves plant production while
reducing raw material consumption and disposal costs.
The analysis was done on a personal computer using a
standard spreadsheet program. The salient data used
in this evaluation are summarized below.
Capital Costs
* The delivered price of the equipment is quoted by
the vendor at $170,000. This includes taxes and
insurance.
* Materials costs (piping, wiring, and concrete) are
estimated at $35,000.
• Installation labor is estimated at $25,000.
* Internal engineering staff costs are estimated at
$7,000. Outside consultant and contractor costs
are estimated at $15,000.
• Miscellaneous environmental permitting costs are
estimated at $15,000.
* Working capital (including chemical inventories, and
materials and supplies) Is estimated at $5,000.
• Start-up costs are estimated by the vendor at
$3,000.
* A contingency of $20,000 for unforeseen costs
and/or overruns is included.
* Planning, design, and installation are expected to
take one year.
Financing
• The project will be financed 60% by retained
earnings and 40% by a bank loan.
* The bank loan will be repaid over 5 years of equal
installments of principal, plus interest at an annual
percentage rate of 13%. Interest accrued during
installation will be added into the total capital costs.
* All capital costs, except working capital and interest
accrued during construction, will be depreciated
over 7 years using the double-declining balance
method, switching to the straight-line method when
the charges by this method become greater.
* The marginal income tax rate is 34%.
• Escalation of all costs is assumed to be 5% per year
for the life of the project.
» The firm's cost of capital is 15%.
Operating Costs and Revenues
* The WM project is estimated to decrease raw
materials consumption by 300 units per year at a
cost of $50 per unit. The project will not result in an
increased production. However, it will produce a
marketable by-product to be recovered at a rate of
200 units per year and a price of $25 per unit.
* The project will reduce the quantity of hazardous
waste disposed by 200 tons per year. The following
items make the total unit disposal costs:
Costs per ton of waste
Offsite disposal fees $500
State generator taxes 10
Transportation costs 25
Other costs 25
TOTAL DISPOSAL COSTS $560
* Incremental operating labor costs are estimated on
the basis that the project is expected to require one
hour of operator's time per eight-hour shift. There
are three shifts per day and the plant operates 350
days per year. The wage rate for operators is
$12.50 per hour.
- Operating supplies expenses are estimated at 30%
of operating labor costs.
* Maintenance labor costs are estimated at 2% of the
sum of the capital costs for equipment, materials,
and installation. Maintenance supplies costs are
estimated at 1% of these costs.
• Incremental supervision costs are estimated at 30%
of the combined costs of operating and
maintenance labor.
• The following overhead costs are estimated as a
percentage of the sum of operating and
maintenance labor and supervision costs.
Labor burden and benefit 28%
Plant overhead 25%
Headquarter overhead 20%
-------
• Escalation of all costs is assumed to be 5% per year
for the life of the project.
* The project life is expected to be 8 years.
* The salvage value of the project is expected to be
zero after eight years.
Results
The four-page printout In Figures H-1 through H-4
presents the WM project profitability spreadsheet
program. Figure H-1 represents the input section of
the program. Each of the numbers in the first three
columns represents an input variable in the program.
The righthand side of Figure H-1 is a summary of the
capital requirement. This includes a calculation of the
interest accrued during construction and the financing
structure of the project.
Figure H-2 is a table of the revenues and operating
cost Hems for each of the eight years of the project's
operating life. These costs are escalated by 5% each
year for the life of the project.
Figure H-3 presents the annual cash flows for the
project. The calculation of depreciation charges and
the payment of interest and repayment of loan principal
is also shown here. The calculation of the internal rate
of return (IRR) and the net present value {NPV) are
based on the annual cash flows. Since the project is
leveraged (financed partly by a bank loan), the equity
portion of the investment is used as the initial cash
flow. The NPV and the IRR are calculated on this basis.
The IRR calculated this way is referred to as the "return
on equity". The program is structured to present the
NPV and IRR after each year of the project's operating
life. In the example, after six years, the IRR is 19.92%
and the NPV is $27,227.
Figure H-4 is a cash flow table based entirely on equity
financing. Therefore, there are no interest payments
or deb principal repayments. The NPV and the IRR in
this case are based on the entire capital investment in
the project. The IRR calculated this way is referred to
as the "return on investment".
The results of the profitability analysis for this project
are summarized below:
Method of Financing PR APV
60% equity/40% debt 26.47% $84,844
100% equity 23.09% $81,625
The IRR values are greater than the 15% cost of
capital, and the NPVs are positive. Therefore, the
project is attractive, and should be implemented.
-------
Waste Minimization
Profitability Program
Capital Cost Factors
Capital Cost
Equipment
Materials
Installation
Plant Engineering
Contractor/Engineering
Permitting Costs
Contingency
Working Capital
Start-up Costs
% Equity
%Debt
Interest Rate on Debt, %
Debt Repayment, years
Depreciation period
Income Tax Rate, %
Escalation Rates, %
Cost of Capital (for NPV)
$170,000
$35,000
$25,000
$7,000
$15,000
$15,000
$20,000
$5,000
$3,000
60%
40%
13.00%
5
7
34,00%
S.0%
15.00%
started 5/22*7
last changed 8/1/87
WPUT
Operating Cost/Revenue Factors
Increased Production
Increased Rate, units/year
Price, $/unit
Marketable By-products
Rate, units/year
Price, $/unit
Decreased Raw Materials
Decreased Rate, units/year
Price, $/unit
Decreased Waste Disposal
Reduced Waste, tons/year
Offsrte Fees, $/ton
State Taxes, $/ton
Transportation! $/ton
Other Disposal Costs, $/ton
Total Disposal Costs, $Aon
0
$100
200
$40
300
$50
200
$500
$10
J25
$25
$560
Operating Labor
Operator hours/shift
Shifts/day
Operating days/year
Wage rate, $/man-hour
Operating Supplies
(% of Operating Labor)
Maintenance Costs
(% of Capital Costs)
Labor
Materials
Other Labor Costs
(% of O&M Labor)
Supervision
(% of O&M Labor + Sue
Plant Overhead
Home Office Overhead
Labor Burden
1
3
350
$13.50
30%
2.00%
1.00%
30.0%
ervision
25.0%
20.0%
28.0%
CAPITAL REQUIREMENT
Construction Year
Capital Expenditures
Equipment
Materials
Installation
Plant Engineering
Contractor/Engineering
Permitting Costs
Contingency
Start-up Costs
Depreciable Capital
Working Capital
Subtotal
Interest on Debt
Total Capital Requirement
Equity Investment
Debt Principal
Interest on Debt
Total Financing
1
$170,000
$35,000
$25,000
$7,000
$15,000
$15,000
$20,000
$3,000
$290,000
$5,000
$295,000
$14,230
$309,230
$185,538
'$10i,462
$14,230
$309,230
Figure H-1. Input Information and Capital Investment
-------
REVENUE AND COST FA<
Operating Year Number
Escalation Factor
INCREASED REVENUES
Increased Production
Marketable By-products
Annual Revenue
OPERATING COST/SAW
Raw Materials
Disposal Costs
Maintenance Labor
Maintenance Supplies
Operating Labor
Operating Supplies
Supervision
Labor Burden
Plant Overhead
Home Office Overhead
Total Operating Costs
JTORS
1,000
4GS
1
1.050
$0
$8.400
$8.400
$15.750
$117.600
($4.830)
($2.415)
($14,884)
($4.465)
($5.914)
($7.176)
($6.407)
($5.126)
$82.133
2
1.103
$0
$8.824
$8.824
$16.545
$123,536
($5.074)
($2.537)
($15.635)
($4.691)
($6.213)
($7.538)
($6.731)
($5.384)
$86.278
3
1.158
$0
$9,264
$9,264
$17.370
$129.696
($5.327)
($2,663)
($16,415)
($4.925)
($6.523)
($7.914)
($7,066)
($5.653)
$90.580
4
1.216
$0
$9,728
$9,728
$18,240
$136.192
($5.594)
($2.797)
($17,237)
($5,171)
($6.849)
($8,310)
($7.420)
($5.936)
$95,118
5
1.277
$0
$10.216
$10.216
$19.155
$143,024
($5.874)
($2.937)
($18.101)
($5.430)
($7,193)
($8,727)
($7,792)
($6.234)
$99.891
6
1.341
$0
$10^728
$10,728
$20,115
$150,192
($6,169)
($3.084)
($19,009)
($5.703)
($7.553)
($9.165)
($8,183)
($6.546)
$104,895
7
1.408
$0
$11.264
$11.264
$21.120
$157,696
($6,477)
($3,238)
($19,958)
($5.987)
($7.931)
($9.622)
($8,592}
($6,873)
$110,138
8
1.478
$0
$11.824
$11,824
$22,170
$165,536
($6.799)
($3,399)
($20.951)
($6.285)
($8.325)
($10,101)
($9,019)
($7215)
$115,612
Figure H-2. Revenues and Operating Costs
-------
RETURN ON EQUITY/RET
Construction Year
Operating Year
Book Value
Depreciation (by straight-!
Depreciation (by doubleDI
Depreciation
Debt Balance
Interest Payment
Principal Repayment
CASHFLOWS
Construction Year
Operating Year
Revenues
+ Operating Savings
Net Revenues
- Depreciation
- Interest on Debt
Taxable Income
- Income Tax
Profit after Tax
+ Depreciation
- Debt Repayment
After-Tax Cash Row
Cash Flow for ROE
Net Present Value
Return on Equity
26.47%
URN ON ASSETS
1
$290,000
ne)
!)
$123,692
1
($185,538)
($185,538)
1
$207.143
$41,429
$82,857
$82,857
$123.692
$16.080
$24,738
1
$8,400
$82,133
$90.533
$82.857
$16,080
($8,404)
($2,857)
($5,547)
$82.857
$24,738
$52,572
$52,572
($139,823)
#NUM!
2
$147,959
$41,429
$59,184
$59.184
$98.954
$12.864
$24,738
2
$8,824
$86,278
$95,102
$59,184
$12,864
$23,054
$7,838
$15,216
$59,184
$24.738
$49.662
$49,662
($102,272)
-32.19%
3
$105,685
$41,429
$42.274
$42.274
$74,216
$9,648
$24,738
3
$9,264
$90,580
$99,844
$42.274
$9.648
$47,922
$16,293
$31.629
$42.274
$24.738
$49,165
$49,165
($69,945)
-9.62%
4
$64,256
$41,429
$30,196
$41,429
$49,478
$6,432
$24,738
4
$9,728
$95,118
$104,846
$41.429
$6.432
$56,985
$19,375
$37,610
$41,429
$24,738
$54,301
$54,301
($38,898)
4.24%
5
$22,827
$41,429
$18,359
$41,429
$24.740
$3,216
$24,738
5
$10,216
$99,891
$110,107
$41,429
$3,216
$65,462
$22,257
$43,205
$41,429
$24,738
$59,896
$59,896
($9,119)
12.95%
6
$0
$41,429
$6,522
$22,827
$2
$0
$2
6
$10,728
$104,895
$115,623
$22,827
$0
$92,796
$31.551
$61.245
$22,827
$2
$84,070
$84,070
$27,227
19.92%
7
$0
$0
$0
$0
$0
$0
$0
7
$11,264
$110,138
$121,402
$0
$0
$121,402
$41,277
$80,125
$0
$0
$80.125
$80,125
$57.349
23.85%
8
$0
$0
$0
$0
$0
$0
$0
8
$11,824
$115,612
$127J436
$0
$0
$127,436
$43,328
$84,108
$0
$0
$84,108
$84,108
$84,844
26.47%
Figure H-3. Cash Rows for Return on Equity
-------
HE lum ON MVBS1MEN
Construction Year
Operating Year
Book Value
Depreciation (by straight-)
Depreciation (by double C
Depreciation
CASHFLOWS
Construction Year
Operating Year
Revenues
+ Operating Savings
Net Revenues
- Depreciation
Taxable Income
- Income Tax
Profit after Tax
+ Depreciation
After-Tax Cash Flow
Cash Flow for ROI
Net Present Value
Return on Investment
23.09%
1
$290,000
ne)
B)
1
($295.000)
($295,000)
1
$207,143
$41.429
$82.857
$82.857
1
$8,400
$82.133
$90,533
$82,857
$7.676
$2.610
$5,066
$82.857
$87,923
$87,923
($218.545)
#NUMI
2
$147.959
$41,429
$59.184
$59.184
2
$8,824
$86,278
$95.102
$59.184
$35.918
$12.212
$23.706
$59.184
$82.890
$82.890
($155.868)
-30.04%
3
$105.685
$41,429
$42,274
$42.274
3
$9.264
$90,580
$99,844
$42,274
$57,570
$19.574
$37.996
$42,274
$80,270
$80,270
($103.090)
-7.76%
4
$64.256
$41.429
$30.196
$41.429
4
$9.728
$95.118
$104,846
$41,429
$63,417
$21.562
$41.855
$41.429
$83.284
$83,284
($55.472)
5.26%
5
$22.827
$41.429
$18,359
$41.429
5
$10.216
$99.891
$110.107
$41,429
$68,678
$23.351
$45.327
$41.429
$86.756
$86,756
($12.339)
13.21%
6
$0
$41,429
$6,522
$22.827
6
$10.728
$104.895
$115,623
$22.827
$92.796
$31,551
$61.245
$22.827
$84.072
$84.072
$24,008
17.99%
7
$0
$0
$0
$0
7
$11,264
$110,138
$121.402
$0
$121,402
$41,277
$80.125
$0
$80.125
$80.125
$54.130
20.97%
8
$0
$0
$0
$0
8
$11.824
$115.612
$127,436
$0
$127.436
$43,328
$84.108
$0
$84.108
$84.108
$81.625
23.09%
Figure H-4. Cash Flows for Return on Investment
-------
&EPA
United States
Environmental Protection
Agency
Office of Research and
Development
Washington, DC 20460
EPA/600/R-92/088
May 1992
Facility Pollution
Prevention
-------
TABLE OF CONTENTS
Page
INTRODUCTION 1
A. PURPOSE OF GUIDANCE 1
B. GUIDANCE SCOPE AND OBJECTIVES 1
II. GRADED APPROACH 3
A. INTRODUCTION 3
B. GRADED APPROACH LOGIC DIAGRAM & PRIORITY LIST 3
C. LEVEL I - ACTIVITY CHARACTERIZATION 5
D. GRADED APPROACH WEIGHTED SUMS EVALUATION 6
E. LEVEL II - INFORMAL ASSESSMENT 7
F. LEVEL III - FORMAL ASSESSMENT 9
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT TEAMS 10
IV. ASSESSMENT OF PROCESSES AND WASTE STREAMS 11
A. INITIAL DATA GATHERING 11
B. PROCESS DESCRIPTION 11
C. PROCESS FLOW DIAGRAM 12
D. MATERIAL BALANCES 13
E. MEASUREMENT OF WASTE 14
F. WASTE STREAM CHARACTERIZATION 15
V. DEVELOPMENT AND EVALUATION OF WASTE
MINIMIZATION/POLLUTION PREVENTION OPTIONS 15
A. IDENTIFICATION OF WMIN/PP OPTIONS 15
B. PRELIMINARY SCREENING OF WMIN/PP OPTIONS 16
C. EVALUATION OF WMIN/PP OPTIONS 17
VI. FINAL REPORT 18
VII. APPENDIX 19
-------
APPENDIX
APPENDIX A: GENERAL CONSIDERATIONS FOR PRIORITIZING THE
ASSESSMENT OF WASTE STREAMS
APPENDIX B: SOURCES OF MATERIAL BALANCE INFORMATION
APPENDIX C: LEVEL I EXAMPLE ACTIVITY CHARACTERIZATION
APPENDIX D:
PPOA GRADED APPROACH WEIGHTED SUMS FORM, CRITERIA,
AND INSTRUCTIONS
APPENDIX E: LEVEL II EXAMPLE INFORMAL ASSESSMENT
APPENDIX F: LEVEL III EXAMPLE FORMAL ASSESSMENT
APPENDIX G:
MODEL POLLUTION PREVENTION OPPORTUNITY
ASSESSMENT WORKSHEETS
APPENDIX H: REFERENCES
FIGURES
FIGURE 1:
FIGURE 2:
FIGURE 3:
PPOA FLOW CHART
PPOA GRADED APPROACH LOGIC DIAGRAM
PPOA GRADED APPROACH WEIGHTED SUMS EVALUATION
-------
LIST OF ACRONYMS
ACGIH
DOE
EPA
ES&H
MNCAW
MSDS
NPDES
ODC
OSHA
PCB
PM/WSL
POTW
PPOA
PWA
VOC
WMin/PP
American Conference of Governmental Industrial Hygienists
Department of Energy
Environmental Protection Agency
Environmental, Safety, & Health
Materials Not Categorized As Waste
Material Safety Data Sheet
National Pollutant Discharge Elimination System
Ozone Depleting Compound
Occupational Safety and Health Administration
Polychlorinated biphenyl
Priority Material/Waste Stream List
Publicly Owned Treatment Works
Pollution Prevention Opportunity Assessment
Process Waste Assessment
Volatile Organic Compound
Waste Minimization/Pollution Prevention
-------
ACKNOWLEDGMENT
In July, 1988, DOE Defense Programs recognized the need for a waste minimization
program that would focus beyond pollution control and the traditional media-by-media
approach to containment and treatment of environmental releases. Defense Programs
was proactive in initiating a Waste Minimization Program that included the completion of
process waste assessments as a means to identify opportunities which would reduce
the generation of waste.
The Waste Minimization Program evolved to a Pollution Prevention Program through the
auspices of the DOE Defense Programs' Pollution Prevention Strategic Plan issued in
April, 1992. The Strategic Plan reiterated the hierarchy of preferred environmental
practices outlined in the Pollution Prevention Act of 1990 (i.e. source reduction,
recycling, treatment, and finally, disposal).
The first Model PWA Guidance was assembled by Defense Programs' contractors
based on the published EPA guidance and previous work performed at the Y-12 Plant.
The manual was originally issued in February 1990, and distributed throughout the
Weapons Complex. This is the first revision to the document, and it replaces the term
"PWA" with a more positive term, "Pollution Prevention Opportunity Assessment". The
new term avoids the implication that assessments should be limited to process wastes,
rather, they should address all releases.
The following DOE personnel and DOE contractors assisted in the suggestions for this
revision. Their time and effort were greatly appreciated.
Frank Adams
EG&G Mound
Don Adoiphson
Sandia National Labs/CA
Doyle Anderson
Raytheon Serv - Nevada
Carl Barr
Westinghouse - Hanford
Angela Bolds
Martin Marietta - Pinellas
Angela Colarusso
DOE/DP - Nevada
Paul Deltete
Analytical Resources Inc.
Cindy Dutro
Reynolds Elect & Eng Co.
George Goode
Brookhaven National Lab
Kent Hancock
DOE/EM-352
Jim Henderson
Raytheon Serv - Nevada
Diana Hovey-Spencer
Desert Research Institute
Dr. Roger Jacobson
Univ & Com Coll - Nevada
Alice Johnson-Duarte
Sandia National Labs/CA
Ed Kjeldgaard
Sandia National Labs/NM
John Marchetti
DOE/DP-64
Elizabeth McPherson
McPherson Env. Resources
Susan Pemberton
AlliedSignal Inc., KCP
Bill SchFosberg
AlliedSignal Inc., KCP
Don Watson
AlliedSignal Inc., KCP
Jill watz
Strategic Env. Services
Jeff Weinrach
Los Alamos National Lab
A point of contact has been established in the DOE complex for Pollution Prevention Opportunity
Assessments. If you are in need of training, assistance, and/or methodology, call or fax your
requests or questions to the following:
Susan Pemberton
AlliedSignal Inc., Kansas City Plant
D/837 2C43
P.O. Box419159
Kansas City, Mo 64141-6159
816-997-5435 (Phone)
816-997-2049 (Fax)
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1. INTRODUCTION
A. PURPOSE OF GUIDANCE
The purpose of this document is to provide a guide for DOE sites to conduct pollution
prevention opportunity assessments (PPOAs), commonly known through the DOE as
process waste assessments (PWAs). This will avoid the implication that assessments
should be limited to process wastes - PPOAs address all releases. This guidance
describes those activities and methods that can be employed to characterize all waste
generating processes and identifies opportunities to reduce or eliminate waste
generation. The document also includes a methodology to evaluate proposed
modifications to site processes and other options to minimize waste and prevent
pollution.
B. GUIDANCE SCOPE AND OBJECTIVES
PPOAs will be conducted as part of an ongoing program to identify opportunities to
eliminate or reduce the generation of waste. A PPOA documents the amount of material
that is disposed of as waste during operations. It provides a summary of material usage,
process by-products, and waste generation; and it targets those processes and
operations that need to be improved or replaced to promote waste minimization and
pollution prevention. The assessment also establishes a basis to prioritize modifications
to site processes or other pollution prevention options that are developed during the
assessment.
The objective of a PPOA is to document a facility's processes, operating procedures,
and waste streams in a manner that will permit the identification of the best
improvements to avoid or minimize waste generation. This guide shall not be used as
an audit tool. The assessment consists of a systematic approach which may include the
following:
GRADED APPROACH LEVEL DETERMINATION
ORGANIZATION OF PPOA TEAMS
ASSESSMENT OF PROCESSES AND WASTE STREAMS
DEVELOPMENT AND EVALUATION OF POLLUTION PREVENTION
OPTIONS
RECOMMENDATIONS OF POLLUTION PREVENTION OPTIONS & FINAL
REPORT
A step-by-step process for completing a PPOA is shown in Figure 1. These steps are
sequential and should be performed in that order for best results.
-------
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
FLOW CHART
FIGURE 1
PLANNING & ORGANIZATION
•
*
ORGANIZE ASSESSMENT TEAM
REVIEW PPOA GUIDANCE
PROCESS ASSESSMENT
*
•
•
•
*
COLLECT & COMPILE DATA
DEVELOP PROCESS DESCRIPTION
GENERATE FLOW DIAGRAM
CALCULATE MATERIAL BALANCE
SUMMARIZE WASTES & COSTS
OPTION GENERATION & EVALUATION
GENERATE AND SELECT OPTIONS
EVALUATE OPTIONS
PPOA FINAL REPORT
•
*
*
SUMMARIZE PROCESS ASSESSMENT
RECOMMEND FEASIBLE OPTIONS
IDENTIFY FUNDING REQUIREMENTS TO
IMPLEMENT OPTIONS
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-------
II. GRADED APPROACH
A. INTRODUCTION
The DOE Complex is comprised of numerous sites located in many different states.
These facilities range from single-mission to multiple-disciplinary facilities, and vary in
size from quite small to very large. The facilities as a whole represent a tremendous
diversity of technologies, processes and activities. Due to this diversity, there is also a
wide variety and number of waste streams generated. Many of these waste streams are
small and intermittent, and not of consistent composition. The value added of detailed
analysis for individual, small waste streams is often not sufficient to justify the cost, nor is
the analysis necessarily meaningful since many of these waste streams are constantly
changing.
Although waste minimization activities have been implemented at DOE sites, these
efforts are not being sufficiently documented. A DOE survey of PPOA activities across
several sites indicated that these waste minimization practices need to be documented
so that waste generation baselines can be more accurately established. Furthermore,
the documentation can ensure that the site receives credit for accomplishing waste
minimization.
The PPOA Graded Approach addresses these complexities and recognizes that
processes vary in the quantity of pollution they generate, as well as in the perceived risk
and hazards associated with an operation. It also recognizes the variance due to the
cost and function of the final product. Therefore, the graded approach is intended to
provide a cost-effective and flexible methodology which allows individual sites to
prioritize their local concerns and align their efforts with the resources allocated, while
also providing some consistency throughout the DOE to perform PPOAs. In order to
achieve this, the approach has defined three levels of effort to satisfy the requirement of
completing a PPOA. This section documents the minimum amount of effort required,
Level I, Activity Characterization, and provides a systematic approach using the
Weighted Sums Evaluation to determine if additional and more detailed analysis should
be conducted for either a Level II, Informal Assessment, or a Level III, Formal
Assessment.
If used properly, the graded approach will allow a site to concentrate its shrinking
resources on the most important waste problems first. While all of the site's waste
streams and processes will be assessed, the most critical areas will be assessed first
and to the greatest extent.
B. GRADED APPROACH LOGIC DIAGRAM & PRIORITY MATERIAL
/WASTE STREAM LIST
Figure 2, the Graded Approach Logic Diagram, illustrates graphically how the graded
approach methodology works. The diagram starts at the top with the Level I, minimum
effort assessment and works down to an informal and/or formal assessment. The
methodology shown in the logic diagram allows flexibility and provides a consistent
-------
FIGURE 2
Pollution Prevention Graded Approach
Logic Diagram
Level I
Activity Characterization
Activity
Enters
Does Process
Use or Generate a
Priority Listed Material
j>r Waste Stream?,
Yes
Apply Weighted
Sums Criteria
Yes
Level III
Formal Assessment
No
Level I-STOP!
Assessment Completed
I As Priority or
Facility Needs
I Change
I
Weighted Sums Score
Higher than xxx?
Level II
Informal Assessment
-------
structure. A site must develop the priority material / waste stream list (PM/WSL) to use
the graded approach. This list is not limited to the requirements specified below but can
include any other additional concerns. (See Appendix A for an additional list of
considerations.) The priority list provides the site an opportunity to identify their
individual regulatory and/or prioritized needs to cost-effectively determine if additional,
more detailed analysis is necessary. DOE has established requirements and
suggestions for this list as follows.
PRIORITY MATERIAL / WASTE STREAM LIST
Required or Mandatory PM/WSL:
• Waste of any amount for which an approved disposal method does not exist
(i.e., mixed wastes, classified waste, etc.)
• Waste which is equal to 5% or more of the facility's total waste stream (Total
waste = Manifest records (Hazardous) + Radioactive + Mixed)
• Clean Air Act, Class I Materials (ODCs - Ozone Depleting Compounds)
• EPA's 33/50 Materials
• Known Human Carcinogens (ACGIH, Type 1)
Suggested Additions to PM/WSL:
• Federal, State, & Local Requirements
» Permitted Waste & Materials (e.g., VOCs, NPDES, POTW, etc.)
• Site Health Risks for Hazardous Materials & Hazardous Wastes (e.g., OSHA -
Suspect carcinogens, teratogens, explosives, PCBs, Asbestos, etc.)
• Municipal Solid Waste
• Materials Not Categorized As Waste Inventory (MNCAW)
C. LEVEL I - ACTIVITY CHARACTERIZATION
Level I, Activity Characterization, requires a minimal amount of descriptive, quantitative,
and qualitative information to document each of the facility's processes and activities
which are defined as "Any existing or planned operation or activity (including
remediation projects) which generates waste or pollution to the air, land, or water." In
gathering this information, the facility begins the initial step to determine whether any
waste reduction or pollution prevention opportunities exist. The collection of this
information will also provide the basis to determine whether or not any of the facility's
-------
processes/activities necessitate further analysis per the graded approach methodology.
Therefore the principle objectives of Level I are to:
* define the process,
« document Waste Minimization / Pollution Prevention (WMin/PP) activities
(past or current),
• determine the level of effort that should be performed for a cost-effective
Pollution Prevention Opportunity Assessment Program, and
• provide information to determine if more analysis is necessary.
Level I Required Documentation
1. A brief process description / simple flow diagram;
2. A quantitative estimate of the material inputs, products, by-products, and
wastes;
3. A preliminary evaluation of WMin/PP potential; and
4. A decision to determine if further analysis is necessary.
Level I process assessments will establish the site's baseline of operational information.
These process/activity descriptions should include input materials, process products, by-
products and/or waste generated. Identification of these elements and estimates of
quantities is made using the best available information source, or combination of
sources. Possible information sources are listed in Appendix B.
In addition to the descriptive information, the potential for WMin/PP can be initially
evaluated based on the activity or process expert's knowledge. These
recommendations should be included in the Level I documentation. If opportunities do
exist and are easily implemented, then the actions taken or planned to be taken should
be documented. Furthermore, for WMin/PP options identified and implemented,
upstream / downstream impacts should also be included in the documentation.
After collecting the process/activity information, it is necessary to determine whether the
process/activity continues to a Level II or III analysis as defined by the graded approach
logic diagram and the site's priority material / waste stream list.
If the process does not contain any of the materials or waste streams on the priority list,
then the Level I documentation satisfies the PPOA requirement. Conversely, those
processes/activities which are captured by the site's priority list are included in the
Weighted Sums Evaluation to determine the next level of effort to be performed.
A completed example Level I Activity Characterization is shown in Appendix C. PPOA
Worksheets 1S-3S can be used to document the information required in a Level I
assessment.
D. GRADED APPROACH WEIGHTED SUMS EVALUATION
The graded approach methodology continues when the site selects a core team to
determine which processes require Level II and Level III assessments. The core team
-------
should be cross-functional and consist of key site personnel with knowledge about the
site's processes, waste management, and regulations. The team's objectives are to
assign weights to the criteria, to determine the numeric value that distinguishes a Level
It from a Level III, and to provide consistency in scoring across processes. The form to
aid in this evaluation (weighted sums) is shown in Figure 3. (Appendix D contains the
weighted sums form, criteria, and instructions.) First the site assigns a weight to each
criteria listed in the first column of the weighted sums. Then, for each process being
evaluated, the team determines a scale for the five listed criteria and a multiplier. From
the products and sums, a total point value is assigned. Finally, the team determines the
cut-off value for which Level II assessments will be completed versus Level III
assessments. Processes identified by the Weighted Sums Evaluation which require a
Level III, Formal Assessment, are those processes that are critical to the site's priorities
and would benefit by the allocation of resources to examine how to best implement
pollution prevention technologies to these critical areas.
E. LEVEL II - INFORMAL ASSESSMENT
After completing the Graded Approach Weighted Sums Evaluation, the facility has
distinguished which processes/activities require the Level II, Informal Assessment. The
principal objectives of Level II are to:
develop and screen WMin/PP opportunities and
recommend viable options for implementation.
This level of effort does not require the collection of new data. Much of the
documentation has already been completed in the Level I assessment. However, due to
some aspect of the process, the facility needs to further explore the WMin/PP
opportunities available to reduce the quantity of waste or the risk/hazard associated with
the operation.
Level II Required Documentation
(1.} Brief process description / simple flow diagram;
{2.} Quantitative estimate of the material inputs, products, by-products, and
wastes;
{3.} Preliminary evaluation of WMin/PP potential;
4. WMin/PP options identification and evaluation;
5. Consideration of potential upstream / downstream impacts; and
6. Recommendations for option implementation.
{} - denotes those items already completed in Level I, Activity Characterization
Further suggested reading for Level II information can be found in sections IV: A-C and
V: A-B. A completed example Level II, Informal Assessment, is shown in Appendix E.
PPOA Worksheets 1S-5S can be used to complete the requirements of a Level II
assessment.
-------
Date:
Page of
FIGURE 3
Pollution Prevention Opportunity Assessment Graded Approach
Weighted Sums Evaluation
Evaluation Criteria
Environmental, Safety,
& Health Hazards
Quantity of Waste
Generated
Site Liabilities
Economic Factors -
Process & Waste Costs
(Unit &/or Annual)
Process By-Product
Management
Other
Subtotal
IwMin/PP Potential
(Multiplier
Total
PPOA Level
Weight
'W1
Site
Assigns
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-------
F. LEVEL III - FORMAL ASSESSMENT
In addition to the information completed in the Level I assessment, the Level III requires
considerably more documentation to complete the PPOA. For example, both the
process description and a corresponding block flow diagram are required to illustrate
the basis of generation. The use of narratives, calculations, photographs, illustrations,
figures and/or data sufficient to convey an understanding of the process are certainly
recommended. The Level III assessment also requires collection of quantitative data for
a material balance. A material balance should be completed to account for all waste
generated. This information, if not already available, may need to be tracked to
accurately establish the current process waste generation information necessary to
complete the WMin/PP options analysis.
The primary objectives of the Level III Assessment are to:
• conduct a detailed analysis of the process for WMin/PP opportunities and
» document the results of the process evaluation in a written report.
Level HI Required Documentation
{1.} Brief process description / simple flow diagram;
{2.} Quantitative estimate of the material inputs, products, by-products, and
wastes;
{3.} Preliminary evaluation of WMin/PP potential;
4. Process description;
5. Flow diagram;
6. Material balance;
7. WMin/PP options identification;
8. Analysis of WMin/PP options generated: economic, technical, upstream /
downstream impacts, and other benefits;
9. Prioritized list of options; and
10. Formal report with documentation and recommendations for option
implementation.
{} - denotes those items already completed in Level I, Activity Characterization
A completed example Level III, Formal Assessment, is shown in Appendix F.
The following sections of this guidance describe the details necessary to achieve the
requirements of a Level III, Formal Assessment. Each of these sections can also be
used as a reference for the information required in the Informal Assessment and Activity
Characterization, Levels II and I, respectively. Blank Model Worksheets have been
included in Appendix G to help guide a team through the PPOA requirements. They are
only suggested forms - they are not requirements. A site may prefer to modify them to fit
their individual site needs. Model PPOA Worksheets 1-10 were developed for the Level
III assessment, PPOA Worksheets 1S-3S were developed for Level I, and Worksheets
1S-5S were developed for a Level II.
-------
III. POLLUTION PREVENTION OPPORTUNITY ASSESSMENT TEAMS
The Waste Minimization and Pollution Prevention Awareness Program Plan states that
assessments of all waste-generating operations at the site will be conducted by PPOA
teams. The team leader should have the authority to complete the assessment, line
responsibility, familiarity with the site's process and waste management operations, and
proven technical and problem-solving abilities (e.g. Value Engineering Specialist).
The remainder of each assessment team should be drawn from line staff, or
subcontractor organizations that can furnish the type of specialized expertise that will be
needed to conduct the assessment. Each PPOA team should consist of a small core of
individuals familiar with the site's operations, who will direct the assessment efforts and
guide the data gathering. The careful selection of personnel to conduct the assessment
is essential. Experienced people familiar with the site's operations are crucial to
completing an accurate and timely assessment. Subsets of this team are satisfactory for
Levels I and II of the graded approach. Other personnel with specialized skills will be
used on a part-time, as-needed basis. Each team may include members who have
knowledge in the following areas:
process operations;
federal, state, and local hazardous waste statutes and regulations;
operation and waste minimization principles and techniques;
quality control requirements;
purchasing procedures;
material control/inventory procedures; and/or
value engineering skills.
Model Worksheets 1 and "IS can be used to record the PPOA team members and the
assessment title and identification (ID) code. The PPOA ID Code should be unique for
each PPOA at the site. For uniformity, the site should determine the structure of this
code.
PPOA team leaders should receive training on the procedures, methodologies,
techniques and documentation requirements for PPOAs before the assessments are
conducted. The team leader needs to have clear authority from the WMin/PP
Coordinator or line management to select other team members, obtain support services,
and to direct the efforts of the assessment team in its interaction with operating
personnel. The team should be given unrestricted access to all facility personnel and
information that may, in the team's estimation, be relevant to the assessment.
-------
IV. ASSESSMENT OF PROCESSES AND WASTE STREAMS
A. INITIAL DATA GATHERING
For each assigned process, the PPOA team begins with gathering data about that
process and associated waste streams. The boundaries of the process must be
established. The team should consider the following process boundary criteria: (1) the
process must have a distinct starting and ending point, (2) the process input materials
must be accounted for, (3) the time frame must be considered, and (4) the process must
be manageable - an appropriate size to collect information and provide focus. The team
will collect information through interviews and the review of process documents that will
permit a thorough understanding of the process to be assessed and the development of
a written analysis on how that process generates waste (see Appendix B for sources of
additional information). The team should also visit the process areas to witness how the
process is conducted and to validate the written information that has been collected.
Each PPOA team should develop and/or collect information as defined in the graded
approach level. The following assessment tools may be used:
• process descriptions,
» process flow diagrams,
• material balances, and/or
• waste stream characterizations for assessment area or process.
Additional guidance may be found in the EPA Facility Pollution Prevention Guide
(Reference #8 of Appendix H) to complete the PPOA.
PPOA team members may identify ways to reduce waste during the data collection
phase. It is at this point that observations about operations, schedules, and procedures
can be noted which may easily be changed to prevent waste. These changes can have
a wide impact. The knowledge and experience of team members and their colleagues
will help to develop these ideas into potential options. The team members should also
make effective use of technical literature from equipment vendors and trade
associations; the experience of plant engineers, operators, and consultants; and the
databases available from environmental agencies.
B. PROCESS DESCRIPTION
The PPOA will include a general description of each process step in the waste
generating operation. The narrative should describe the following:
purpose of the process;
material and equipment used in the process;
equipment layout;
personnel and their experience / training level; and
products, by-products, and waste streams generated.
-------
Model Worksheets 2 and 2S can be used to complete the process description.
Chemicals and other materials purchased or otherwise introduced into the process
should be identified. The description should also include other information that
adequately describes the process and may be relevant to WMin/PP planning. For
example, process or product specifications, requirements, assumptions, and upstream
and downstream impacts may have a critical bearing on waste generation and should
be included in the description.
To further understand the process, the team may perform a function analysis as
explained in the DOE/Defense Program's Prioritization of Pollution Prevention Options
Using Value Engineering (Reference #13 of Appendix H). The principal objective of
function analysis is to discover the basic purposes of a process in contrast to its
secondary or support uses. It aids the team in determining the process1 primary
functions and in minimizing or eliminating secondary functions which, in turn, may
produce unnecessary wastes. The function analysis can help answer the question as to
whether this process is actually necessary.
C. PROCESS FLOW DIAGRAM
The analytical work of the waste assessment effort starts with the development of a
simple process flow diagram for the operation being assessed. The requirement for this
flow diagram is based on the maxim that a picture is worth a 1000 words. It is also the
foundation upon which the material balance is built. The process flow diagram should
identify the major steps within an operation and diagram the flow of materials into and
out of each step during the process. The diagram should indicate the following:
• process steps,
• material inputs, and
• process outputs (e.g., product, by-products and waste streams).
The diagram should also characterize the streams according to the nature of the release
and waste classification, including but not limited to the following:
air,
liquid,
solid,
radioactive,
mixed,
hazardous, and/or
non-hazardous.
Model Worksheets 3 and 2S can be used for the completion of the process flow
diagram. There are three styles to chose from for Model Worksheet 3 depending on the
complexity of the analysis and whether radioactive materials and waste streams are
involved.
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D. MATERIAL BALANCE
The PPOA shall account for all input materials that enter the process which are either
consumed, transferred, or disposed of as waste. This accounting, which is called a
"material balance", will be indicated on the process flow diagram and transferred to a
spreadsheet. A material balance is a tool which is used to provide an input/output
summary of the process being assessed. Closing the balance on an unknown stream
can help identify the constituents in that stream. The material balance should indicate
the following;
* amount of input materials introduced into the process,
• amount of materials consumed,
* amount of materials withdrawn as a product or by-product, and
* amount of materials flowing out of a process as a waste stream.
Using the best available information, the material balance should be closed (i.e., all
input materials and transfers should be accounted for in the product, by-product and
waste streams). The purpose of closing the balance is to identify streams which are
difficult to quantify, e.g. fugitive and point-source emission streams. The material
balance should show the average material flows over a representative time period
which is logical for the site's operations. For example, it may be appropriate to gather
data for Operation A from monthly averages, while a longer time span may be more
appropriate for Operation B. Material balances performed over the duration of a
complete production run are typically the easiest to construct and are reasonably
accurate.
In its simplest form, the material balance is represented by the mass conservation
principle:
Mass in = Mass out + Mass Accumulated
That is, materials placed into a process can be accounted for through products, by-
products, air emissions, water discharges, spills, recycling streams, waste streams,
scrap, out-of-shelf life materials, or out-of-specification materials. All materials
(hazardous and non hazardous) should be accounted for in the input and output
streams. The quantification units for the material balance should be consistent, i.e.
pounds. The Material Safety Data Sheet (MSDS) can be helpful in converting materials
into a common unit.
Measurement of Feed Materials: All input materials that are introduced into a process
must be identified. The amount and type of the input materials can be determined by
examining the following:
• procurement and inventory records;
• processing logs; and/or
» other records that show purchase, transfer, donation, or other receipt of
materials by production unit.
Other examples of information sources are found in Appendix B.
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Products and By-products: The material balance should indicate the amount of
materials leaving the work unit as a product or by-product.
Transfer of Materials: Some materials may be used in a process and then transferred to
another area or process for further processing. The material balance should account for
the transfer of the materials.
E. MEASUREMENT OF WASTE
Information about the quantity and character of the waste streams is a critical component
of the PPOA. Waste stream information should be obtained from sources such as:
site tracking system,
permits and permit applications,
monitoring reports,
hazardous waste manifests,
emission factors,
experiments,
emission or toxic substance release inventories,
hazardous waste reports,
waste analyses, and/or
environmental audit reports.
If the waste data is not available from the above sources, it may be necessary to monitor
the process and record the needed information. Model Worksheet 4 can be used to
record material balance data. The completed material balance should be a database of
process information that represents the process area over a time period long enough to
characterize that operation. The suggested time period to record this data is an annual
basis to coincide with other site reporting requirements. If data was taken over a shorter
time period, extrapolation can be used. The material balance will show the source of
waste streams and the contribution that different activities make to the waste streams. It
will serve as a baseline for tracking WMin/PP efforts and will provide data needed for
evaluation of WMin/PP options. The process data used to calculate a baseline of
operations should be as representative of current operations as possible.
Monitoring waste stream flows and compositions is something that should be done
periodically. By tracking waste streams, seasonal variations in waste flows or single,
large waste streams can be distinguished from continual, constant flows. Changes in
waste generation cannot be meaningfully measured unless the information is collected
both before and after a pollution prevention option is implemented.
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F. WASTE STREAM CHARACTERIZATION
Each waste stream identified in the process flow diagram will be characterized,
including but not limited to the following:
• source of waste;
• composition;
* rate of generation from work unit operation; and
• costs associated with treatment, storage, or disposal of wastes.
The waste stream characterization information is also part of Model Worksheet 4. The
cost information for the input materials and waste streams can be recorded on Model
Worksheet 5. After characterization, consideration should be given to each waste
stream to determine where WMin/PP is most needed.
V. DEVELOPMENT AND EVALUATION OF WASTE MINIMIZATION/
POLLUTION PREVENTION OPTIONS
A. IDENTIFICATION OF WMIN/PP OPTIONS
Once the process and causes of waste generation are understood, the PPOA enters the
creative phase. Following the collection of data and site inspections, the members of
the team will have begun to identify possible ways to minimize waste or prevent
pollution in the assessment process. Identifying potential options relies both on the
expertise and creativity of the team members. Much of the requisite knowledge may
come from their education and on-the-job experience, however, the use of technical
literature, contacts, and other sources may also be employed.
The process by which pollution prevention options are identified should occur in
an environment that encourages creativity and independent thinking by the
members of the assessment team. The key to successful results is the deferral of
any critical judgments or comments which might inhibit any of the team members.
While the individual team members will suggest many potential options on their
own, the process can be enhanced by using some of the common group decision
techniques. These techniques allow the assessment team to identify options that
the individual members might not have come up with on their own. Employees
having practical experience with the process may have given thought to the
process1 input and output efficiencies or alternative operating methods. Therefore,
creativity and brainstorming is strongly encouraged.
-------
To identify WMin/PP options, the PPOA teams will utilize the following priorities:
« source-reduction options:
- material substitution,
- process changes,
- product reformulating,
- equipment changes,
- operational improvements,
- schedule changes,
- affirmative procurement, and/or
- administrative controls (e.g., inventory control, employee
training, polices, etc.).
• recycling/reuse options
Each of these different approaches may generate many options or none, i.e., while
operational improvements are a very broad approach, input or process changes may be
difficult to control. Are there any processes / prodiicts upstream and downstream which
could be affected by changes to the process or product? As these different approaches
are discussed several questions should be repeatedly asked:
Is this operation necessary?
Why is this waste generated?
Why do we do this operation in this manner?
Why must we use these chemical??
Are there any non-hazardous substitutions available?
In addition to using the process expert's knowledge, there are numerous outside
references to assist in developing a list of options. These include EPA publications,
databases, and technical references; state and local environmental agency's
publications, bibliographies, and technical assistance; as well as, published literature in
technical magazines, trade journals, research briefs, vendor equipment information and
chemical supplier information.
Model Worksheet 6 can be used in a team brainstorming session to generate the
pollution prevention opportunities. Model Worksheets 7 and 4S can be used to record
the detailed description for each of the options generated. The description should
include the basic idea behind the option, affected materials and product, any roadblocks
to implementation, and the anticipated reduction quantity.
B. PRELIMINARY SCREENING OF WMIN/PP OPTIONS
Many pollution prevention options will be identified in a successful assessment. At this
point, it is necessary to identify those options that offer real potential to minimize waste
and reduce costs. Since detailed evaluation of technical and economic feasibility is
usually costly, the proposed options should be screened to identify those that deserve
further evaluation. The screening procedure serves to eliminate suggested options that
appear marginal, impractical, or inferior without a detailed and more costly feasibility
-------
study. The screening procedures may include any combination of the following
methods:
* information reviews by program managers,
* ballots by team members, and/or
• quantitative tools (e.g. weighted sum method).
Whatever method is used, the preliminary screening procedure should consider the
following questions:
Is implementation of the option cost effective?
What is the principal benefit of the option?
What is the expected change in the type or amount of waste generated
(toxicity, reactivity, etc.)?
Does it use existing technology?
What kind of development effort is required?
Will implementation be constrained by time?
Does the option have a dependable performance record?
Will the option effect product, employee health, or safety?
What are the upstream/downstream impacts if implemented?
The results of the screening process will be a list of options that are candidates for more
detailed technical and economic evaluation. It is important to document the decisions
made in the screening process for future reference. Model Worksheet 7 can also be
used to record the results from the initial screening process.
C. EVALUATION OF WMIN/PP OPTIONS
The PPOA team should perform an in-depth evaluation on the potential economic and
technical feasibility of each option using Model PPOA Worksheets 8 and 9. The options
will then be ranked in order of preferred implementation. The highest priority normally
should be given to source-reduction projects, after which projects that recycle/reuse all
or part of a waste stream or by-product will be considered.
Model Worksheet 8 evaluates each option from a cost perspective. The three major cost
categories for weighing options are: Implementation Costs, Incremental Operating
Costs, and Incremental Intangible Costs. EPA's Pollution Prevention Benefits Manual
(Reference #12 of Appendix H) provides more detail on cost analysis and contains
examples of each of these cost categories.
The following considerations must be fully evaluated to determine the recommended
WMin/PP options. These include: economic evaluation including capital cost, operating
cost, waste management costs and return on investment; expected change in the type or
amount of waste generated (toxicity, reactivity, etc.); technical feasibility; avoided costs;
effect on product, employee health and safety; permits, variances, and compliance
schedule of applicable agencies; releases and discharges to all media; previous
successes; implementation period; and/or ease of implementation.
-------
This evaluation is most easily accomplished and documented by the use of a simple
matrix for scoring and ranking - the suggested evaluation is the weighted sums method
shown on Model Worksheet 9. The DOE/DP Prioritization of Pollution Prevention
Options Using Value Engineering (Reference #13 in Appendix H) also demonstrates
how options can be evaluated and prioritized using this method. The evaluation matrix
provides a means to quantify the important criteria that affect the site and is a quick
visual representation of the factors affecting various WMin/PP options. The scoring
system for each criteria, used in the matrix and some rational for selection or weighting
of scores should be included in the formal report. Evaluation of this matrix would
complete the final requirement for prioritizing the list of options for implementation. The
formal report should provide sufficient detail to allow transfer of the measure to other
generators with similar processes or operations.
VI. FINAL REPORT
A final report is required for each PPOA. The final report is a compilation of essential
facts about the process, pollution prevention options, feasibility of those options,
upstream/downstream impacts of those options, and future implementation costs. The
final report documents the work performed, assumptions made during the assessment,
and identifies funding requirements necessary to implement pollution prevention
options. The length of the final report will depend on the complexity of the PPOA. For
Level II assessments, Model Worksheet 5S can be used to complete the requirements of
the final report.
For a Formal Assessment, Level III, each option will be ranked by the PPOA team
according to its economic and technical feasibility using Model Worksheets 8 & 9.
Economic feasibility will be a factor, but not the determining factor, in judging the relative
merit of each WMin/PP option. The PPOA team will report the results of its evaluation,
including final rankings and ranking criteria, to the Waste Minimization Committee or
line management. The PPOA team will indicate its preferred options in the report.
Easily implemented options will be completed and documented in the final report.
Options that require additional analysis and/or approval shall be addressed via the
site's Waste Minimization and Pollution Prevention Program Plan.
Documentation of the WMin/PP options and recommendations should demonstrate a
good faith effort undertaken to identify alternatives and should provide a narrative
description of these factors in sufficient detail to allow transfer of the measure to other
generators with similar processes or operations.
The final report and associated data will be maintained as permanent records for later
reference and tracking information. PPOAs should be reviewed on an annual basis
after the initial PPOA is completed and should be revised if significant process changes
are made.
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VII. APPENDIX
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APPENDIX A
GENERAL CONSIDERATIONS FOR PRIORITIZING
THE ASSESSMENT OF WASTE STREAMS
» Costs savings (direct and indirect)
« Potential for (or ease of) minimization
• Potential recovery of valuable by-products
• Reduced quantity of waste
» Compliance with current and future regulations
« Hazardous properties of the waste (including toxicity, fiammability,
corrosivity, and reactivity)
• Other safety hazards to employees
• Potential environmental and safety liability/improvements
• Potential for removing bottlenecks in production or waste treatment
-------
APPENDIX B
SOURCES OF MATERIAL BALANCE INFORMATION
Listed below are potential sources of information for preparing a process description,
flow diagram or material balance inventory. The list is not meant to be exclusive.
• Process Expert Knowledge
• Operating Logs
* On-site Tracking Systems
• Purchasing Records
• Vendor Information
• Process Design Information
• Batch Makeup Records
• Emission Inventories
• Equipment Cleaning and Validation Procedures
• Material & Chemical Inventories
* Operating Procedures and Manuals
• Production Records
• Product Specifications
* Samples, Analyses, and Flow Measurements
• Waste Disposal Records
• Waste Manifests
• E S & H reports
• Permitting Applications
• Experiments
• Laboratory Notebooks
-------
APPENDIX C
LEVEL I EXAMPLE PPOA
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PROCESS DEFINITION
SNL/NM Oroanization: 7813-5
Page _J of 2
Process Name: Asbestos Brakes & Clutch Removal
DATA FORM
DESCRIPTION OF
PROCESS/OPERATIONS
Area I,II,III,IV,V & Remote Area
Process Location SNL-Albuguerque NM/SNL-Livermore CA./TTR-Las Vaeas NV./KTF-Kauat
(include site, TA, building, room, as appropriate)
Describe the general operations or activities of the organization performing the process. Continue on
the back of this sheet, if necessary.
The Crane and Hoist section is responsible for performing annual
Repairs, and Preventative Maintenance on Cranes and Hoists.
Describe the particular process that generates wastes and/or other pollutants, or uses hazardous
materials. Describe how the hazardous materials are used, and how the wastes or pollutants are
generated. (See Chapter 2 of the PWA Guidance Manual for guidelines on defining a process.)
Continue on the back of this sheet, if necessary.
Asbestos Brakes and Clutches are generated waste In this process.
Asbestos Brakes and Clutches becomes a generated waste when the Asbestos
and Clutches areremoved and replaced with Non-Asbestos Brakes and Clutches,
Date: 7/22/93
PWA#:
Prepared by (MinNet Rep): Bernard. Alexander Phone: 4-1365
Process Contact: Bernard Alexander Phone: 4-1361
(to be completed fay WMSC)
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PROCESS D
SNUNM Organization: 7B13-5
Pane _| ol
Process Name: Asbestos Brakes & Clutch Removal
DATA FORM
PROCESS
FLOW DIAGRAM
Re»ote Areas
Process location: SHL-Atsuqaerque
,
CA*
StaHO. . flow |Seal rfoves shall be s"!f'fifi*itftl*f:!F3(.^,
If •vlGeneciile KAF8 Form 483 Asbestos Containing Materials WasJel
-------
PROCESS DEFINITION
SNL/NM Organization: 7813-5
Sheet 1 of 2 Page __ lm: of 2
Process Name: Asbestos Brakes and Clutches Removal
DATA FORM
CALENDAR YEAR 1992 WASTE
MINIMIZATION ACTIVITIES
Area I,II,III,IV,V, & Remote Areas
Process Location: SNL-Albuqgerque NM/SNL-Livermore CA./TTR-Las Vegas HV. /KTF-Kauai
(include site, TA, building, room, as appropriate)
Have waste minimization (WM) activities been undertaken in CY92? E Yes O No
If No, briefly discuss factors that have prevented waste minimization activities:
If Yes, short name of WM activity (e.g., Increase Input Purity, Improve Rinse Process) (use other sheets
if more than one activity taken): Removing and disposing of a hazardous material.
Type of WM activity (check best one that applies):
Source Reduction
09 Good Operating Practice
D Inventory Control
O Spill and Leaks Prevention
D Raw Material Modification
D Production Modification
O Process Modification (Clean and Degreasing)
D Process Modification (Surface Prep and Finish)
D Process Modification (Other)
D Other (specify below)
Recycling
O Began Onsite Recycling
O Began Off site Recycling
O Reuse in Original Process
O Reuse in Another Process
Energy Recovery
O Began Onsite Energy Recovery
O Began Off site Energy Recovery
Treatment
O Began Onsite Treatment
D Began Offsite Treatment
Briefly describe WM activity: Removal of Asbestos Brakes and Clutches to be replace with
a non-asbestos material. __^_^___ __^_
Prepared by (MinNet Rep): Bernard Alexander Phone: 4-1365
Process Contact: Bernard Alexander Phone: A-1365
7/22/93
PWA#:
(to b« comploted by WMSC)
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PROCESS DEFINITION
SNL/NM. Organization: 7813-5
Sheet 2 of 2 Page 2 of 2
Process Name: Asbestos Brakes and Clutches Removal
DATA FORM
FISCAL YEAR 1992 WASTE
MINIMIZATION ACTIVITIES
Waste stream type affected: D Hazardous (Chemical! Solid Waste
D Radioactive/Mixed Solid Waste
O Waste Water Discharge
O Air Emission
Waste stream name affected (see corresponding Data Form 2): Asbestos Brakes and Clutches
Did WM activity increase the toxicity of waste generated? D Yes E No
Did WM activity increase the quantity or toxicity of wastes emitted to other media (air, waste, land)?
D Yes 0 No
Did WM activity reduce toxicity but not quantity? E Yes D No
Indicate the quantity impact of the WM activity (use most appropriate measure):
Mass before WM activity (kg/yrj:
Volume before WM activity (4/yr):
Specific activity before WM activity (Ci/kg/yr):
Mass after WM activity (kg/yrj:
Volume after WM activity (l/yr|:
Specific activity after WM activity (Ci/kg/yr}:
Basis of quantities (e.g., direct measurement, material balance calculation, published emission factors,
engineering calculations, engineering/scientific judgment):
Has the WM activity been successful? d Yes D No
Is the activity still being used? Q Yes O No
If unsuccessful or otherwise not being used, describe why:
Date: 7/22/93
PWA #:
Prepared by (MinNet Rep): Bernard Alexander Phone: 4-1365
Process Contact: Bernard Alexander Phone: 4-1365
(to b« completed by WMSCI
-------
PROCESS CHARACTERIZATION Page i . of 1
SNUNM Organization: 7813-5 Process Name: Asbestos Brakes and Clutches
DATA FCnM
HAZARDOUS/RADIOACTIVE
MATERIAL INPUTS
Nam* of Hazardous/Radioactive Material
Asbestos
Glove Bag
Tvvek Suits .Rags, Drip Cloth
input Stream
Number
1
2
9
Predicted
Frequency of
Usage"1
Average
Annual Usage
Rate
-------
PROCESS CHARACTERIZATION Sheet 1 of 3 Page 1 of
SNUNM Organization: 7813-5 Process Name: Asbestos Brakes and Clutches
DATA FORM
HAZARDOUS (CHEMICAL)
SOLID WASTE
Waste Stream Number (from Worksheet 1): 1,2,9.10
Waste Stream Name (from Data Form 2/Worksheet 1): Asbestos,tyvk suits,rags .drip cloth, plastic
Location of waste generation (TA, building, room): SNL-Alb/SNL-CA/TTR-NV/KTF-Kauai bag
Inside RMMA? D Yes ® No
Briefly describe how waste is generated: Asbestos Brakes and Clutches are removed and replaced
with non-asbestos material. Glove bages.tyvek suits rags, and drip cloth are used in th
removal process to remove the generated waste.
Frequency of waste generation:
O Continuously
d Monthly
D Daily
O Quarterly
D Weekly
O Annually
Which description fits the process step that generates the waste (check best one):
IE A regularly scheduled process step that is likely to be repeated several times during the upcoming year.
O A one-time activity that is not likely to be repeated during the upcoming year.
Predicted average quantity of waste generated annually - normal operations (kg): 200 Ibs.
Predicted min/max quantity generated annually - normal operations (kg): Min Max
List (describe) all hazardous constituents (e.g., mercury inside switches, benzene-tainted glassware)
or brand names (e.g., WD-40) that could be in the waste:
Asbestos , ___^__
Do the hazardous constituents of the waste stream listed above vary (e.g., sometimes contains lead,
sometimes contains lead and cadmium)? D Yes H No if yes, describe how the waste varies:
Describe physical characteristics of wastes (e.g., aqueous solution, solid, sludge, oil, containerized
compressed gas - include % of solids or % moisture, If applicable): Solid
Date: 7/22/92
PWA#:
{to b* completed by WMSCI
Prepared by (MinNet Rep): Bernard Alexander
Process Contact: Bernard Alexander
Phone:,
Phone:
4-1365
4-1365
-------
PROCESS CHARACTERIZATION Sheet 2 of 3 Page 2 of _
SNUNM Organization: 7813-5 Process Name: Asbestos Brakes and Clutches
DATA FORM
HAZARDOUS (CHEMICAL)
SOLID WASTE
The pH of the waste stream may range from N/A to N/A (answer if appropriate)
Is the waste ignitable? (see Guidance Manual for clarification!
Is the waste corrosive? (see Guidance Manual for clarification}
Is the waste reactive? (see Guidance Manual for clarification)
D Yes
D Yes
D Yes
m NO
BNo
BNo
O Unknown
O Unknown
O Unknown
Does the waste stream contain any of the following toxic metals: Q Yes H No (check all that apply)
D Arsenic D Barium O Cadmium O Chromium
O Lead O Mercury D Selenium D Silver
Does the waste stream, contain a toxic volatile, semi-volatile, or pesticide listed in Table 3-2?
D Yes S No If yes, list:
Does the waste stream contain any of the spent solvents listed in Table 3-3? O Yes B No
If yes, list:
Does the waste stream contain, or is it generated from the production of, any of the following benzene
derivatives? O Yes 0 No (check all that apply)
D trichlorophenol D tetrachlorobenzene
O tetrachlorophenol Q pentachlorobenzene
O pentachloropheno! D hexachlorobenzene
Is the waste any of the following? O Yes
O waste water treatment sludge
O petroleum refining waste
E No (check all that apply)
O wood preserving process waste
O leachate from treatment, storage, or disposal of waste
Does the waste contain cyanide or is cyanide used in the process? O Yes B No
Is the waste any of the following? O Yes E No (check all that apply)
O waste from the production of inorganic pigments
O waste from the production of inorganic chemicals
O waste from the production of organic chemicals
D waste from the production of explosives
D waste from the production of ink formulations
D waste from the production of pesticides
D waste from the production of metals
O waste from the production of Pharmaceuticals
D coking waste
O petroleum refining waste
Date: 7/22/93
PWA #:
(to be completed by WMSC)
Prepared by (MinNet Rep):Bernard Alexander
Process Contact: Bernard Alexander
Phone: 4-1365
Phone:4-1365
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PROCESS CHARACTERIZATION Sheet 3 of 3 Page 3 of
SNL/NM Organization: 7813—5 Process Name: Asbestos Brakesand Clutches
DATA FORM
HAZARDOUS (CHEMICAL)
SOLID WASTE
Based on the above description of how the waste is generated, select the single best summary of the
waste-generating process step.
CLEANING AND DECREASING
D Stripping (A01)
D Acid cleaning ((A02)
O Caustic (Alkali) cleaning (A03)
D Flush rinsing (A04)
n Dip rinsing (A05)
D Spray rinsing (A06)
O Vapor degreesing (A07)
D Physical scraping and removal (A03I
O Clean out process equipment (AOSJ
O Other cleaning and degreasing (A19)
SURFACE PREPARATION AND FINISHING
D Painting (A21J
D Electroplating (A22)
D Electroless plating (A23)
O Phosphating (A24)
O Heat treating (A25)
D PieWing (A26I
D Etching (A271
D Other surface coating/preparation (A29)
PROCESSES OTHER THAN SURFACE PREPARATION
D Product rinsing (A31)
D Product filtering {A32»
O Product distillation (A33)
D Product solvent extraction (A34J
D By-product processing (ASS)
O Spent catalyst removal (A36)
O Spent process liquids removal (A38)
O Tank sludge removal (A38)
O Slag removal (A39)
O Metal forming (A40)
O Plastics forming (A41)
PRODUCTION OR SERVICE DERIVED ONE-TIME AND
INTERMITTENT PROCESSES
O Leak collection (ASK
O Cleanup of spill residues (A53)
D Oil changes (A54)
D Filter/battery replacement (ASS)
O Discontinue u*« of process equipment (ASS)
B Discarding off-spac material (A571
O Discarding out-of-date products or chemicals (ASS)
D Other production-derived on-time and intermittent
processes (ASS)
D Sludge removal (A60)
REMEDIATION DERIVED WASTE
D Superfund Remedial Action (A61)
D Superfund Emergency Response (A62)
O RCRA Corrective Action at solid waste management
unit (A63)
D RCRA closure of hazardous waste management unit
(A64|
O Underground storage tank cleanup (A65)
O Other remediation (A69)
POLLUTION CONTROL OR WASTE TREATMENT
PROCESSES
O Filtering/screening (A71)
O Metals recovery (A72)
O Solvents recovery (A73)
D Incineration/thermal treatment (A74)
O Westeweter treatment (A75)
O Sludge dewetering (A76)
O Stabilization (A77)
O Air pollution control devices (A78)
O Leachate collection (A79)
O Other pollution control or waste treatment (ASS)
OTHER PROCESSES
S Clothing end personal protective equipment (A91)
S Routine cleanup wastes (e.g., floor sweepings)
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APPENDIX D
PPOA GRADED APPROACH WEIGHTED SUMS
FORM, CRITERIA, AND INSTRUCTIONS
-------
Date:
Page
of
Pollution Prevention Opportunity Assessment Graded Approach
Weighted Sums Evaluation
Evaluation Criteria
Weight
'W'
Process:
Scale
'S' 'WxS1
Process:
Scale
'S1 'WxS1
Process:
Scale
'S1 'WxS1
Process:
Scale
'S1 'WxS1
Process:
Scale
'S1 'WxS1
Environmental, Safety,
& Health Hazards
Site
Assigns
Quantity of Waste
Generated
Site Liabilities
Economic Factors -
Process & Waste Costs
(Unit &/or Annual)
Process By-Product
Management
Other
Subtotal
WMin/PP Potential
Multiplier
Total
PPOA Level
8/93
-------
Date;
Page
of
Pollution Prevention Opportunity Assessment Graded Approach
Weighted Sums Evaluation
Evaluation Criteria
Weight
•W
Process:
Scale
'S1 'WxS'
Process:
Scale
'S' 'WxS1
Process:
Scale
'S1 'WxS1
Process:
Scale
'S' 'WxS'
Process:
Scale
'S' 'WxS'
Environmental, Safety,
& Health Hazards
Site
Assigns
Quantity of Waste
Generated
Site Liabilities
Economic Factors -
Process & Waste Costs
{Unit &/or Annual)
Process By-Product
Management
Other
Subtotal
i
Min/PP Potential
[Multiplier
Total
PPOA Level
8/93
-------
Graded Approach Worksheet
The purpose of this worksheet is to determine the PPOA level for each of the facility processes. To begin, a list of these
processes or areas should be generated for each facility. Then for each item listed, complete one column on this worksheet.
For consistency, each facility should establish site-specific weights for each of the criteria. Once each item has received a
weighted sum value, then each facility should establish the dividing line from which to require informal (Level II) or formal PPOAs
(Level III).
Weighted Sums Instructions:
a. The values in the Weight column (designated by W)
represent the facility's priority for the criteria.
b. In the Scale column for each process (designated by 'S'),
rate each criteria by assigning a value from 0-10
(lowest to highest).
c. In the 'Wx S' column for each process, enter the product of
the weight and scale.
d. Sum the 'W x S1 column for each process to obtain a
subtotal.
e. Calculate the process ratio for waste generated/input
material used (0-1). This is the multiplier.
f. Multiply the subtotal by the multiplier and enter the product
in the Total column for each process.
g. Determine the level of PPOA required by comparing the
Total weighted sums value with the site guidelines in
the following table.
Weighted Sums
Total
If 0 to (?)
If > (?)
PPOA Level
Required
Level II
Informal PPOA
Level III
Formal PPOA
-------
APPENDIX E
LEVEL II EXAMPLE PPOA
-------
[ PPOA-1 1 Original Issue Date: 8/31/91
V / Revision Mn •
Revision No.:
Revision Date:
Pollution Prevention Opportunity Assessment
Team & Scope
Assessment ID Code: Assessment Title:
SNL/CA MS001 Machine and Fabrication Shop
Name Job Classification Phone
Alice Johnson- Duarte
Andy Cardiel
Charlie Schmitz
Kim Shepodd
WMin Coordinator
Shop Supervisor
Machinist
Waste Manager
4-3266
4-2544
4-2315
4-1475
* Team Leader
Assessment Scope:
The Machining and Fabrication Shop is a support function whose principal
purpose is machining parts requiring a quick turn-around, restriction of
access due to classification, and/or close liaison with the designer and
engineer. The shop maintains equipment suitable to perform turning,
milling and grinding operations. The major hazardous waste stream
generated by this facility is the spent coolant used in the machining
process. The diluted Aqua-Syn 180 itself is a non-hazardous material per
29CFR 1910.1200(c); however, in the machining process it is mixed with
small amounts of machine oil and metal shavings. The coolant is routinely
changed after 3 to 4 months of service except as noted in the shop's
operating procedures.
Potential for Pollution Prevention / Waste Minimization or Recommendations:
There are limited operational and administrative pollution prevention
opportunities to reduce the spent coolant waste.
-------
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
PROCESS FLOW DIAGRAM
PWA ASSESSMENT ID CODE: SNL/CA MS001
TITLE: Machine and Fabrication Shop
Unspecified Aqueous Solution
CY91 Generated 11,000 pounds
COOLANT
SOLUTION
Water, 20 Parts
Aqua-Syn 180,
1 Part
Replaced
"only as "
required
Small Metalic Chips
Thin Film Machine Oil
A total of
35 machines
including:
19 lathes,
9 mills,
5 grinders,
and 2 handsaws
use coolant.
Waste
Solution
55 GAL
Sent to Off-site
Disposal
-------
PPOA-2
Pago; 1 of
Pollution Prevention Opportunity Assessment
Material & Waste Stream Summary
Assessment ID Code: SNUG A MS001
Title: Machine and Fabrication Shop
Input
Material
Name/No.
Water
Aqua-Syn
Metafic chips
Machine oil
Annual
Quantity
Used
10400.0
520.0
65.0
15.0
%
Product
%
Recycled
Total Releases
%
Air
5
1
%
Liquid
95
99
100
%
Solid
100
Totals/Page: 11000.0
Total Annual Quantity 11000.0
Does the process require further analysis
based on the site's Priority Material/Waste
Stream List?
ONo
[Level II DLevel II
9/16/93
-------
Page _1_of J
Pollution Prevention Opportunity Assessment
Option Summary
Assessment ID Code: Title:
SNL/CA MS001 Machine and Fabrication Shop
Option Description
One consideration for an operational improvement would be to recycle the spent coolant. According to industrial
sources, a reduction of approximately 50% in the present amount of coolant disposed of.
Type
Recycling
Consider?
• Yes ONo
Feasibility
Fair
Estimated
Cost
$25,000.00
Estimated
Savings
$100.00
Anticipated
Reduction Qty
5,000.00
Qpilan Description
&°-* Analyze the spent coolant solution for contaiminants and determine if it is indeed hazardous.
2
Type
Disposal
Consider?
OYes 9No
Feasibility
Poor
Estimated
Cost
$5,000.00
Estimated
Savings
$100.00
Anticipated
Reduction Qty
1,0000
-------
Date
8/31/91
Pollution Prevention Opportunity Assessment
Final Summary
Assessment ID CodeSNUCA MS001
Title: Machine and Fabrication Shop
Assessment:
A Level I and Level II PWA were completed on the Machining and Fabrication Shop
coolant waste stream. The machinist responsible for the operational maintenance of
the machine shop equipment had limited suggestions for reducing the amount of
spent coolant generated. Recycling and treatment options were generated and
evaluated. Assumptions made during this assessment were: the level of activity of the
machine shop is relatively stable; the coolant must be changed on a periodic basis
which is dependent on use and/or time and; disposal costs are relatively stable.
Conclusions:
The PWA team concluded the options are not economically feasible at this time since:
1) option one would require a considerable investment with the possibility of
increasing the actual amount of coolant waste caused by contamination; 2) the
recycling equipment presently available is not designed to treat the small quantity of
spent coolant generated; 3) a conservative approach regarding waste management is
consistent with the site's policy.
Recommendations:
The Line Management will continue monitoring the amount of waste generated and
the availability of recycling equipment for improvement in the economical feasibility of
implementation.
-------
APPENDIX F
LEVEL III EXAMPLE PPOA
-------
Worksheet 1
Level ill
Original Issue Date;
Revision No.:
Revision Date:
OI-Dae-1993
Pollution Prevention Opportunity Assessment
PPOA Team
PPOA Title: Polyurethane Foam Mixing and Curing
PPOA ID Code(s): G517-034-Machine_Mix
Name
"Team Leader
Additional Resources
Job Classification
Phone
*Bill Harrison
John Taylor
Albert Green
Mary White
Violet Jones
Process Engineer
Area Supervisor
Foam Machine Operator
Foam Machine Operator
Area Production Planner
X1234
X1235
X1235
X1235
X1236
Name
Phone
PPOA Coordinator
Waste Management
Industrial Hygiene
Environmental Protection
Safety
Fire Protection
Process Engineering
Materials Engineering
Utilities Engineering
Facilities Engineering
Maintenance (Equipment)
Analytical Lab Testing
Scheduling
Purchasing
Nancy Notrebmep
Hakim Senoj
Tim Sregge
Dottie Muldune
X5432
X5433
X5434
X5431
11/93
-------
Worksheet 2
Level 111
Revision No.:
Revision Date:
Pollution Prevention Opportunity Assessment
Process Description
PPOA Title: Polyurethane Foam Mixing and Curing
PPOA ID Code(s): G517-034-Machine_Mix
Process Location: Main Building #105, Post FN33
Process Description:
The foam mixing process is a process in which the required material
components are metered and mixed at a defined ratio. The ratio of the two
component streams is set and calibrated by production personnel. The
materials are then mixed during the dispense cycle by the action of a motorized
impeller. The mixed material "foam" is transferred manually to a mold and cured
at temperatures from 165 to 350 deg. F. for four to six hours. Input materials
include polyol resins, isocyanates, cleaning solvent and processing supplies.
Five foam dispensing units are used. They range in age from four to fifteen
years. The cure ovens are ventilated as is the foam pouring area. The foam
machine operators have sufficient training to operate the dispensing units.
Their previous training did not emphasize pollution prevention.
Waste streams include solid and liquid waste from the foaming operations as
well as air emissions from the foam pouring and curing activities.
Description of Major Product(s) of Process:
Molded Polyurethane Foam Products
11/93
-------
Level 111
Revision No.: 0
Revision Data:
Pollution Prevention Opportunity Assessment
Process Flow Diagram
PPOA Title or PPOA ID Code(s):
G517-034-Machine Mix
Inputs:
Isocyanate Comp.
Resin Component
Solvent
Supplies
Process:
Foam Mixing
and Curing
Outputs:
Product
Hazardous
Non-Hazardous
Other
(PR2)
(PR3)
Solid
Foam
Product
Liquid
Air
Solid
Purge
Waste
Calibration
Waste
Air
Isocyanate
Emissions
(NH2)
(NHS)
Solid
Scrap
Product
Liquid
Air
(Sri)
(cm)
(OT3)
Solid
Liquid
Air
11/93
-------
Level
Time frame
Pollution Prevention Opportunity Assessment
Material Balance Summary
PPOA Title or PPOA ID Code(s): G517-034-Machlne_Mlx
Revision No.:
Revision Date;
Page 1 of
muni, ui— uan — 9£
To: 31-Dec-92
Material
Description
Isocyanate
Resin
Solvent
Supplies
Foam
Totals/Subtotals
Total
Input
313.6
186.4
80.0
94.0
0.0
674.0
Total
Output
124.5
73.5
80.0
94.0
302.0
674.0
Stream
ID Code
Foam
Product
(S)
237.0
237.0
Stream
ID Code
Purge
Waste
@)
98.3
58.9
80.0
94.0
331.2
Stream
ID Code
Calibration
Waste
(HZ2)
24.4
14.6
39.0
Stream
ID Code
Isocyanate
Emissions
(HZS)
1.8
1.8
Stream
ID Code
Scrap
Product
(NHI)
65.0
65.0
Stream
ID Code
o
Stream
ID Code
O
Stream
ID Code
O
Stream
ID Code
O
11/93
-------
Worksheet 5
Level 111 Revision No.: _
Revision Date:
Page 1 of
Pollution Prevention Opportunity Assessment
Material Cost
PPOA Title or PPOA ID Code(s); G517-034-Machine_Mix
Material
Isocyanate Component
Resin Component
Solvent
Supplies (paper cups, etc.)
Stock Number
(if applicable)
Cost Per
Unit
$1.96/lb
$2.25/1 b
$0.27/1 b
$O.S7/lb
Total /
Subtotal
Annual Cost
$614.65
$419.40
$ 21.60
$ 53.60
$1109.25
Waste Disposal Cost:
Material / Waste Stream
Waste Liquid
Waste Solid
Scrap Product
Waste Stream
Category
Haz. Liquid
Haz, Solid
Non Haz. Solid
Cost Per
Unit
$4.60/lb
$2.97/lb
$0.69/lb
Total/
Subtotal
Annual Cost
$179.40
$983.66
$ 44.85
$1207.91
11/93
-------
Worksheet 6
Level III
Pollution Prevention Opportunity Assessment
Option Generation
PPOA Title or PPOA ID Code(s): GS17-034-Machme-Mix
Revision No.:
Revision Date:
Practices &
Procedures
Material
Substitution
New Product
&/or Process
Reduce calibration
Amount & duration.
Reduce solvent
purge time
Increase operator
^awareness & training
Redefine foam
kit requirements
In-line calibration
system
Use submerged
pumps
Equipment
Modification
Pollution
Prevention
Options
11/93
-------
Worksheet 7
Level III Revision No.: 0_
Revision Date:
Page 1 of 2
Pollution Prevention Opportunity Assessment
Option Description
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Option Name and Description
(Include input materials, products affected, and anticipated reduction quantity.)
Option No. 1 : Calibration Reduction. Reduce the amount and duration of the
calibration shots for the foam dispensers. Use new analytical methods "nitrogen
testing" to justify the reduced level.
Consider; Yes X No_
Practices & Procedures X Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation
Option No. 2 : Increase Awareness and Training. Conduct training session to
increase pollution prevention awareness. Instruct in the importance of the individual
in the waste generation process.
Consider: Yes X No_
Practices & Procedures X Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation
Option No. 3 : Use Submerged Pumps. Replace gear pumps on foam
machines with in-tank pumps. Leakage will be into material tanks. This will eliminate
material waste and exposure as the result of clean-up
Consider: Yes X No
Practices & Procedures Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process X Recycling, Reuse, & Reclamation
Option No. 4 : In-Line Calibration System. Purchase new foam equipment
with "in-line" calibration capability. This would replace the open cup method and
would reduce the liquid and solid waste streams
Consider: Yes X No
Practices & Procedures Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification X
New Product &/or Process Recycling, Reuse, & Reclamation
-------
Worksheet 7
Level III Revision No.:
Revision Date:
Page 2 of 2
Pollution Prevention Opportunity Assessment
Option Description
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Option Name and Description
(Include Input materials, products affected, and anticipated reduction quantity,)
Option No. 5 : Substitute for TDI. Lessen the toxicity of the waste stream by
replacing TDI isocyanate with a PMDI based foam system. PMDI is not a carcinogen
and is not a RCRC Hazardous waste.
Consider: Yes X No_
Practices & Procedures Waste Segregation/Hazard Reduction
Material Substitution X Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation
Option No. 6 : Reuse Calibration Material. Retain spent calibration material
for use on low end product requirements. This could include machine tryout parts,
or foam billets used as base material for holding fixtures.
Consider; Yes X No_
Practices & Procedures Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation X
Option No. 7 : Reduce Solvent Purge Time. Reset the solvent timers on the
foam machine to the absolute minimum to flush the mix head. Subsequent soaking
of mixer blade and housing can also reduce the required amount.
Consider; Yes X No_
Practices & Procedures X Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation
Option No. 8 : Redefine Foam Kit Requirements. Set-up separate material
numbers for resin and isocyanate components so ratio/usage of material will be
balanced. Current "matched set" distribution result in waste of excess component.
Consider: Yes X No_
Practices & Procedures X Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation
-------
Worksheet 8
Level
Revision No.: 0
Revision Date: _
Page 1 of 2_
Pollution Prevention Opportunity Assessment
Options Cost Evaluation
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Option No.:
1
Option No.:
2
Option No.:
3
Option No.:
4
Option No.:
5
Implementation Costs
Purchased Equipment
Installation
Materials
Utility Connections
Engineering
Development
Start up / Training
Administrative
Other
Total Implementation
Cost
$250
$100
$50
$400
$100
$100
$50
$250
$500
$100
$150
$150
$900
$75,000
$10,000
$2000
$3000
$5000
$95,000
$1000
$500
$1500
Incremental Operating Costs
Change in Raw
Materials
Change in Maintenance
Change in Labor
Change in Disposal
Other
Annual Operating
Savings/(Cost)
$215
$500
$50
$765
$100
$50
$150
Incremental Intang
Penalties and Fines
Future Liabilities
Other
Annual Intangible
Savings/(Cost)
Total Annual
Savings/(Cost)
Payback Period
$0
$765
0.5 yrs
$0
$150
1 .6 yrs
$150
($150)
$100
$100
$750
$500
$600
$1850
$500
$500
$1000
ible Costs
$0
$100
9.0 yrs
$0
$1850
51 yrs
$0
$1000
1.5 yrs
11/93
-------
Worksheet 8
Level III
Revision No.: 0
Revision Date:
Page 2 of 2_
Pollution Prevention Opportunity Assessment
Options Cost Evaluation
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Option No.:
6
Option No.:
7
Option No.:
8
Option No.:
Option No.:
Purchased Equipment
Installation
Materials
Utility Connections
Engineering
Development
Start up / Training
Administrative
Other
Total Implementation
Cost
$200
$200
$150
$150
$300
$150
$150
$300
Incremental Operating Costs
Change in Raw
Materials
Change in Maintenance
Change in Labor
Change in Disposal
Other
Annual Operating
Savings/(Cost)
$180
$180
$15
$125
$140
Penalties and Fines
Future Liabilities
Other
Annual Intangible
Savings/(Cost)
Total Annual
Savings/(Cost)
Payback Period
$0
$180
1.1 yrs
$0
$140
2.1 yrs
$350
$350
mm>mfmmmmm:mmmmm] ; • •.
$0
$350
0.9 yrs
11/93
-------
Worksheet 9
Level ill
Revision No.:
Revision Date:
Page 1 of
Pollution Prevention Opportunity Assessment
Weighted Sums Option Evaluation
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Criteria
Public Health, Safety, &
Environment
Employee Health & Safety
Regulatory Compliance
Economic
Implementation Period
Improved Operation /
Product
Other
Subtotal
Likelihood of Technical
Success (Multiplier)
Likelihood of Useful
Results (Multiplier)
Total
Rank
Weight
W
10
10
8
6
4
2
iiiiiiiiiitill
liiiiiiiiiiilif
:-;•:•:•:--•.-:-.• :-:-;-:-:•:-;•:•;•;•:•:•:•:•:•:•:•:•:•:•:
;:;>:-[[[
:^S:?:^:^:^'^SS$!::™'. *:: :•
Option N
Scale
'S1
8
8
7
8
7
5
sssssiisspsss?
X
X
:%::?S:^S;:^^SS::^::::
;;x:x:£:;:x:;:;:;:;:;:|:;:;:;:£:j:;:;:;:
o.: 1
'WxS'
80
80
56
48
28
10
302
0.8
0.9
217
7
Option N
Scale
'S'
6
7
7
9
9
8
X
X
o.: 2
'WxS1
60
70
SB
54
36
16
292
1.0
0.9
262
4
Option N
Scale
•S'
6
5
8
7
6
7
X
X
x*:W:W:*: : ?:v£*:;;::
xl:;:*:*:*:*: : :|: £>:-#
;S:;:;:;:£:;::$- | £ <:;:$:•:
1111 1111
o.: 3
'WxS1
60
50
64
42
24
14
254
0.9
0.9
205
8
Option N
Scale
'S'
7
8
7
5
6
8
lllllllilllll
X
X
o.: 4
'WxS'
70
80
56
30
24
16
276
0.9
0.9
224
5
Option N
Scale
'S'
8
9
9
8
7
8
X
X
'^^?^^^^^^ :¥:
o.: 5
'WxS1
80
so
72
48
28
16
334
1.0
1.0
339
1
-------
IliiiiiBiiiaig^iiiiiiilllKliflaiSllaahi':
Level III
Pollution Prevention Opportunity Assessment
Weighted Sums Option Evaluation
Revision No.:
Revision Date:
Page 2 of
PPOA Title or PPOA ID Code(s): G517-034-Machine Mix
Criteria
Public Health, Safety, &
Environment
Employee Health & Safety
Regulatory Compliance
Economic
Implementation Period
Improved Operation /
Product
Other
Subtotal
Likelihood of Technical
Success (Multiplier)
Likelihood of Useful
Results (Multiplier)
Total
Rank
Weight
W
10
10
8
6
4
2
mi
111 \
• i iiiii
:-;-:-;;:-:|:v:;:::;:;;|x-;::::-:'X:L::^LjLj;j;J;J;J
y;-;J;y;v;J;;;|:;::;::::-:-x-:-:-:-:-;":|:;:':;:j;j:
Option No.: _6
Scale
'S1 'WxS'
6
7
6
7
7
7
1
1
X
X
60
70
48
42
28
14
262
0.9
0.9
212
6
Option No.: 7
Scale
'S1 'WxS'
8
8
7
9
9
6
X
X
5i5:sg;S¥gft;: SSs : f
1111111$ 1 |l M
tp;?SS:tP :w : S
80
80
56
54
36
12
318
1.0
0.9
286
2
Option No.: _8
Scale
'S' 'WxS'
6
7
7
8
8
9
X
X
60
70
56
48
32
18
284
1.0
1.0
284
3
Option No.:
Scale
'S1 'WxS'
X
X
Option No.:
Scale
'S1 'WxS'
X
X
11/93
-------
Worksheet 10
Level HI
Revision No,: 0
Revision Date:
1 of 1
Pollution Prevention Opportunity Assessment
Final Report Check Sheet
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Requirement Completed
Title Page X
PPOA Title
PPOA ID Code(s)
Team members
Issue date/revision date/revision no.
Executive Summary X
Process description
Process assessment
Option summary and analysis
Conclusions
Recommendations
Introduction X
Background of evaluation
Process Description X
Associated equipment
Process flow diagram
Process Assessment X
Methodology
Material Balance
Unusual occurrences
Option Summary and Analysis X
Option description and rank
Upstream/Downstream impacts
Material usage
Anticipated reduction
Estimated costs
Estimated benefits
Feasibility
Waste streams affected
Conclusion X
Concluding evaluation
Option analysis decisions
Concerns
Options already implemented
Lessons learned
Recommendations X
Future work
New equipment
Implementation strategies
Worksheets X
1-10
11/93
-------
APPENDIX G
MODEL PPOA WORKSHEETS
-------
Worksheet 1
Level
Original Issue Date:
Revision No.:
Revision Date:
Pollution Prevention Opportunity Assessment
PPOA Team
PPOA Title:
PPOA ID Code(s):
Name
Job Classification
Phone
*Team Leader
Additional Resources
Name
Phone
PPOA Coordinator
Waste Management
Industrial Hygiene
Environmental Protection
Safety
Fire Protection
Process Engineering
Materials Engineering
Utilities Engineering
Facilities Engineering
Maintenance (Equipment)
Analytical Lab Testing
Scheduling
Purchasing
11/93
-------
Worksheet 1
Worksheet 1 provides the identification of the PPOA assessment team. For the PPOA
to be successful, employees involved with the process should be members of the
team. The assessment team needs a leader, members, and additional resources,
as required.
The team leader should have technical knowledge of the process, knowledge of the
current production operations, and the personnel involved. The leader shall
assemble the team to perform the assessment. Team members may include
process engineers, product engineers, knowledgeable department personnel such
as production operator(s), and material experts. Additional resources may be called
in to provide information not available within the team. The size of the team may be
large for complicated processes, but should be kept to a minimum to maintain focus.
1. Original Issue Date: List the original issue date of the PPOA.
2. Revision No.: List the revision number for this worksheet. {Original issue = 0.}
3. Revision Date: List the most recent revision date for this worksheet.
4. PPOA Title: List the PPOA title selected by the team.
5. PPOA ID Code(s): List the PPOA ID Code(s) selected by the team.
6. Name, Job Classification, Phone: To facilitate team meetings and for future
reference, this information should be completed when the PPOA team is
formed.
-------
Level III
Revision No.:
Revision Date:
Pollution Prevention Opportunity Assessment
Process Description
PPOA Title:
PPOA ID Code(s):
Process Location:
Process Description:
Description of Major Product(s) of Process:
-------
Worksheet 2
Worksheet 2 provides a brief description of the process. The main elements of
the process description are the process location, input materials, equipment,
summary of operations performed, process controls, operator training, major
products, and the waste streams affected.
1. Revision No.; List the revision number for this worksheet,
2. Revision Date: List the most recent revision date for this worksheet.
3. PPOA Title: List the PPOA Title given on Worksheet 1.
4. PPOA ID Code(s): List the PPOA ID Code(s) given on Worksheet 1.
5. Process Location: List the best descriptor of the process location. It may
be a department, building, room, etc..
6. Process Description: The process description should detail important
attributes of the process. Equipment, summary of operations
performed, process controls, input materials, and operator training
(qualification or certification) should be included.
7. Description of Major Product(s) of Process: Describe the major products
which result from this process or the reason the process is being
perfromed.
-------
Worksheet 3
Sty to 1
Revision No.:
Revision Date:
Level III
Pollution Prevention Opportunity Assessment
Process Flow Diagram
PPOA Title or PPOA ID Code(s):
Inputs:
Outputs:
Highlight those sections that apply.
: Use Worksheet 4 to identify and
quantify the appropriate stream.
Non-Hazardous
(PRJ)
(PR2)
(PR3)
Solid
Liquid
Air
(HZI)
(HZ2)
(HZS)
Solid
Liquid
Air
(NHI)
(NH2)
(NH|)
Solid
Liquid
Air
(on)
(012)
(ora)
Solid
Liquid
Air
11/93
-------
Worksheet 3
Worksheet 3 provides a process flow diagram for the PPOA. The flow diagram should identify
all PPOA ID Code(s) associated with the process, all input materiats, and outputs
(products/wastes). The flow diagram should track materials from the time they enter the
process boundary until they leave. This diagram represents a very simplistic flow model; a
more detailed diagram may be required to identify all waste streams, especially for complex,
multi-step processes.
1. Revision No.; List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
4. Process Flow Diagram; List the input materials on the lines provided. Fill in the Process
Name box. Then highlight those outputs that are applicable to the process (e.g.
Product, Hazardous, etc.). Then sub-categorize those outputs into solid, liquid, or air
emission streams by highlighting the corresponding output stream. A Stream ID Code is
provided for each sub-category of waste.
5. Outputs: The Stream ID Code provides a uniform coding scheme for the release
information requested on Worksheet 4. A brief waste description may be recorded in the
box to the right of the Stream ID Code.
-------
Revision No.:
Revision Date:
Level III
Pollution Prevention Opportunity Assessment
Process Flow Diagram
PPOA Title or PPOA ID Code(s):
Inputs:
Solid
Liquid
Air
(on)
(^2)
(OT3)
Solid
Liquid
Air
•tt:vX-^x<<<<<<^x<*x-x-:-:-x*:^;-;-x-X"X"X"X^
m ^^mismmm^^mmmm^^ff^^^^msmmrmmmm
quantify the appropriate stream.
(pm)
(pj§)
(PRS)
Solid
Liquid
Air
Solid
Liquid
Air
(HZI)
(nz2)
(HZS)
Solid
Liquid
Air
(em)
(5^
(RDS)
Solid
Liquid
Air
11/93
-------
Worksheet 3
Worksheet 3 provides a process flow diagram for the PPOA. The flow diagram should identify
all PPOA ID Code(s) associated with the process, all input materials, and outputs
(products/wastes). The flow diagram should track materials from the time they enter the
process boundary until they leave. This diagram represents a very simplistic flow model; a
more detailed diagram may be required to identify all waste streams, especially for complex,
multi-step processes.
1. Revision No.: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
4. Process Flow Diagram: List the input materials on the lines provided. Fill in the Process
Name box. Then highlight those outputs that are applicable to the process (e.g.
Product, Hazardous, etc.). Then sub-categorize those outputs Into solid, liquid, or air
emission streams by highlighting the corresponding output stream. A Stream ID Code is
provided for each sub-category of waste.
5. Outputs: The Stream ID Code provides a uniform coding scheme for the release
information requested on Worksheet 4. A brief waste description may be recorded in the
box to the right of the Stream ID Code.
-------
: •: •: -x—x-^xvx-x>> x-x-x->x •: •
Level
Revision No.:
Revision Date:
Pollution Prevention Opportunity Assessment
Process Flow Diagram
PPOA Title or PPOA ID Code(s):
Inputs:
Solid
Liquid
Air
/Process:
Outputs:
(Jim)
(NH2)
(NH^)
Solid
Liquid
Air
Product
Hazardous- RCRA
Hazard, non RCRA
Toxic, TSCA
Non-Hazardous
Other
to worksheet 3B
(for radioactive wastes)
(pm)
(PR2)
(PR3)
Solid
Liquid
Air
Solid
Liquid
Air
(HRI)
(HR2)
(HRS)
Solid
Liquid
Air
(HNI)
(HN2)
(HN3)
Solid
Liquid
Air
11/93
-------
Worksheet 3A
Worksheet 3 provides a process flow diagram for the PPOA. The flow diagram should
represent all PPOA ID Code(s) associated with the process, all input materials, and outputs
(products/wastes). The flow diagram should track materials from the time they enter the
process boundary until they leave. This diagram represents a very simplistic flow model; a
more detailed diagram may be required to identify all waste streams, especially for complex,
multi-step processes.
1, Revision No.: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet!
4. Process Flow Diagram: List the input materials on the lines provided. Fill in the
Process Name box. Then highlight those outputs that are applicable to the process
(e.g. Product, Hazardous, etc.). Then categorize those outputs into solid, liquid, or
air emission streams by highlighting the corresponding output stream. A Stream ID
Code is provided for each category of waste.
5. Outputs: The Stream ID Code provides a uniform coding scheme for the release
information requested on Worksheet 4. A brief waste description may be recorded
in the box to the right of the Stream ID Code.
DOE Definitions:
Hazardous Waste - Waste, which because of its quantitiy, concentration, or physical,
chemical or infectious nature may (a) cause or significantly contribute to an increase
in mortality or an increase in serious irreversible, or incapacitating reversible illness,
or (b) pose a substantial present or potential hazard to human health or the
environment when improperly treated, stored, transported, disposed of, or otherwise
managed. Hazardous waste can be further defined as:
RCRA-reguIated - solid waste not specifically excluded from regulation under 40 CFR
261.4, or delisted by petition, that is either a listed hazardous waste (40 CFR 261.30 -
261.33) or exhibits the characteristics of a hazardous waste (40 CFR 261.20 -
261.24).
Non RCRA-regulated - any other hazardous waste not specifically regulated under
TSCA or RCRA, which may be regulated by the state or local authorities, such as
used oil.
TSCA Waste - Individual chemical wastes (both liquid and solid), such as polychlorinated
biphenyls (PCBs).
-------
Revision No.:
Revision Date:
Level
Pollution Prevention Opportunity Assessment
Process Flow Diagram
PPOA Title or PPOA ID Code(s):
Solid
Liquid
Air
from Worksheet 3A
Outputs:
(LMI)
(LM|)
(LMJ)
Solid
Liquid
Air
High Level
Transuranic, (TRU)
TRU, Mixed
Low Level
Low Level, Mixed
Other, Rad
Solid
Liquid
Air
(ryj)
(?U2)
(rua)
Solid
Liquid
Air
(TMI)
(TM2)
(TMS)
Solid
Liquid
Air
(LLJ)
(J£2)
(E)
Solid
Liquid
Air
11/93
-------
Worksheet 3B
Worksheet 3 provides a process flow diagram for the PPOA. The flow diagram should
represent all PPOA ID Code(s) associated with the process, all input materials, and outputs
(products/wastes). The flow diagram should track materials from the time they enter the
process boundary until they leave. This diagram represents a very simplistic flow model; a
more detailed diagram may be required to identify all waste streams, especially for complex,
multi-step processes.
1. Revision No,: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
4. Process Flow Diagram: List the input materials on the lines provided. Fill in the
Process Name box. Then highlight those outputs that are applicable to the process
(e.g. Product, Hazardous, etc.). Then categorize those outputs into solid, liquid, or
air emission streams by highlighting the corresponding output stream. A Stream ID
Code is provided for each category of waste.
5. Outputs: The Stream ID Code provides a uniform coding scheme for the release
information requested on Worksheet 4. A brief waste description may be recorded
in the box to the right of the Stream ID Code.
DOE Definitions:
High Level Waste- Irradiated reactor fuel, liquid wastes resulting from operation of the
first cycle solvent extraction system, or equivalent, and the concentrated wastes
from subsequent extraction cycles, or equivalent, in a facility for reprocessing
irradiated reactor fuel, and solids into which such liquid wastes have been
converted. (10CFR60.2)
Transuranic Waste - Waste that is contaminated with alpha-emitting radionuclides with
(1) an atomic number greater than 92 (heavier than uranium); (2) half-lives greater
than 20 years; and (3) concentrations greater than 100 nanocuries per gram of
waste.
Transuranic Mixed Waste: - Waste which contains both transuranic waste and
hazardous components, as defined by the Atomic Energy Act and RCRA,
respectively.
Low Level Waste: - Radioactive Waste not classified as high level waste, transuranic
waste, spent nuclear fuel, or by-product material [specified as uranium or thorium
tailings and waste in accordance with DOE Order 5820.2A].
Low Level Mixed Waste: - Waste which contains both low level waste and hazardous
components, as defined by the Atomic Energy Act and RCRA, respectively.
-------
Level III
Time frame
From:
To:
Polli
Material
Description
Totals/Subtotals
Total
Input
ution Prevention Opportunity Assessment
Mass Balance Summary
PFOA Title or PPOA ID Code(s):
Total
Output
Stream
ID Code
o
Stream
ID Code
O
Stream
ID Code
O
Stream
ID Code
O
Stream
ID Code
O
Stream
ID Code
O
Revision No.;
Revision Date:
Page
Of
Stream
ID Code
O
Stream
ID Code
O
Stream
ID Code
O
11/93
-------
Worksheet 4
A material balance is a summation of the total quantity of input material
to a process and the releases to the environment, another process, or
made into product. The purpose of Worksheet 4 is to tabulate this
information and total the inputs and outputs for all streams.
1. Revision No.: List the revision number of the PPOA.
2.
3.
Revision Date: List the most recent revision date for the PPOA
worksheet.
PPOA Titie/PPOA ID Code(s):
given on Worksheet 1.
List the PPOA Title or ID Code(s)
4. Page
of
Indicate the page number for this worksheet and
the number of pages for this worksheet.
5. From/To: Report the dates (month and year) for the time period
covered. An annual period is suggested for purposes of averaging
and documenting performance toward facility goals.
6, Material Description: List the material name and stock number
(optional) or the output product if different than originating material.
7. Units : Enter the unit of measure for the input/output summary.
A consistent unit of measurement is suggested. If requirements
dictate mixing units, designate the units for a particular column
under the Stream ID Code heading.
8. Total Input: For the material described in the far left column enter the
weight of material used in the process during the time frame
specified.
i. Total Output: For the material specified in the Material Description
column enter the weight of the output. This is the sum of all waste
streams and any product generated. For processes where chemical
reactions take place, input materials are consumed or changed to
different compounds, a separate entry in the Material Description
column is required to adequately define the output. In these cases,
the input and output quantities will not balance for the listed
material in that row.
10. Output Quantity: Use these columns to break down the total output
into output categories. Refer to Worksheet 3 for the appropriate
Stream ID Code for the output type. Enter the Stream ID Code at
the top of the column (e.g., HZ1 for a hazardous solid waste
stream), then enter the discharge amount for the material described
in the Material Description column that relates to that Stream ID
Code. Continue across the worksheet for all Stream ID Code(s)
utilized in Worksheet 3.
11. Totals/Subtotals: Sum the Total Input, Total Output, and Output
columns. Record the sum at the bottom row of the last worksheet.
Subtotals are recorded at the bottom row for other pages of the
worksheet. The Total Input column should equal the Total Output
column unless there is system accumulation. The Total Output
column should also be the sum of all the Stream ID Code output
streams.
Stream ID Codes:
Designator
Product
Hazardous
Non-Hazardous
Radioactive
Mixed
Other
Hazardous, RCRA
Hazardous, Non-
RCRA
Toxic, TSCA
High Level
Transuranic, TRU
TRU, Mixed
Low Level
Low Level, Mixed
Other, Radioactive
Style 1
PR
HZ
NH
OT
Style 2
PR
HZ
NH
RD
MX
OT
Style 3
PR
NH
OT
HR
HN
TS
HL
TU
TM
LL
LM
OR
Solid Stream = 1, Liquid Stream = 2, Air Stream = 3
Style refers to the version of Worksheet 3 used.
-------
Worksheet 5
Level
Revision No.: _
Revision Date:
Page of _
Pollution Prevention Opportunity Assessment
Material Cost
PPOA Title or PPOA ID Code(s):
Input Material Cost:
Material
Stock Number
(if applicable)
Waste Disposal Cost:
Material / Waste Stream
Waste Stream
Category
Cost Per
Unit
Total /
Subtotal
Annual Cost
Cost Per
Unit
Total /
Subtotal
Annual Cost
-------
Worksheet 5
Worksheet 5 details the cost of the PPOA input materials (use the quantities from
Worksheet 4) and the cost of disposal for these materials. The material cost may be
obtained from Purchasing or Stores. The cost of disposal may be obtained from Waste
Management or Accounting. Annual Cost is calculated from the amount of material placed
in the process or from the amount of disposed material, multiplied by the cost per unit.
1. Revision No.: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. Page of : Indicate the number of this page and the total number of pages for
this worksheet.
4. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
5. Input Material Cost: List the material, stock number (if applicable), cost per unit
($/lb., $/gal, etc.), and the annual cost for this process.
6. Waste Disposal Cost: List the material or waste stream, waste stream category, (e.g.,
hazardous liquid), stock number if applicable, the cost per unit ($/lb., $/gal, etc.),
and annual cost.
7. Totals / Subtotals: Record the sum of the annual costs for the materials or waste
streams listed. There will be a total for both the input material cost and waste
disposal cost.
-------
Worksheet 6
Level III
Pollution Prevention Opportunity Assessment
Option Generation
PPOA Title or PPOA ID Code(s);
Practices &
Procedures
Revision No.:
Revision Date:
Material
Substitution
fidr Prlaceis
Equipment
Modification
Pollution
Prevention
Options
11/93
-------
Worksheet 6
Worksheet 6 provides a tool for option generation.
The purpose of this diagram (sometimes referred to
as a Fishbone Diagram) is to help generate pollution
prevention ideas. It is especially useful in a
brainstorming session to group ideas undersimilar
pollution prevention categories. It also helps insure
that all of the pollution prevention categories are
considered.
1. Revision No.: List the revision number for this
worksheet.
2. Revision Date: List the most recent revision date
for this worksheet.
3. PPOA Title or PPOA ID Code(s): List the PPOA title
or PPOA ID Code(s) given on Worksheet 1.
4. Brainstorming ideas: Using the Fishbone
Diagram, briefly document ideas for pollution
prevention.
The following definitions clarify each of the major
categories.
Practices & Procedures - Good operating
practices and procedures apply to the human
aspect of operations. They are largely
efficiency improvements. Examples are:
Pollution Prevention Programs, personnel
training, material handling & inventory
practices, material loss prevention, scrap
reduction, cost accounting, production
scheduling, etc.
Material Substitution ~ Changes to the input
materials of the process. The result is a
reduction or elimination of a pollutant or
hazard.
New Product &/or Process -- Product changes
which result in the reduction or elimination of
waste. In addition, a different process can be
used to create the same product with the intent
of minimizing waste.
Waste Segregation/Hazard Reduction -- Actions
taken to segregate waste streams to prevent
nonhazardous waste from being designated
and handled as hazardous. Hazard reduction
can result from changes to the physical,
chemical, or biological character or
composition of the waste. These include
neutralization, toxicity reduction, or volume
reduction.
Equipment Modification -- Changes that occur to
the equipment used in a process. These could
include minor adjustments, additions, or
complete replacements.
Recycling - A material is recycled if it is used,
reused, or reclaimed: (1) if it is used for
something other than its original purpose, (2) if
it goes back into the original process, or (3) if it
is chemically or physically treated for use or
reuse.
-------
Level III
Revision No.:
Revision Date:.
Page pf_
Pollution Prevention Opportunity Assessment
Option Description
PPOA Title or PPOA ID Code(s):
Option Name and Description
( Include input materials, products affected, and anticipated reduction quantity.)
Option No. :
Practices & Procedures
Material Substitution
New Product &/or Process
Option No.
Consider: Yes No
Waste Segregation/Hazard Reduction
Equipment Modification
Recycling, Reuse, & Reclamation
Practices & Procedures
Material Substitution
New Product &/or Process
Option No.
Consider: Yes No
Waste Segregation/Hazard Reduction
Equipment Modification
Recycling, Reuse, & Reclamation
Practices & Procedures
Material Substitution
New Product &/or Process
Option No.
Consider: Yes No
Waste Segregation/Hazard Reduction
Equipment Modification
Recycling, Reuse, & Reclamation
Practices & Procedures
Material Substitution
New Product &/or Process
Consider: Yes No
Waste Segregation/Hazard Reduction
Equipment Modification
Recycling, Reuse, & Reclamation
11/93
-------
Worksheet 7
The purpose of this worksheet is to further document the pollution prevention options
identified on Worksheet 6. The process by which options are identified should occur in an
environment that encourages creativity and independent thinking. Brainstorming sessions
are effective ways for individuals to generate options. Consideration of the options
generated in a brainstorming session can lead to questions. Answering these questions
may require additional research. Listed below are some of the sources that can help to
answer questions and/or generate additional options.
Literature searches
Technical conferences
Equipment exhibitions
Trips to other plants
Vendor surveys
Contact with design engineers
Contact with personnel in other departments who have participated in similar
PPOAs
Materials engineers
Benchmarking
1.Revision No.: List the revision number for this worksheet.
2. Revision Date; List the most recent revision date for this worksheet.
3. PPOA Title or PPOA ID Code: List the PPOA Title or PPOA ID Code given on
Worksheet 1.
4. Page of : Indicate the number of this page and the total number of pages for this
worksheet.
5. Option: Options generated should be numbered consecutively and placed on this
worksheet (reference Worksheet 6). They may or may not be evaluated. Briefly
describe each option, affected materials and product, any roadblocks to
implementation, upstream and downstream impacts if implemented, and
anticipated reduction quantity.
6. Consider Yes/No: If the suggestion is worth further consideration, check
'Yes1. If the suggestion will not be pursued, check 'No' and indicate
briefly in the Option Description why not.
7. Practices & Procedures, Material Substitution, New Product &/or Process, Waste
Segregation/ Hazard Reduction, Equipment Modification, and Recycling, Reuse, &
Reclamation: Check the appropriate descriptions. See Worksheet 6 for definitions.
-------
Worksheet 8
Level III
Revision No,:
Revision Date:
Page
of
Pollution Prevention Opportunity Assessment
Options Cost Evaluation
PPOA Title or PPOA ID Code(s):
Option No.:
Option No.:
Option No.:
Option No.:
Purchased Equipment
Installation
Materials
Utility Connections
Engineering
Development
Start up / Training
Administrative
Other
Total Implementation
Cost
Option No.:
Incremental Operating Costs
Change in Raw
Materials
Change in Maintenance
Change in Labor
Change in Disposal
Other
Annual Operating
Savincjs/(Cost)
Penalties and Fines
Future Liabilities
Other
Annual Intangible
Savings/(Cost)
Total Annual
Savings/(Cost)
Payback Period
incremental jfritang
|$e Costs
11/93
-------
Worksheet 8
This worksheet provides a method to compare and contrast the pollution prevention options
generated on Worksheet 6 from a cost perspective. The three major cost categories for
weighing options are: Implementation Costs, Incremental Operating Costs, and incremental
Intangible Costs. These costs are totaled for each option considered from Worksheet 7.
This worksheet will aid in completing the economic evaluation portion of Worksheet 9.
1. Revision No.: List the revision for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. Page of : Indicate the number of this page and the total number of pages for
this worksheet.
4. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
5. Implementation Cost: These are the one-time, first-year costs associated with the
implementation of each option. Installation costs should be reported as an estimate.
Implementation Cost may include materials, utility connections, site preparation,
installation, engineering, procurement, start-up, training, permitting, initial catalysts and
chemicals, and working capital; minus the salvage value of any existing equipment.
6. Annual Operating Savings/(Costs): These are the costs associated with day-to-day
operations. List the incremental costs compared to the current process costs (positive for
savings or negative for increased costs) that would be incurred if this option is
implemented. Incremental operating costs could include waste disposal, raw material
consumption, ancillary catalysts and chemicals, labor, maintenance and supplies,
insurance, incremental revenues from increased / decreased production, and incremental
revenues from marketable by-products.
7. Annual Intangible Savings/(Cost): These include hidden, liability, and other costs not
immediately obvious for each option. List the incremental costs compared to the current
process costs (positive for savings or negative for increased costs) that would be incurred
if this option is implemented. These costs could include penalties and fines, future
liabilities (storage, transportation, and disposal of hazardous waste), reporting, consulting
fees, monitoring/testing, record keeping, preparedness and protective equipment,
medical surveillance, manifesting, inspections, and corporate/public image.
8. Total Annual Cost/Savings: This is the sum of the Annual Operating Savings/(Cost) and
the Annual Intangible Savings/(Cost)
S. Payback Period: Divide the Total Implementation Cost by the Total Annual
Savings/(Cost).
-------
Worksheet 9
Level Hi
Pollution Prevention Opportunity Assessment
Weighted Sums Option Evaluation
PPOA Title or PPOA ID Code(s):
Revision No.:
Revision Date:
Page of
Criteria
Public Health, Safety, &
Environment
Employee Health &
Safety
Regulatory Compliance
Economic
Implementation Period
Improved Operation /
Product
Other
Subtotal
Likelihood of Technical
Success (Multiplier)
Likelihood of Useful
Results (Multiplier)
Total
Rank
Weight
W
10
10
8
6
4
2
Ilillii I?
1
111 ;
Option N
Scale
'S'
X
X
o.:
•WxS'
Option N(
Scale
'S'
X
X
a.:
'WxS1
Option N<
Scale
'S'
X
X
iililiiii
D.:
'WxS'
Option N
Scale
'S1
X
X
o.:
'WxS'
Option N
Scale
'S*
X
X
o.:
'WxS1
-------
Many pollution prevention options will be identified in a successful assessment. At this point, it is necessary to identify those
options that offer real potential to minimize waste and reduce costs. Worksheet 9 serves as a screening tool to prioritize or
eliminate suggested options.
1. Revision No.: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. Page
of : Indicate the number of this page and the total number of pages for this worksheet.
4. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on Worksheet 1.
Additional Instructions:
a. The values in the Weight column (designated by W)
represent the facility's priority for the criteria.
b. In the Scale column for each option (designated by 'S'),
rate each criteria by assigning a value from 0-10
(lowest to highest). Use the definitions which follow to
help determine a value.
c. In the 'W x S' column for each option, enter the product of
the weight and scale.
d. Sum the 'W x S1 column for each option to obtain a subtotal.
e. Multiply the subtotal for each option by the Likelihood of
Technical Success.
f. Multiply the value in step e. above for each option by the
Likelihood of Useful Results.
g. Enter the product found in step f. in the Total column for
each option.
h. Assign a priority rank for each option; #1 for the highest
score, #2 for the next highest, and so on.
-------
Worksheet 9 -- (Scale & Multiplier Definitions)
Scale Factor Definitions (0-10)
10
Reduce the risk of loss of life or long-term
environmental damage. High concentrations of
hazardous materials.
8
Reduce the risk of long-term disability or moderate
environmental damage. Moderate concentrations
of hazardous materials.
Reduce the risk of short-term disability or
unplanned releases to the environment. Low
concentrations of hazardous materials.
No effect.
0
Negative effect.
10
Reduce the risk of loss of life through an accident
or long-term exposure.
8
Reduce the risk of permanent or long-term
disability through an accident or long-term
exposure.
Reduce the risk of short-term disability or lost-time
through an accident or long-term exposure.
No effect.
0
Negative effect.
10
Reduce the risk and avoid criminal penalties.
8
Reduce the risk and avoid civil penalties.
Reduce the risk.
No effect.
0
Negative impact.
10
Large savings and short payback.
8
Moderate savings and moderate payback.
Positive cost savings and extented payback.
No cost savings and no possibility of payback.
0
Negative cost savings.
10
Immediate (e.g., within 1 month).
8
Short-term (e.g., within 1 year).
Intermediate (e.g., within 2 years).
Long-term (e.g., within 3 years).
0
Greater than 3 years.
10
8
6
4
0
Significant improvement.
Moderate improvement.
Positive improvement.
No improvement.
Negative effect.
-------
Worksheet 9 - (Scale & Multiplier Definitions)
Multiplier Definitions (0-1)
High likelihood: No major technical breakthrough
required. Well-designed plans to meet objectives
and successful track record exists.
0.5
Medium likelihood: Technical advancements may
be necessary. Key issues are identified but no
specific contingency plans have been made.
0.1
Low likelihood: Major technical breakthroughs are
required. Adequate plans for meeting objectives or
key problems have not been Identified.
^^: M^
High likelihood: Project has demonstrated that it
can meet production requirements. There is a high
confidence that implementation will not create
unacceptable risks. Benefits outweigh the costs.
0.5
Medium likelihood: Project has not yet
demonstrated that it can meet production
requirements. There are reservations that
implementation can be achieved without creating
unacceptable risks. Benefits do not clearly
outweigh the costs.
0.1
Low likelihood: The option is not capable of
demonstrating that it can meet production
requirements. Serious reservations are present
that implementation can be achieved without
creating unacceptable risks. Costs significantly
outweigh the benefits.
-------
Level III
Revision No.:_
Revision Date:_
Page of.
Pollution Prevention Opportunity Assessment
Final Report Check Sheet
PPOA Title or PPOA ID Code(s):
Requirement Completed
Title Page
PPOA Title
PPOA ID Code(s)
Team members
Issue date/revision date/revision no,
Executive Summary
Process description
Process assessment
Option summary and analysis
Conclusions
Recommendations
Introduction
Background of evaluation
Process Description
Associated equipment
Process flow diagram
Process Assessment
Methodology
Material Balance
Unusual occurrences
Option Summary and Analysis
Option description and rank
Upstream/Downstream impacts
Material usage
Anticipated reduction
Estimated costs
Estimated benefits
Feasibility
Waste streams affected
Conclusion
Concluding evaluation
Option analysis decisions
Concerns
Options already implemented
Lessons learned
Recommendations
Future work
New equipment
Implementation strategies
Worksheets
1-10
-------
Worksheet 10
A final report is required for each PPOA. The final report is a compilation of essential facts
about the process, pollution prevention options, feasibility and impact of those options, and
future implementation costs. The report documents the work performed and identifies
funding requirements necessary to implement pollution prevention options. The length of
the final report will depend on the complexity of the PPOA.
1. Revision No.: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. Page of : Indicate the number of this page and the total number of pages for
this worksheet.
4. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
5. While writing the final report, check the blank next to each major requirement as all
elements of that task are completed.
Title Page
Executive Summary
Introduction
Process Description
Process Assessment
Option Summary
& Analysis
Conclusion
Recommendations
Uniquely identify the PPOA, including team members and
issue/revision date.
This should be an overview of all of the elements of the final
PPOA report. It should relate to the reader any information that
is critical about this PPOA.
Present background information and efforts taken to initiate the
PPOA.
Detail process flow and associated equipment. Include
process flow diagram, if desired.
Describe the approach used to complete the PPOA. Document
any assumptions made. Include information on the material
balance.
Present the options generated, impacts if implemented, and
their respective pollution prevention possibilities.
Provide closure to the report. The team's consensus on the
benefits achieved from this PPOA or any concerns respective to
the process should be included.
Describe any actions that will be taken to further advance the
results of this PPOA.
-------
Level I Date:
Page of.
TOe:
Pollution Prevention Opportunity Assessment
Team & Process Description
PPOAIDCode:
Team Members ('Leader) Job Classification Phone
Process Description:
Potential for Pollution Prevention or Recommendations:
11/93
-------
Worksheet 1S
This worksheet provides the scope arid identification of the pollution prevention
opportunity assessment (PPOA) team. For the PPOA to be successful,
employees involved with the activity being assessed should be members of the
team. The assessment team needs a leader, members, and additional
resources, as required.
The team leader should have technical knowledge of the area's operations and
the personnel involved. The leader shall assemble the team to perform the
assessment. Team members may include engineers, waste generators,
waste management specialists, scientists, laboratory technicians, and other
line personnel. Additional resources may be utilized to provide information not
available within the team. The size of the team may be large for complicated
operations, but should be kept to a minimum to maintain focus.
1. Date: List the initiation date for this PPOA.
2. Title: List the PPOA title selected by the team.
3. PPOA ID Code: List the PPOA ID Code selected by the team. This should
be a unique identifier.
4. Team Members, Job Classification, Phone: To facilitate team meetings
and for future reference, this information should be completed when the
PPOA team is formed.
5. Process Description: This should detail important attributes of the
operation. Equipment, summary of operations performed, controls,
input materials, and operator training (qualification or certification) may
be included.
6. Potential for Pollution Prevention or Recommendations: For this process,
describe the potential for pollution prevention, source reduction, and/or
waste minimization. (Is there any pollution prevention potential for the
following changes: material substitution, procedures, process
parameters, equipment, general practices, recycling, reuse, reclamation,
etc.?) Are there any recommendations for this process?
-------
Level I
Date:
Pollution Prevention Opportunity Assessment
Process Flow Diagram
Title or Assessment ID Code:
Inputs:
(MXI)
(MX2)
(MXS)
Solid
Liquid
Air
Solid
Liquid
Air
Solid
Liquid
Air
Solid
Liquid
Air
(NHI)
(NH2)
(NH3)
Solid
Liquid
Air
Solid
Liquid
Air
-------
Worksheet 2S
This worksheet provides a method to document the process flow diagram for
the assessment. The flow diagram should identify all Assessment Code(s)
associated with the process, all input materials, and outputs
(products/wastes). The flow diagram should track materials from the time they
enter the process boundary until they leave. This diagram represents a very
simplistic flow model; a more detailed diagram may be required to identify all
waste streams, especially for complex, multi-step processes.
1. Title or Assessment ID Code(s): List the PPOA Title or PPOA ID Code given
on Worksheet 1S.
2. Page of.
Indicate the page number for this worksheet and the
number of pages for this worksheet.
3. Inputs: List the input materials on the lines provided. Fill in the Process
Name box. Then highlight those outputs that are applicable to the process
(e.g. Product, Hazardous, etc.). Then sub-categorize those outputs into
solid, liquid, or air emission streams by highlighting the corresponding
output stream. A Stream ID Code is provided for each sub-category of
waste.
4. Outputs: The Stream ID Code provides a uniform coding scheme for the
release information. A brief waste description may be recorded in the box
to the right of the Stream ID Code. The code information is summarized in
the table below:
Stream ID Codes
Designator
Product
Hazardous
Non-Hazardous
Radioactive
Mixed
Other
Code
PR
HZ
NH
RD
MX
OT
Solid Stream = 1, Liquid Stream = 2, Air Stream = 3
-------
Level I
Page
of
Pollution Prevention Opportunity Assessment
Material & Waste Stream Summary
Title:
PPOA ID Code:
Input
Material
Annual
Quantity
Used
%
Product
%
Recycled
Total Releases
%
Air
%
Liquid
%
Solid
Does the process require further analysis based on the site's Priority
Material/Waste Stream List? Yes No
Level II Level
-------
Worksheet 3S
This worksheet provides a brief summary of the input materials and output
streams from the operation or activity being assessed. Its purpose is to
provide the pollution prevention team an overview of the waste streams
resulting from the PPOA.
1. Title: List the PPOA title given on Worksheet 1S.
2. Assessment ID Code: List the PPOA ID Code given on Worksheet 18.
3. Input Material: List the material names which enter the operation.
4. Annual Quantity Used: Enter the annual quantity used for each material
listed - include the unit of measure, e.g., Ibs, curies, etc. For input
material from another process, it may be helpful to also identify the
release components of those materials.
5. % Product: For each input material, estimate the percent of the annual
quantity used which goes to product.
6. % Recycled: For each input material, estimate the percent of the annual
quantity used which is recycled.
7. % Air: For each input material, estimate the percent of the annual quantity
used which is an air waste stream.
8. % Liquid: For each input material, estimate the percent of the annual
quantity used which is a liquid waste stream.
i. % Solid: For each input material, estimate the percent of the annual quantity
used which is a solid waste stream.
10. Does the process require further analysis based on the site's Priority
Material/Waste Stream List? Using your site's Priority Material/Waste
Stream List and the DOE Graded Approach Logic Diagram, determine if
further assessment is necessary. If yes, indicate the level of
assessment required.
-------
Worksheet 45
Level II
Page
of.
Pollution Prevention Opportunity Assessment
Option Summary
Title or PPOA ID Code(s)
Option h
o. :
Type
<*)
Option N
Consider?
Feasibility
Estimated
Cost
Estimated
Savings
Anticipated
Reduction Qty
o. :
Type
n
Option N
Consider?
Feasibility
Estimated
Cost
Estimated
Savings
Anticipated
Reduction Qty
o. :
Type
(*)
Consider?
Feasibility
Estimated
Cost
Estimated
Savings
Anticipated
Reduction Qty
(*) Type = Source Reduction, Recycling, Treatment, or Disposal
11/93
-------
Worksheet 4S
This summary sheet serves as a method to record and evaluate the options that have been
identified during brainstorming sessions or other option generating techniques.
1. Title or PPOA ID Code{s): List the PPOA Title or PPOA ID Code given on Worksheet 1S.
2. Option : Options generated should be numbered consecutively. Briefly describe each
option, affected materials, waste streams, upstream/downstream impacts if
implemented, and anticipated reduction quantity if implemented.
3. Type: Indicate whether the option is source reduction, recycling, treatment, or disposal.
4. Consider?: If the option is worth further consideration, enter YES. If not, enter NO and
briefly indicate in the Option Description why not.
5. Feasibility: Provide a brief description. (Excellent, good, fair, poor)
6. Estimated Cost: Estimate an implementation cost.
7. Estimated Cost Savings: Estimate the cost savings.
8. Anticipated Reduction Qty.: Estimate the weight or volume of the waste that will be
reduced.
Note: Typically, it is difficult to estimate the anticipated waste reduction or cost avoidance in
the initial phases of implementation because of many factors. However, for some options,
especially in cases where the option provides complete elimination of a hazardous material
or waste stream, these estimates can be accurately completed.
The process by which options are identified should occur in an environment that encourages
creativity and independent thinking. Brainstorming sessions are effective ways for
individuals to generate options. To make these sessions beneficial, research is often
necessary. Provided below is a fishbone diagram that will help the team generate ideas.
Pollution
Prevention
Options
-------
Level II
Date:
Page of.
Pollution Prevention Opportunity Assessment
Final Summary
Title:
PPOA ID Code(s):
Assessment:
Conclusions:
Recommendations:
-------
Worksheet 5S
This sheet provides a brief summary of other pertinent information about the activity
being assessed. Its purpose is to document how this assessment was performed,
the conclusions reached by the team, and the recommendations for further actions.
1. Date: List the date this sheet was completed,
2. Title: List the title given on Worksheet 1S.
3. PPOA ID Code(s): List the ID Code(s) given on Worksheet 1S.
4. Assessment: Briefly describe the approach (methodology) used to complete this
assessment and any assumptions made.
5, Conclusions: Briefly describe the waste streams or input material to be
minimized, benefits achieved from this assessment, and any concerns
(environmental or health risks) associated with the material or operation.
6. Recommendations: Briefly describe any actions that should or will be taken in
respect to this assessment.
-------
APPENDIX H
REFERENCES
1. U.S. Department of Energy, General Environmental Protection Program, DOE
Order 5400.1 (November 9, 1988).
2. U.S. Department of Energy, Hazardous and Radioactive Mixed Waste Program,
DOE Order 5400.3 (February 22, 1989).
3. U.S. Department of Energy, Radioactive Waste Management, DOE Order
5820.2A (September 26, 1988).
4. U.S. Department of Energy, Environmental Restoration and Waste Management
Five-Year Plan, DOE/S-0070 (1989).
5. U.S. Department of Energy, Applied Research Development, Demonstration,
Testing and Evaluation Plan (Draft) (November 1989).
6. U.S. Department of Energy, Model Waste Minimization and Pollution Prevention
Awareness Plan (1990).
7. U.S. Department of Energy, Process Waste Assessment Guidance (ISO).
8. U.S. Environmental Protection Agency, Facility Pollution Prevention Guide
EPA/600/R-92/088 (May 1992).
9. M.I. Baker and F.E. Kosinski, Process Waste Assessments for Waste Minimization
Planning, U.S. Department of Energy, Oak Ridge Y-12 Plant, Y/DZ-532
(November 21, 1989).
10. E.A. Kjeldgaard, J.H. Saloio, and G.B. Varnado, Development and Test Case
Application of a Waste Minimization Project Evaluation Method, U.S. Department
of Energy, Sandia National Laboratories, SAND90-1178 (August 1990).
11. H.M. Freeman, Hazardous Waste Minimization, McGraw-Hill Publishing
Company (1990).
12. U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation
and Office of Solid Waste, Pollution Prevention Benefits Manual, October 1990.
13. U.S. Department of Energy/Defense Program's, Office of Production Facilities
-------
&EPA
United States
Environmental Protection
Agency
Office of Research and
Development
Washington, DC 20460
EPA/600/R-92/088
May 1992
Facility Pollution
Prevention
-------
TABLE OF CONTENTS
Page
INTRODUCTION 1
A. PURPOSE OF GUIDANCE 1
B. GUIDANCE SCOPE AND OBJECTIVES 1
II. GRADED APPROACH 3
A. INTRODUCTION 3
B. GRADED APPROACH LOGIC DIAGRAM & PRIORITY LIST 3
C. LEVEL I - ACTIVITY CHARACTERIZATION 5
D. GRADED APPROACH WEIGHTED SUMS EVALUATION 6
E. LEVEL II - INFORMAL ASSESSMENT 7
F. LEVEL III - FORMAL ASSESSMENT 9
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT TEAMS 10
IV. ASSESSMENT OF PROCESSES AND WASTE STREAMS 11
A. INITIAL DATA GATHERING 11
B. PROCESS DESCRIPTION 11
C. PROCESS FLOW DIAGRAM 12
D. MATERIAL BALANCES 13
E. MEASUREMENT OF WASTE 14
F. WASTE STREAM CHARACTERIZATION 15
V. DEVELOPMENT AND EVALUATION OF WASTE
MINIMIZATION/POLLUTION PREVENTION OPTIONS 15
A. IDENTIFICATION OF WMIN/PP OPTIONS 15
B. PRELIMINARY SCREENING OF WMIN/PP OPTIONS 16
C. EVALUATION OF WMIN/PP OPTIONS 17
VI. FINAL REPORT 18
VII. APPENDIX 19
-------
APPENDIX
APPENDIX A: GENERAL CONSIDERATIONS FOR PRIORITIZING THE
ASSESSMENT OF WASTE STREAMS
APPENDIX B: SOURCES OF MATERIAL BALANCE INFORMATION
APPENDIX C: LEVEL I EXAMPLE ACTIVITY CHARACTERIZATION
APPENDIX D:
PPOA GRADED APPROACH WEIGHTED SUMS FORM, CRITERIA,
AND INSTRUCTIONS
APPENDIX E: LEVEL II EXAMPLE INFORMAL ASSESSMENT
APPENDIX F: LEVEL III EXAMPLE FORMAL ASSESSMENT
APPENDIX G:
MODEL POLLUTION PREVENTION OPPORTUNITY
ASSESSMENT WORKSHEETS
APPENDIX H: REFERENCES
FIGURES
FIGURE 1:
FIGURE 2:
FIGURE 3:
PPOA FLOW CHART
PPOA GRADED APPROACH LOGIC DIAGRAM
PPOA GRADED APPROACH WEIGHTED SUMS EVALUATION
-------
LIST OF ACRONYMS
ACGIH
DOE
EPA
ES&H
MNCAW
MSDS
NPDES
ODC
OSHA
PCB
PM/WSL
POTW
PPOA
PWA
VOC
WMin/PP
American Conference of Governmental Industrial Hygienists
Department of Energy
Environmental Protection Agency
Environmental, Safety, & Health
Materials Not Categorized As Waste
Material Safety Data Sheet
National Pollutant Discharge Elimination System
Ozone Depleting Compound
Occupational Safety and Health Administration
Polychlorinated biphenyl
Priority Material/Waste Stream List
Publicly Owned Treatment Works
Pollution Prevention Opportunity Assessment
Process Waste Assessment
Volatile Organic Compound
Waste Minimization/Pollution Prevention
-------
ACKNOWLEDGMENT
In July, 1988, DOE Defense Programs recognized the need for a waste minimization
program that would focus beyond pollution control and the traditional media-by-media
approach to containment and treatment of environmental releases. Defense Programs
was proactive in initiating a Waste Minimization Program that included the completion of
process waste assessments as a means to identify opportunities which would reduce
the generation of waste.
The Waste Minimization Program evolved to a Pollution Prevention Program through the
auspices of the DOE Defense Programs' Pollution Prevention Strategic Plan issued in
April, 1992. The Strategic Plan reiterated the hierarchy of preferred environmental
practices outlined in the Pollution Prevention Act of 1990 (i.e. source reduction,
recycling, treatment, and finally, disposal).
The first Model PWA Guidance was assembled by Defense Programs' contractors
based on the published EPA guidance and previous work performed at the Y-12 Plant.
The manual was originally issued in February 1990, and distributed throughout the
Weapons Complex. This is the first revision to the document, and it replaces the term
"PWA" with a more positive term, "Pollution Prevention Opportunity Assessment". The
new term avoids the implication that assessments should be limited to process wastes,
rather, they should address all releases.
The following DOE personnel and DOE contractors assisted in the suggestions for this
revision. Their time and effort were greatly appreciated.
Frank Adams
EG&G Mound
Don Adoiphson
Sandia National Labs/CA
Doyle Anderson
Raytheon Serv - Nevada
Carl Barr
Westinghouse - Hanford
Angela Bolds
Martin Marietta - Pinellas
Angela Colarusso
DOE/DP - Nevada
Paul Deltete
Analytical Resources Inc.
Cindy Dutro
Reynolds Elect & Eng Co.
George Goode
Brookhaven National Lab
Kent Hancock
DOE/EM-352
Jim Henderson
Raytheon Serv - Nevada
Diana Hovey-Spencer
Desert Research Institute
Dr. Roger Jacobson
Univ & Com Coll - Nevada
Alice Johnson-Duarte
Sandia National Labs/CA
Ed Kjeldgaard
Sandia National Labs/NM
John Marchetti
DOE/DP-64
Elizabeth McPherson
McPherson Env. Resources
Susan Pemberton
AlliedSignal Inc., KCP
Bill SchFosberg
AlliedSignal Inc., KCP
Don Watson
AlliedSignal Inc., KCP
Jill watz
Strategic Env. Services
Jeff Weinrach
Los Alamos National Lab
A point of contact has been established in the DOE complex for Pollution Prevention Opportunity
Assessments. If you are in need of training, assistance, and/or methodology, call or fax your
requests or questions to the following:
Susan Pemberton
AlliedSignal Inc., Kansas City Plant
D/837 2C43
P.O. Box419159
Kansas City, Mo 64141-6159
816-997-5435 (Phone)
816-997-2049 (Fax)
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1. INTRODUCTION
A. PURPOSE OF GUIDANCE
The purpose of this document is to provide a guide for DOE sites to conduct pollution
prevention opportunity assessments (PPOAs), commonly known through the DOE as
process waste assessments (PWAs). This will avoid the implication that assessments
should be limited to process wastes - PPOAs address all releases. This guidance
describes those activities and methods that can be employed to characterize all waste
generating processes and identifies opportunities to reduce or eliminate waste
generation. The document also includes a methodology to evaluate proposed
modifications to site processes and other options to minimize waste and prevent
pollution.
B. GUIDANCE SCOPE AND OBJECTIVES
PPOAs will be conducted as part of an ongoing program to identify opportunities to
eliminate or reduce the generation of waste. A PPOA documents the amount of material
that is disposed of as waste during operations. It provides a summary of material usage,
process by-products, and waste generation; and it targets those processes and
operations that need to be improved or replaced to promote waste minimization and
pollution prevention. The assessment also establishes a basis to prioritize modifications
to site processes or other pollution prevention options that are developed during the
assessment.
The objective of a PPOA is to document a facility's processes, operating procedures,
and waste streams in a manner that will permit the identification of the best
improvements to avoid or minimize waste generation. This guide shall not be used as
an audit tool. The assessment consists of a systematic approach which may include the
following:
GRADED APPROACH LEVEL DETERMINATION
ORGANIZATION OF PPOA TEAMS
ASSESSMENT OF PROCESSES AND WASTE STREAMS
DEVELOPMENT AND EVALUATION OF POLLUTION PREVENTION
OPTIONS
RECOMMENDATIONS OF POLLUTION PREVENTION OPTIONS & FINAL
REPORT
A step-by-step process for completing a PPOA is shown in Figure 1. These steps are
sequential and should be performed in that order for best results.
-------
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
FLOW CHART
FIGURE 1
PLANNING & ORGANIZATION
•
*
ORGANIZE ASSESSMENT TEAM
REVIEW PPOA GUIDANCE
PROCESS ASSESSMENT
*
•
•
•
*
COLLECT & COMPILE DATA
DEVELOP PROCESS DESCRIPTION
GENERATE FLOW DIAGRAM
CALCULATE MATERIAL BALANCE
SUMMARIZE WASTES & COSTS
OPTION GENERATION & EVALUATION
GENERATE AND SELECT OPTIONS
EVALUATE OPTIONS
PPOA FINAL REPORT
•
*
*
SUMMARIZE PROCESS ASSESSMENT
RECOMMEND FEASIBLE OPTIONS
IDENTIFY FUNDING REQUIREMENTS TO
IMPLEMENT OPTIONS
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-------
II. GRADED APPROACH
A. INTRODUCTION
The DOE Complex is comprised of numerous sites located in many different states.
These facilities range from single-mission to multiple-disciplinary facilities, and vary in
size from quite small to very large. The facilities as a whole represent a tremendous
diversity of technologies, processes and activities. Due to this diversity, there is also a
wide variety and number of waste streams generated. Many of these waste streams are
small and intermittent, and not of consistent composition. The value added of detailed
analysis for individual, small waste streams is often not sufficient to justify the cost, nor is
the analysis necessarily meaningful since many of these waste streams are constantly
changing.
Although waste minimization activities have been implemented at DOE sites, these
efforts are not being sufficiently documented. A DOE survey of PPOA activities across
several sites indicated that these waste minimization practices need to be documented
so that waste generation baselines can be more accurately established. Furthermore,
the documentation can ensure that the site receives credit for accomplishing waste
minimization.
The PPOA Graded Approach addresses these complexities and recognizes that
processes vary in the quantity of pollution they generate, as well as in the perceived risk
and hazards associated with an operation. It also recognizes the variance due to the
cost and function of the final product. Therefore, the graded approach is intended to
provide a cost-effective and flexible methodology which allows individual sites to
prioritize their local concerns and align their efforts with the resources allocated, while
also providing some consistency throughout the DOE to perform PPOAs. In order to
achieve this, the approach has defined three levels of effort to satisfy the requirement of
completing a PPOA. This section documents the minimum amount of effort required,
Level I, Activity Characterization, and provides a systematic approach using the
Weighted Sums Evaluation to determine if additional and more detailed analysis should
be conducted for either a Level II, Informal Assessment, or a Level III, Formal
Assessment.
If used properly, the graded approach will allow a site to concentrate its shrinking
resources on the most important waste problems first. While all of the site's waste
streams and processes will be assessed, the most critical areas will be assessed first
and to the greatest extent.
B. GRADED APPROACH LOGIC DIAGRAM & PRIORITY MATERIAL
/WASTE STREAM LIST
Figure 2, the Graded Approach Logic Diagram, illustrates graphically how the graded
approach methodology works. The diagram starts at the top with the Level I, minimum
effort assessment and works down to an informal and/or formal assessment. The
methodology shown in the logic diagram allows flexibility and provides a consistent
-------
FIGURE 2
Pollution Prevention Graded Approach
Logic Diagram
Level I
Activity Characterization
Activity
Enters
Does Process
Use or Generate a
Priority Listed Material
j>r Waste Stream?,
Yes
Apply Weighted
Sums Criteria
Yes
Level III
Formal Assessment
No
Level I-STOP!
Assessment Completed
I As Priority or
Facility Needs
I Change
I
Weighted Sums Score
Higher than xxx?
Level II
Informal Assessment
-------
structure. A site must develop the priority material / waste stream list (PM/WSL) to use
the graded approach. This list is not limited to the requirements specified below but can
include any other additional concerns. (See Appendix A for an additional list of
considerations.) The priority list provides the site an opportunity to identify their
individual regulatory and/or prioritized needs to cost-effectively determine if additional,
more detailed analysis is necessary. DOE has established requirements and
suggestions for this list as follows.
PRIORITY MATERIAL / WASTE STREAM LIST
Required or Mandatory PM/WSL:
• Waste of any amount for which an approved disposal method does not exist
(i.e., mixed wastes, classified waste, etc.)
• Waste which is equal to 5% or more of the facility's total waste stream (Total
waste = Manifest records (Hazardous) + Radioactive + Mixed)
• Clean Air Act, Class I Materials (ODCs - Ozone Depleting Compounds)
• EPA's 33/50 Materials
• Known Human Carcinogens (ACGIH, Type 1)
Suggested Additions to PM/WSL:
• Federal, State, & Local Requirements
» Permitted Waste & Materials (e.g., VOCs, NPDES, POTW, etc.)
• Site Health Risks for Hazardous Materials & Hazardous Wastes (e.g., OSHA -
Suspect carcinogens, teratogens, explosives, PCBs, Asbestos, etc.)
• Municipal Solid Waste
• Materials Not Categorized As Waste Inventory (MNCAW)
C. LEVEL I - ACTIVITY CHARACTERIZATION
Level I, Activity Characterization, requires a minimal amount of descriptive, quantitative,
and qualitative information to document each of the facility's processes and activities
which are defined as "Any existing or planned operation or activity (including
remediation projects) which generates waste or pollution to the air, land, or water." In
gathering this information, the facility begins the initial step to determine whether any
waste reduction or pollution prevention opportunities exist. The collection of this
information will also provide the basis to determine whether or not any of the facility's
-------
processes/activities necessitate further analysis per the graded approach methodology.
Therefore the principle objectives of Level I are to:
* define the process,
« document Waste Minimization / Pollution Prevention (WMin/PP) activities
(past or current),
• determine the level of effort that should be performed for a cost-effective
Pollution Prevention Opportunity Assessment Program, and
• provide information to determine if more analysis is necessary.
Level I Required Documentation
1. A brief process description / simple flow diagram;
2. A quantitative estimate of the material inputs, products, by-products, and
wastes;
3. A preliminary evaluation of WMin/PP potential; and
4. A decision to determine if further analysis is necessary.
Level I process assessments will establish the site's baseline of operational information.
These process/activity descriptions should include input materials, process products, by-
products and/or waste generated. Identification of these elements and estimates of
quantities is made using the best available information source, or combination of
sources. Possible information sources are listed in Appendix B.
In addition to the descriptive information, the potential for WMin/PP can be initially
evaluated based on the activity or process expert's knowledge. These
recommendations should be included in the Level I documentation. If opportunities do
exist and are easily implemented, then the actions taken or planned to be taken should
be documented. Furthermore, for WMin/PP options identified and implemented,
upstream / downstream impacts should also be included in the documentation.
After collecting the process/activity information, it is necessary to determine whether the
process/activity continues to a Level II or III analysis as defined by the graded approach
logic diagram and the site's priority material / waste stream list.
If the process does not contain any of the materials or waste streams on the priority list,
then the Level I documentation satisfies the PPOA requirement. Conversely, those
processes/activities which are captured by the site's priority list are included in the
Weighted Sums Evaluation to determine the next level of effort to be performed.
A completed example Level I Activity Characterization is shown in Appendix C. PPOA
Worksheets 1S-3S can be used to document the information required in a Level I
assessment.
D. GRADED APPROACH WEIGHTED SUMS EVALUATION
The graded approach methodology continues when the site selects a core team to
determine which processes require Level II and Level III assessments. The core team
-------
should be cross-functional and consist of key site personnel with knowledge about the
site's processes, waste management, and regulations. The team's objectives are to
assign weights to the criteria, to determine the numeric value that distinguishes a Level
It from a Level III, and to provide consistency in scoring across processes. The form to
aid in this evaluation (weighted sums) is shown in Figure 3. (Appendix D contains the
weighted sums form, criteria, and instructions.) First the site assigns a weight to each
criteria listed in the first column of the weighted sums. Then, for each process being
evaluated, the team determines a scale for the five listed criteria and a multiplier. From
the products and sums, a total point value is assigned. Finally, the team determines the
cut-off value for which Level II assessments will be completed versus Level III
assessments. Processes identified by the Weighted Sums Evaluation which require a
Level III, Formal Assessment, are those processes that are critical to the site's priorities
and would benefit by the allocation of resources to examine how to best implement
pollution prevention technologies to these critical areas.
E. LEVEL II - INFORMAL ASSESSMENT
After completing the Graded Approach Weighted Sums Evaluation, the facility has
distinguished which processes/activities require the Level II, Informal Assessment. The
principal objectives of Level II are to:
develop and screen WMin/PP opportunities and
recommend viable options for implementation.
This level of effort does not require the collection of new data. Much of the
documentation has already been completed in the Level I assessment. However, due to
some aspect of the process, the facility needs to further explore the WMin/PP
opportunities available to reduce the quantity of waste or the risk/hazard associated with
the operation.
Level II Required Documentation
(1.} Brief process description / simple flow diagram;
{2.} Quantitative estimate of the material inputs, products, by-products, and
wastes;
{3.} Preliminary evaluation of WMin/PP potential;
4. WMin/PP options identification and evaluation;
5. Consideration of potential upstream / downstream impacts; and
6. Recommendations for option implementation.
{} - denotes those items already completed in Level I, Activity Characterization
Further suggested reading for Level II information can be found in sections IV: A-C and
V: A-B. A completed example Level II, Informal Assessment, is shown in Appendix E.
PPOA Worksheets 1S-5S can be used to complete the requirements of a Level II
assessment.
-------
Date:
Page of
FIGURE 3
Pollution Prevention Opportunity Assessment Graded Approach
Weighted Sums Evaluation
Evaluation Criteria
Environmental, Safety,
& Health Hazards
Quantity of Waste
Generated
Site Liabilities
Economic Factors -
Process & Waste Costs
(Unit &/or Annual)
Process By-Product
Management
Other
Subtotal
IwMin/PP Potential
(Multiplier
Total
PPOA Level
Weight
'W1
Site
Assigns
ii
•I
•I
•I
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•i
ii
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Process:
Scale
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8/93
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F. LEVEL III - FORMAL ASSESSMENT
In addition to the information completed in the Level I assessment, the Level III requires
considerably more documentation to complete the PPOA. For example, both the
process description and a corresponding block flow diagram are required to illustrate
the basis of generation. The use of narratives, calculations, photographs, illustrations,
figures and/or data sufficient to convey an understanding of the process are certainly
recommended. The Level III assessment also requires collection of quantitative data for
a material balance. A material balance should be completed to account for all waste
generated. This information, if not already available, may need to be tracked to
accurately establish the current process waste generation information necessary to
complete the WMin/PP options analysis.
The primary objectives of the Level III Assessment are to:
• conduct a detailed analysis of the process for WMin/PP opportunities and
» document the results of the process evaluation in a written report.
Level HI Required Documentation
{1.} Brief process description / simple flow diagram;
{2.} Quantitative estimate of the material inputs, products, by-products, and
wastes;
{3.} Preliminary evaluation of WMin/PP potential;
4. Process description;
5. Flow diagram;
6. Material balance;
7. WMin/PP options identification;
8. Analysis of WMin/PP options generated: economic, technical, upstream /
downstream impacts, and other benefits;
9. Prioritized list of options; and
10. Formal report with documentation and recommendations for option
implementation.
{} - denotes those items already completed in Level I, Activity Characterization
A completed example Level III, Formal Assessment, is shown in Appendix F.
The following sections of this guidance describe the details necessary to achieve the
requirements of a Level III, Formal Assessment. Each of these sections can also be
used as a reference for the information required in the Informal Assessment and Activity
Characterization, Levels II and I, respectively. Blank Model Worksheets have been
included in Appendix G to help guide a team through the PPOA requirements. They are
only suggested forms - they are not requirements. A site may prefer to modify them to fit
their individual site needs. Model PPOA Worksheets 1-10 were developed for the Level
III assessment, PPOA Worksheets 1S-3S were developed for Level I, and Worksheets
1S-5S were developed for a Level II.
-------
III. POLLUTION PREVENTION OPPORTUNITY ASSESSMENT TEAMS
The Waste Minimization and Pollution Prevention Awareness Program Plan states that
assessments of all waste-generating operations at the site will be conducted by PPOA
teams. The team leader should have the authority to complete the assessment, line
responsibility, familiarity with the site's process and waste management operations, and
proven technical and problem-solving abilities (e.g. Value Engineering Specialist).
The remainder of each assessment team should be drawn from line staff, or
subcontractor organizations that can furnish the type of specialized expertise that will be
needed to conduct the assessment. Each PPOA team should consist of a small core of
individuals familiar with the site's operations, who will direct the assessment efforts and
guide the data gathering. The careful selection of personnel to conduct the assessment
is essential. Experienced people familiar with the site's operations are crucial to
completing an accurate and timely assessment. Subsets of this team are satisfactory for
Levels I and II of the graded approach. Other personnel with specialized skills will be
used on a part-time, as-needed basis. Each team may include members who have
knowledge in the following areas:
process operations;
federal, state, and local hazardous waste statutes and regulations;
operation and waste minimization principles and techniques;
quality control requirements;
purchasing procedures;
material control/inventory procedures; and/or
value engineering skills.
Model Worksheets 1 and "IS can be used to record the PPOA team members and the
assessment title and identification (ID) code. The PPOA ID Code should be unique for
each PPOA at the site. For uniformity, the site should determine the structure of this
code.
PPOA team leaders should receive training on the procedures, methodologies,
techniques and documentation requirements for PPOAs before the assessments are
conducted. The team leader needs to have clear authority from the WMin/PP
Coordinator or line management to select other team members, obtain support services,
and to direct the efforts of the assessment team in its interaction with operating
personnel. The team should be given unrestricted access to all facility personnel and
information that may, in the team's estimation, be relevant to the assessment.
-------
IV. ASSESSMENT OF PROCESSES AND WASTE STREAMS
A. INITIAL DATA GATHERING
For each assigned process, the PPOA team begins with gathering data about that
process and associated waste streams. The boundaries of the process must be
established. The team should consider the following process boundary criteria: (1) the
process must have a distinct starting and ending point, (2) the process input materials
must be accounted for, (3) the time frame must be considered, and (4) the process must
be manageable - an appropriate size to collect information and provide focus. The team
will collect information through interviews and the review of process documents that will
permit a thorough understanding of the process to be assessed and the development of
a written analysis on how that process generates waste (see Appendix B for sources of
additional information). The team should also visit the process areas to witness how the
process is conducted and to validate the written information that has been collected.
Each PPOA team should develop and/or collect information as defined in the graded
approach level. The following assessment tools may be used:
• process descriptions,
» process flow diagrams,
• material balances, and/or
• waste stream characterizations for assessment area or process.
Additional guidance may be found in the EPA Facility Pollution Prevention Guide
(Reference #8 of Appendix H) to complete the PPOA.
PPOA team members may identify ways to reduce waste during the data collection
phase. It is at this point that observations about operations, schedules, and procedures
can be noted which may easily be changed to prevent waste. These changes can have
a wide impact. The knowledge and experience of team members and their colleagues
will help to develop these ideas into potential options. The team members should also
make effective use of technical literature from equipment vendors and trade
associations; the experience of plant engineers, operators, and consultants; and the
databases available from environmental agencies.
B. PROCESS DESCRIPTION
The PPOA will include a general description of each process step in the waste
generating operation. The narrative should describe the following:
purpose of the process;
material and equipment used in the process;
equipment layout;
personnel and their experience / training level; and
products, by-products, and waste streams generated.
-------
Model Worksheets 2 and 2S can be used to complete the process description.
Chemicals and other materials purchased or otherwise introduced into the process
should be identified. The description should also include other information that
adequately describes the process and may be relevant to WMin/PP planning. For
example, process or product specifications, requirements, assumptions, and upstream
and downstream impacts may have a critical bearing on waste generation and should
be included in the description.
To further understand the process, the team may perform a function analysis as
explained in the DOE/Defense Program's Prioritization of Pollution Prevention Options
Using Value Engineering (Reference #13 of Appendix H). The principal objective of
function analysis is to discover the basic purposes of a process in contrast to its
secondary or support uses. It aids the team in determining the process1 primary
functions and in minimizing or eliminating secondary functions which, in turn, may
produce unnecessary wastes. The function analysis can help answer the question as to
whether this process is actually necessary.
C. PROCESS FLOW DIAGRAM
The analytical work of the waste assessment effort starts with the development of a
simple process flow diagram for the operation being assessed. The requirement for this
flow diagram is based on the maxim that a picture is worth a 1000 words. It is also the
foundation upon which the material balance is built. The process flow diagram should
identify the major steps within an operation and diagram the flow of materials into and
out of each step during the process. The diagram should indicate the following:
• process steps,
• material inputs, and
• process outputs (e.g., product, by-products and waste streams).
The diagram should also characterize the streams according to the nature of the release
and waste classification, including but not limited to the following:
air,
liquid,
solid,
radioactive,
mixed,
hazardous, and/or
non-hazardous.
Model Worksheets 3 and 2S can be used for the completion of the process flow
diagram. There are three styles to chose from for Model Worksheet 3 depending on the
complexity of the analysis and whether radioactive materials and waste streams are
involved.
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D. MATERIAL BALANCE
The PPOA shall account for all input materials that enter the process which are either
consumed, transferred, or disposed of as waste. This accounting, which is called a
"material balance", will be indicated on the process flow diagram and transferred to a
spreadsheet. A material balance is a tool which is used to provide an input/output
summary of the process being assessed. Closing the balance on an unknown stream
can help identify the constituents in that stream. The material balance should indicate
the following;
* amount of input materials introduced into the process,
• amount of materials consumed,
* amount of materials withdrawn as a product or by-product, and
* amount of materials flowing out of a process as a waste stream.
Using the best available information, the material balance should be closed (i.e., all
input materials and transfers should be accounted for in the product, by-product and
waste streams). The purpose of closing the balance is to identify streams which are
difficult to quantify, e.g. fugitive and point-source emission streams. The material
balance should show the average material flows over a representative time period
which is logical for the site's operations. For example, it may be appropriate to gather
data for Operation A from monthly averages, while a longer time span may be more
appropriate for Operation B. Material balances performed over the duration of a
complete production run are typically the easiest to construct and are reasonably
accurate.
In its simplest form, the material balance is represented by the mass conservation
principle:
Mass in = Mass out + Mass Accumulated
That is, materials placed into a process can be accounted for through products, by-
products, air emissions, water discharges, spills, recycling streams, waste streams,
scrap, out-of-shelf life materials, or out-of-specification materials. All materials
(hazardous and non hazardous) should be accounted for in the input and output
streams. The quantification units for the material balance should be consistent, i.e.
pounds. The Material Safety Data Sheet (MSDS) can be helpful in converting materials
into a common unit.
Measurement of Feed Materials: All input materials that are introduced into a process
must be identified. The amount and type of the input materials can be determined by
examining the following:
• procurement and inventory records;
• processing logs; and/or
» other records that show purchase, transfer, donation, or other receipt of
materials by production unit.
Other examples of information sources are found in Appendix B.
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Products and By-products: The material balance should indicate the amount of
materials leaving the work unit as a product or by-product.
Transfer of Materials: Some materials may be used in a process and then transferred to
another area or process for further processing. The material balance should account for
the transfer of the materials.
E. MEASUREMENT OF WASTE
Information about the quantity and character of the waste streams is a critical component
of the PPOA. Waste stream information should be obtained from sources such as:
site tracking system,
permits and permit applications,
monitoring reports,
hazardous waste manifests,
emission factors,
experiments,
emission or toxic substance release inventories,
hazardous waste reports,
waste analyses, and/or
environmental audit reports.
If the waste data is not available from the above sources, it may be necessary to monitor
the process and record the needed information. Model Worksheet 4 can be used to
record material balance data. The completed material balance should be a database of
process information that represents the process area over a time period long enough to
characterize that operation. The suggested time period to record this data is an annual
basis to coincide with other site reporting requirements. If data was taken over a shorter
time period, extrapolation can be used. The material balance will show the source of
waste streams and the contribution that different activities make to the waste streams. It
will serve as a baseline for tracking WMin/PP efforts and will provide data needed for
evaluation of WMin/PP options. The process data used to calculate a baseline of
operations should be as representative of current operations as possible.
Monitoring waste stream flows and compositions is something that should be done
periodically. By tracking waste streams, seasonal variations in waste flows or single,
large waste streams can be distinguished from continual, constant flows. Changes in
waste generation cannot be meaningfully measured unless the information is collected
both before and after a pollution prevention option is implemented.
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F. WASTE STREAM CHARACTERIZATION
Each waste stream identified in the process flow diagram will be characterized,
including but not limited to the following:
• source of waste;
• composition;
* rate of generation from work unit operation; and
• costs associated with treatment, storage, or disposal of wastes.
The waste stream characterization information is also part of Model Worksheet 4. The
cost information for the input materials and waste streams can be recorded on Model
Worksheet 5. After characterization, consideration should be given to each waste
stream to determine where WMin/PP is most needed.
V. DEVELOPMENT AND EVALUATION OF WASTE MINIMIZATION/
POLLUTION PREVENTION OPTIONS
A. IDENTIFICATION OF WMIN/PP OPTIONS
Once the process and causes of waste generation are understood, the PPOA enters the
creative phase. Following the collection of data and site inspections, the members of
the team will have begun to identify possible ways to minimize waste or prevent
pollution in the assessment process. Identifying potential options relies both on the
expertise and creativity of the team members. Much of the requisite knowledge may
come from their education and on-the-job experience, however, the use of technical
literature, contacts, and other sources may also be employed.
The process by which pollution prevention options are identified should occur in
an environment that encourages creativity and independent thinking by the
members of the assessment team. The key to successful results is the deferral of
any critical judgments or comments which might inhibit any of the team members.
While the individual team members will suggest many potential options on their
own, the process can be enhanced by using some of the common group decision
techniques. These techniques allow the assessment team to identify options that
the individual members might not have come up with on their own. Employees
having practical experience with the process may have given thought to the
process1 input and output efficiencies or alternative operating methods. Therefore,
creativity and brainstorming is strongly encouraged.
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To identify WMin/PP options, the PPOA teams will utilize the following priorities:
« source-reduction options:
- material substitution,
- process changes,
- product reformulating,
- equipment changes,
- operational improvements,
- schedule changes,
- affirmative procurement, and/or
- administrative controls (e.g., inventory control, employee
training, polices, etc.).
• recycling/reuse options
Each of these different approaches may generate many options or none, i.e., while
operational improvements are a very broad approach, input or process changes may be
difficult to control. Are there any processes / prodiicts upstream and downstream which
could be affected by changes to the process or product? As these different approaches
are discussed several questions should be repeatedly asked:
Is this operation necessary?
Why is this waste generated?
Why do we do this operation in this manner?
Why must we use these chemical??
Are there any non-hazardous substitutions available?
In addition to using the process expert's knowledge, there are numerous outside
references to assist in developing a list of options. These include EPA publications,
databases, and technical references; state and local environmental agency's
publications, bibliographies, and technical assistance; as well as, published literature in
technical magazines, trade journals, research briefs, vendor equipment information and
chemical supplier information.
Model Worksheet 6 can be used in a team brainstorming session to generate the
pollution prevention opportunities. Model Worksheets 7 and 4S can be used to record
the detailed description for each of the options generated. The description should
include the basic idea behind the option, affected materials and product, any roadblocks
to implementation, and the anticipated reduction quantity.
B. PRELIMINARY SCREENING OF WMIN/PP OPTIONS
Many pollution prevention options will be identified in a successful assessment. At this
point, it is necessary to identify those options that offer real potential to minimize waste
and reduce costs. Since detailed evaluation of technical and economic feasibility is
usually costly, the proposed options should be screened to identify those that deserve
further evaluation. The screening procedure serves to eliminate suggested options that
appear marginal, impractical, or inferior without a detailed and more costly feasibility
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study. The screening procedures may include any combination of the following
methods:
* information reviews by program managers,
* ballots by team members, and/or
• quantitative tools (e.g. weighted sum method).
Whatever method is used, the preliminary screening procedure should consider the
following questions:
Is implementation of the option cost effective?
What is the principal benefit of the option?
What is the expected change in the type or amount of waste generated
(toxicity, reactivity, etc.)?
Does it use existing technology?
What kind of development effort is required?
Will implementation be constrained by time?
Does the option have a dependable performance record?
Will the option effect product, employee health, or safety?
What are the upstream/downstream impacts if implemented?
The results of the screening process will be a list of options that are candidates for more
detailed technical and economic evaluation. It is important to document the decisions
made in the screening process for future reference. Model Worksheet 7 can also be
used to record the results from the initial screening process.
C. EVALUATION OF WMIN/PP OPTIONS
The PPOA team should perform an in-depth evaluation on the potential economic and
technical feasibility of each option using Model PPOA Worksheets 8 and 9. The options
will then be ranked in order of preferred implementation. The highest priority normally
should be given to source-reduction projects, after which projects that recycle/reuse all
or part of a waste stream or by-product will be considered.
Model Worksheet 8 evaluates each option from a cost perspective. The three major cost
categories for weighing options are: Implementation Costs, Incremental Operating
Costs, and Incremental Intangible Costs. EPA's Pollution Prevention Benefits Manual
(Reference #12 of Appendix H) provides more detail on cost analysis and contains
examples of each of these cost categories.
The following considerations must be fully evaluated to determine the recommended
WMin/PP options. These include: economic evaluation including capital cost, operating
cost, waste management costs and return on investment; expected change in the type or
amount of waste generated (toxicity, reactivity, etc.); technical feasibility; avoided costs;
effect on product, employee health and safety; permits, variances, and compliance
schedule of applicable agencies; releases and discharges to all media; previous
successes; implementation period; and/or ease of implementation.
-------
This evaluation is most easily accomplished and documented by the use of a simple
matrix for scoring and ranking - the suggested evaluation is the weighted sums method
shown on Model Worksheet 9. The DOE/DP Prioritization of Pollution Prevention
Options Using Value Engineering (Reference #13 in Appendix H) also demonstrates
how options can be evaluated and prioritized using this method. The evaluation matrix
provides a means to quantify the important criteria that affect the site and is a quick
visual representation of the factors affecting various WMin/PP options. The scoring
system for each criteria, used in the matrix and some rational for selection or weighting
of scores should be included in the formal report. Evaluation of this matrix would
complete the final requirement for prioritizing the list of options for implementation. The
formal report should provide sufficient detail to allow transfer of the measure to other
generators with similar processes or operations.
VI. FINAL REPORT
A final report is required for each PPOA. The final report is a compilation of essential
facts about the process, pollution prevention options, feasibility of those options,
upstream/downstream impacts of those options, and future implementation costs. The
final report documents the work performed, assumptions made during the assessment,
and identifies funding requirements necessary to implement pollution prevention
options. The length of the final report will depend on the complexity of the PPOA. For
Level II assessments, Model Worksheet 5S can be used to complete the requirements of
the final report.
For a Formal Assessment, Level III, each option will be ranked by the PPOA team
according to its economic and technical feasibility using Model Worksheets 8 & 9.
Economic feasibility will be a factor, but not the determining factor, in judging the relative
merit of each WMin/PP option. The PPOA team will report the results of its evaluation,
including final rankings and ranking criteria, to the Waste Minimization Committee or
line management. The PPOA team will indicate its preferred options in the report.
Easily implemented options will be completed and documented in the final report.
Options that require additional analysis and/or approval shall be addressed via the
site's Waste Minimization and Pollution Prevention Program Plan.
Documentation of the WMin/PP options and recommendations should demonstrate a
good faith effort undertaken to identify alternatives and should provide a narrative
description of these factors in sufficient detail to allow transfer of the measure to other
generators with similar processes or operations.
The final report and associated data will be maintained as permanent records for later
reference and tracking information. PPOAs should be reviewed on an annual basis
after the initial PPOA is completed and should be revised if significant process changes
are made.
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VII. APPENDIX
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APPENDIX A
GENERAL CONSIDERATIONS FOR PRIORITIZING
THE ASSESSMENT OF WASTE STREAMS
» Costs savings (direct and indirect)
« Potential for (or ease of) minimization
• Potential recovery of valuable by-products
• Reduced quantity of waste
» Compliance with current and future regulations
« Hazardous properties of the waste (including toxicity, fiammability,
corrosivity, and reactivity)
• Other safety hazards to employees
• Potential environmental and safety liability/improvements
• Potential for removing bottlenecks in production or waste treatment
-------
APPENDIX B
SOURCES OF MATERIAL BALANCE INFORMATION
Listed below are potential sources of information for preparing a process description,
flow diagram or material balance inventory. The list is not meant to be exclusive.
• Process Expert Knowledge
• Operating Logs
* On-site Tracking Systems
• Purchasing Records
• Vendor Information
• Process Design Information
• Batch Makeup Records
• Emission Inventories
• Equipment Cleaning and Validation Procedures
• Material & Chemical Inventories
* Operating Procedures and Manuals
• Production Records
• Product Specifications
* Samples, Analyses, and Flow Measurements
• Waste Disposal Records
• Waste Manifests
• E S & H reports
• Permitting Applications
• Experiments
• Laboratory Notebooks
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APPENDIX C
LEVEL I EXAMPLE PPOA
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PROCESS DEFINITION
SNL/NM Oroanization: 7813-5
Page _J of 2
Process Name: Asbestos Brakes & Clutch Removal
DATA FORM
DESCRIPTION OF
PROCESS/OPERATIONS
Area I,II,III,IV,V & Remote Area
Process Location SNL-Albuguerque NM/SNL-Livermore CA./TTR-Las Vaeas NV./KTF-Kauat
(include site, TA, building, room, as appropriate)
Describe the general operations or activities of the organization performing the process. Continue on
the back of this sheet, if necessary.
The Crane and Hoist section is responsible for performing annual
Repairs, and Preventative Maintenance on Cranes and Hoists.
Describe the particular process that generates wastes and/or other pollutants, or uses hazardous
materials. Describe how the hazardous materials are used, and how the wastes or pollutants are
generated. (See Chapter 2 of the PWA Guidance Manual for guidelines on defining a process.)
Continue on the back of this sheet, if necessary.
Asbestos Brakes and Clutches are generated waste In this process.
Asbestos Brakes and Clutches becomes a generated waste when the Asbestos
and Clutches areremoved and replaced with Non-Asbestos Brakes and Clutches,
Date: 7/22/93
PWA#:
Prepared by (MinNet Rep): Bernard. Alexander Phone: 4-1365
Process Contact: Bernard Alexander Phone: 4-1361
(to be completed fay WMSC)
-------
PROCESS D
SNUNM Organization: 7B13-5
Pane _| ol
Process Name: Asbestos Brakes & Clutch Removal
DATA FORM
PROCESS
FLOW DIAGRAM
Re»ote Areas
Process location: SHL-Atsuqaerque
,
CA*
StaHO. . flow |Seal rfoves shall be s"!f'fifi*itftl*f:!F3(.^,
If •vlGeneciile KAF8 Form 483 Asbestos Containing Materials WasJel
-------
PROCESS DEFINITION
SNL/NM Organization: 7813-5
Sheet 1 of 2 Page __ lm: of 2
Process Name: Asbestos Brakes and Clutches Removal
DATA FORM
CALENDAR YEAR 1992 WASTE
MINIMIZATION ACTIVITIES
Area I,II,III,IV,V, & Remote Areas
Process Location: SNL-Albuqgerque NM/SNL-Livermore CA./TTR-Las Vegas HV. /KTF-Kauai
(include site, TA, building, room, as appropriate)
Have waste minimization (WM) activities been undertaken in CY92? E Yes O No
If No, briefly discuss factors that have prevented waste minimization activities:
If Yes, short name of WM activity (e.g., Increase Input Purity, Improve Rinse Process) (use other sheets
if more than one activity taken): Removing and disposing of a hazardous material.
Type of WM activity (check best one that applies):
Source Reduction
09 Good Operating Practice
D Inventory Control
O Spill and Leaks Prevention
D Raw Material Modification
D Production Modification
O Process Modification (Clean and Degreasing)
D Process Modification (Surface Prep and Finish)
D Process Modification (Other)
D Other (specify below)
Recycling
O Began Onsite Recycling
O Began Off site Recycling
O Reuse in Original Process
O Reuse in Another Process
Energy Recovery
O Began Onsite Energy Recovery
O Began Off site Energy Recovery
Treatment
O Began Onsite Treatment
D Began Offsite Treatment
Briefly describe WM activity: Removal of Asbestos Brakes and Clutches to be replace with
a non-asbestos material. __^_^___ __^_
Prepared by (MinNet Rep): Bernard Alexander Phone: 4-1365
Process Contact: Bernard Alexander Phone: A-1365
7/22/93
PWA#:
(to b« comploted by WMSC)
-------
PROCESS DEFINITION
SNL/NM. Organization: 7813-5
Sheet 2 of 2 Page 2 of 2
Process Name: Asbestos Brakes and Clutches Removal
DATA FORM
FISCAL YEAR 1992 WASTE
MINIMIZATION ACTIVITIES
Waste stream type affected: D Hazardous (Chemical! Solid Waste
D Radioactive/Mixed Solid Waste
O Waste Water Discharge
O Air Emission
Waste stream name affected (see corresponding Data Form 2): Asbestos Brakes and Clutches
Did WM activity increase the toxicity of waste generated? D Yes E No
Did WM activity increase the quantity or toxicity of wastes emitted to other media (air, waste, land)?
D Yes 0 No
Did WM activity reduce toxicity but not quantity? E Yes D No
Indicate the quantity impact of the WM activity (use most appropriate measure):
Mass before WM activity (kg/yrj:
Volume before WM activity (4/yr):
Specific activity before WM activity (Ci/kg/yr):
Mass after WM activity (kg/yrj:
Volume after WM activity (l/yr|:
Specific activity after WM activity (Ci/kg/yr}:
Basis of quantities (e.g., direct measurement, material balance calculation, published emission factors,
engineering calculations, engineering/scientific judgment):
Has the WM activity been successful? d Yes D No
Is the activity still being used? Q Yes O No
If unsuccessful or otherwise not being used, describe why:
Date: 7/22/93
PWA #:
Prepared by (MinNet Rep): Bernard Alexander Phone: 4-1365
Process Contact: Bernard Alexander Phone: 4-1365
(to b« completed by WMSCI
-------
PROCESS CHARACTERIZATION Page i . of 1
SNUNM Organization: 7813-5 Process Name: Asbestos Brakes and Clutches
DATA FCnM
HAZARDOUS/RADIOACTIVE
MATERIAL INPUTS
Nam* of Hazardous/Radioactive Material
Asbestos
Glove Bag
Tvvek Suits .Rags, Drip Cloth
input Stream
Number
1
2
9
Predicted
Frequency of
Usage"1
Average
Annual Usage
Rate
-------
PROCESS CHARACTERIZATION Sheet 1 of 3 Page 1 of
SNUNM Organization: 7813-5 Process Name: Asbestos Brakes and Clutches
DATA FORM
HAZARDOUS (CHEMICAL)
SOLID WASTE
Waste Stream Number (from Worksheet 1): 1,2,9.10
Waste Stream Name (from Data Form 2/Worksheet 1): Asbestos,tyvk suits,rags .drip cloth, plastic
Location of waste generation (TA, building, room): SNL-Alb/SNL-CA/TTR-NV/KTF-Kauai bag
Inside RMMA? D Yes ® No
Briefly describe how waste is generated: Asbestos Brakes and Clutches are removed and replaced
with non-asbestos material. Glove bages.tyvek suits rags, and drip cloth are used in th
removal process to remove the generated waste.
Frequency of waste generation:
O Continuously
d Monthly
D Daily
O Quarterly
D Weekly
O Annually
Which description fits the process step that generates the waste (check best one):
IE A regularly scheduled process step that is likely to be repeated several times during the upcoming year.
O A one-time activity that is not likely to be repeated during the upcoming year.
Predicted average quantity of waste generated annually - normal operations (kg): 200 Ibs.
Predicted min/max quantity generated annually - normal operations (kg): Min Max
List (describe) all hazardous constituents (e.g., mercury inside switches, benzene-tainted glassware)
or brand names (e.g., WD-40) that could be in the waste:
Asbestos , ___^__
Do the hazardous constituents of the waste stream listed above vary (e.g., sometimes contains lead,
sometimes contains lead and cadmium)? D Yes H No if yes, describe how the waste varies:
Describe physical characteristics of wastes (e.g., aqueous solution, solid, sludge, oil, containerized
compressed gas - include % of solids or % moisture, If applicable): Solid
Date: 7/22/92
PWA#:
{to b* completed by WMSCI
Prepared by (MinNet Rep): Bernard Alexander
Process Contact: Bernard Alexander
Phone:,
Phone:
4-1365
4-1365
-------
PROCESS CHARACTERIZATION Sheet 2 of 3 Page 2 of _
SNUNM Organization: 7813-5 Process Name: Asbestos Brakes and Clutches
DATA FORM
HAZARDOUS (CHEMICAL)
SOLID WASTE
The pH of the waste stream may range from N/A to N/A (answer if appropriate)
Is the waste ignitable? (see Guidance Manual for clarification!
Is the waste corrosive? (see Guidance Manual for clarification}
Is the waste reactive? (see Guidance Manual for clarification)
D Yes
D Yes
D Yes
m NO
BNo
BNo
O Unknown
O Unknown
O Unknown
Does the waste stream contain any of the following toxic metals: Q Yes H No (check all that apply)
D Arsenic D Barium O Cadmium O Chromium
O Lead O Mercury D Selenium D Silver
Does the waste stream, contain a toxic volatile, semi-volatile, or pesticide listed in Table 3-2?
D Yes S No If yes, list:
Does the waste stream contain any of the spent solvents listed in Table 3-3? O Yes B No
If yes, list:
Does the waste stream contain, or is it generated from the production of, any of the following benzene
derivatives? O Yes 0 No (check all that apply)
D trichlorophenol D tetrachlorobenzene
O tetrachlorophenol Q pentachlorobenzene
O pentachloropheno! D hexachlorobenzene
Is the waste any of the following? O Yes
O waste water treatment sludge
O petroleum refining waste
E No (check all that apply)
O wood preserving process waste
O leachate from treatment, storage, or disposal of waste
Does the waste contain cyanide or is cyanide used in the process? O Yes B No
Is the waste any of the following? O Yes E No (check all that apply)
O waste from the production of inorganic pigments
O waste from the production of inorganic chemicals
O waste from the production of organic chemicals
D waste from the production of explosives
D waste from the production of ink formulations
D waste from the production of pesticides
D waste from the production of metals
O waste from the production of Pharmaceuticals
D coking waste
O petroleum refining waste
Date: 7/22/93
PWA #:
(to be completed by WMSC)
Prepared by (MinNet Rep):Bernard Alexander
Process Contact: Bernard Alexander
Phone: 4-1365
Phone:4-1365
-------
PROCESS CHARACTERIZATION Sheet 3 of 3 Page 3 of
SNL/NM Organization: 7813—5 Process Name: Asbestos Brakesand Clutches
DATA FORM
HAZARDOUS (CHEMICAL)
SOLID WASTE
Based on the above description of how the waste is generated, select the single best summary of the
waste-generating process step.
CLEANING AND DECREASING
D Stripping (A01)
D Acid cleaning ((A02)
O Caustic (Alkali) cleaning (A03)
D Flush rinsing (A04)
n Dip rinsing (A05)
D Spray rinsing (A06)
O Vapor degreesing (A07)
D Physical scraping and removal (A03I
O Clean out process equipment (AOSJ
O Other cleaning and degreasing (A19)
SURFACE PREPARATION AND FINISHING
D Painting (A21J
D Electroplating (A22)
D Electroless plating (A23)
O Phosphating (A24)
O Heat treating (A25)
D PieWing (A26I
D Etching (A271
D Other surface coating/preparation (A29)
PROCESSES OTHER THAN SURFACE PREPARATION
D Product rinsing (A31)
D Product filtering {A32»
O Product distillation (A33)
D Product solvent extraction (A34J
D By-product processing (ASS)
O Spent catalyst removal (A36)
O Spent process liquids removal (A38)
O Tank sludge removal (A38)
O Slag removal (A39)
O Metal forming (A40)
O Plastics forming (A41)
PRODUCTION OR SERVICE DERIVED ONE-TIME AND
INTERMITTENT PROCESSES
O Leak collection (ASK
O Cleanup of spill residues (A53)
D Oil changes (A54)
D Filter/battery replacement (ASS)
O Discontinue u*« of process equipment (ASS)
B Discarding off-spac material (A571
O Discarding out-of-date products or chemicals (ASS)
D Other production-derived on-time and intermittent
processes (ASS)
D Sludge removal (A60)
REMEDIATION DERIVED WASTE
D Superfund Remedial Action (A61)
D Superfund Emergency Response (A62)
O RCRA Corrective Action at solid waste management
unit (A63)
D RCRA closure of hazardous waste management unit
(A64|
O Underground storage tank cleanup (A65)
O Other remediation (A69)
POLLUTION CONTROL OR WASTE TREATMENT
PROCESSES
O Filtering/screening (A71)
O Metals recovery (A72)
O Solvents recovery (A73)
D Incineration/thermal treatment (A74)
O Westeweter treatment (A75)
O Sludge dewetering (A76)
O Stabilization (A77)
O Air pollution control devices (A78)
O Leachate collection (A79)
O Other pollution control or waste treatment (ASS)
OTHER PROCESSES
S Clothing end personal protective equipment (A91)
S Routine cleanup wastes (e.g., floor sweepings)
-------
APPENDIX D
PPOA GRADED APPROACH WEIGHTED SUMS
FORM, CRITERIA, AND INSTRUCTIONS
-------
Date:
Page
of
Pollution Prevention Opportunity Assessment Graded Approach
Weighted Sums Evaluation
Evaluation Criteria
Weight
'W'
Process:
Scale
'S' 'WxS1
Process:
Scale
'S1 'WxS1
Process:
Scale
'S1 'WxS1
Process:
Scale
'S1 'WxS1
Process:
Scale
'S1 'WxS1
Environmental, Safety,
& Health Hazards
Site
Assigns
Quantity of Waste
Generated
Site Liabilities
Economic Factors -
Process & Waste Costs
(Unit &/or Annual)
Process By-Product
Management
Other
Subtotal
WMin/PP Potential
Multiplier
Total
PPOA Level
8/93
-------
Date;
Page
of
Pollution Prevention Opportunity Assessment Graded Approach
Weighted Sums Evaluation
Evaluation Criteria
Weight
•W
Process:
Scale
'S1 'WxS'
Process:
Scale
'S' 'WxS1
Process:
Scale
'S1 'WxS1
Process:
Scale
'S' 'WxS'
Process:
Scale
'S' 'WxS'
Environmental, Safety,
& Health Hazards
Site
Assigns
Quantity of Waste
Generated
Site Liabilities
Economic Factors -
Process & Waste Costs
{Unit &/or Annual)
Process By-Product
Management
Other
Subtotal
i
Min/PP Potential
[Multiplier
Total
PPOA Level
8/93
-------
Graded Approach Worksheet
The purpose of this worksheet is to determine the PPOA level for each of the facility processes. To begin, a list of these
processes or areas should be generated for each facility. Then for each item listed, complete one column on this worksheet.
For consistency, each facility should establish site-specific weights for each of the criteria. Once each item has received a
weighted sum value, then each facility should establish the dividing line from which to require informal (Level II) or formal PPOAs
(Level III).
Weighted Sums Instructions:
a. The values in the Weight column (designated by W)
represent the facility's priority for the criteria.
b. In the Scale column for each process (designated by 'S'),
rate each criteria by assigning a value from 0-10
(lowest to highest).
c. In the 'Wx S' column for each process, enter the product of
the weight and scale.
d. Sum the 'W x S1 column for each process to obtain a
subtotal.
e. Calculate the process ratio for waste generated/input
material used (0-1). This is the multiplier.
f. Multiply the subtotal by the multiplier and enter the product
in the Total column for each process.
g. Determine the level of PPOA required by comparing the
Total weighted sums value with the site guidelines in
the following table.
Weighted Sums
Total
If 0 to (?)
If > (?)
PPOA Level
Required
Level II
Informal PPOA
Level III
Formal PPOA
-------
APPENDIX E
LEVEL II EXAMPLE PPOA
-------
[ PPOA-1 1 Original Issue Date: 8/31/91
V / Revision Mn •
Revision No.:
Revision Date:
Pollution Prevention Opportunity Assessment
Team & Scope
Assessment ID Code: Assessment Title:
SNL/CA MS001 Machine and Fabrication Shop
Name Job Classification Phone
Alice Johnson- Duarte
Andy Cardiel
Charlie Schmitz
Kim Shepodd
WMin Coordinator
Shop Supervisor
Machinist
Waste Manager
4-3266
4-2544
4-2315
4-1475
* Team Leader
Assessment Scope:
The Machining and Fabrication Shop is a support function whose principal
purpose is machining parts requiring a quick turn-around, restriction of
access due to classification, and/or close liaison with the designer and
engineer. The shop maintains equipment suitable to perform turning,
milling and grinding operations. The major hazardous waste stream
generated by this facility is the spent coolant used in the machining
process. The diluted Aqua-Syn 180 itself is a non-hazardous material per
29CFR 1910.1200(c); however, in the machining process it is mixed with
small amounts of machine oil and metal shavings. The coolant is routinely
changed after 3 to 4 months of service except as noted in the shop's
operating procedures.
Potential for Pollution Prevention / Waste Minimization or Recommendations:
There are limited operational and administrative pollution prevention
opportunities to reduce the spent coolant waste.
-------
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
PROCESS FLOW DIAGRAM
PWA ASSESSMENT ID CODE: SNL/CA MS001
TITLE: Machine and Fabrication Shop
Unspecified Aqueous Solution
CY91 Generated 11,000 pounds
COOLANT
SOLUTION
Water, 20 Parts
Aqua-Syn 180,
1 Part
Replaced
"only as "
required
Small Metalic Chips
Thin Film Machine Oil
A total of
35 machines
including:
19 lathes,
9 mills,
5 grinders,
and 2 handsaws
use coolant.
Waste
Solution
55 GAL
Sent to Off-site
Disposal
-------
PPOA-2
Pago; 1 of
Pollution Prevention Opportunity Assessment
Material & Waste Stream Summary
Assessment ID Code: SNUG A MS001
Title: Machine and Fabrication Shop
Input
Material
Name/No.
Water
Aqua-Syn
Metafic chips
Machine oil
Annual
Quantity
Used
10400.0
520.0
65.0
15.0
%
Product
%
Recycled
Total Releases
%
Air
5
1
%
Liquid
95
99
100
%
Solid
100
Totals/Page: 11000.0
Total Annual Quantity 11000.0
Does the process require further analysis
based on the site's Priority Material/Waste
Stream List?
ONo
[Level II DLevel II
9/16/93
-------
Page _1_of J
Pollution Prevention Opportunity Assessment
Option Summary
Assessment ID Code: Title:
SNL/CA MS001 Machine and Fabrication Shop
Option Description
One consideration for an operational improvement would be to recycle the spent coolant. According to industrial
sources, a reduction of approximately 50% in the present amount of coolant disposed of.
Type
Recycling
Consider?
• Yes ONo
Feasibility
Fair
Estimated
Cost
$25,000.00
Estimated
Savings
$100.00
Anticipated
Reduction Qty
5,000.00
Qpilan Description
&°-* Analyze the spent coolant solution for contaiminants and determine if it is indeed hazardous.
2
Type
Disposal
Consider?
OYes 9No
Feasibility
Poor
Estimated
Cost
$5,000.00
Estimated
Savings
$100.00
Anticipated
Reduction Qty
1,0000
-------
Date
8/31/91
Pollution Prevention Opportunity Assessment
Final Summary
Assessment ID CodeSNUCA MS001
Title: Machine and Fabrication Shop
Assessment:
A Level I and Level II PWA were completed on the Machining and Fabrication Shop
coolant waste stream. The machinist responsible for the operational maintenance of
the machine shop equipment had limited suggestions for reducing the amount of
spent coolant generated. Recycling and treatment options were generated and
evaluated. Assumptions made during this assessment were: the level of activity of the
machine shop is relatively stable; the coolant must be changed on a periodic basis
which is dependent on use and/or time and; disposal costs are relatively stable.
Conclusions:
The PWA team concluded the options are not economically feasible at this time since:
1) option one would require a considerable investment with the possibility of
increasing the actual amount of coolant waste caused by contamination; 2) the
recycling equipment presently available is not designed to treat the small quantity of
spent coolant generated; 3) a conservative approach regarding waste management is
consistent with the site's policy.
Recommendations:
The Line Management will continue monitoring the amount of waste generated and
the availability of recycling equipment for improvement in the economical feasibility of
implementation.
-------
APPENDIX F
LEVEL III EXAMPLE PPOA
-------
Worksheet 1
Level ill
Original Issue Date;
Revision No.:
Revision Date:
OI-Dae-1993
Pollution Prevention Opportunity Assessment
PPOA Team
PPOA Title: Polyurethane Foam Mixing and Curing
PPOA ID Code(s): G517-034-Machine_Mix
Name
"Team Leader
Additional Resources
Job Classification
Phone
*Bill Harrison
John Taylor
Albert Green
Mary White
Violet Jones
Process Engineer
Area Supervisor
Foam Machine Operator
Foam Machine Operator
Area Production Planner
X1234
X1235
X1235
X1235
X1236
Name
Phone
PPOA Coordinator
Waste Management
Industrial Hygiene
Environmental Protection
Safety
Fire Protection
Process Engineering
Materials Engineering
Utilities Engineering
Facilities Engineering
Maintenance (Equipment)
Analytical Lab Testing
Scheduling
Purchasing
Nancy Notrebmep
Hakim Senoj
Tim Sregge
Dottie Muldune
X5432
X5433
X5434
X5431
11/93
-------
Worksheet 2
Level 111
Revision No.:
Revision Date:
Pollution Prevention Opportunity Assessment
Process Description
PPOA Title: Polyurethane Foam Mixing and Curing
PPOA ID Code(s): G517-034-Machine_Mix
Process Location: Main Building #105, Post FN33
Process Description:
The foam mixing process is a process in which the required material
components are metered and mixed at a defined ratio. The ratio of the two
component streams is set and calibrated by production personnel. The
materials are then mixed during the dispense cycle by the action of a motorized
impeller. The mixed material "foam" is transferred manually to a mold and cured
at temperatures from 165 to 350 deg. F. for four to six hours. Input materials
include polyol resins, isocyanates, cleaning solvent and processing supplies.
Five foam dispensing units are used. They range in age from four to fifteen
years. The cure ovens are ventilated as is the foam pouring area. The foam
machine operators have sufficient training to operate the dispensing units.
Their previous training did not emphasize pollution prevention.
Waste streams include solid and liquid waste from the foaming operations as
well as air emissions from the foam pouring and curing activities.
Description of Major Product(s) of Process:
Molded Polyurethane Foam Products
11/93
-------
Level 111
Revision No.: 0
Revision Data:
Pollution Prevention Opportunity Assessment
Process Flow Diagram
PPOA Title or PPOA ID Code(s):
G517-034-Machine Mix
Inputs:
Isocyanate Comp.
Resin Component
Solvent
Supplies
Process:
Foam Mixing
and Curing
Outputs:
Product
Hazardous
Non-Hazardous
Other
(PR2)
(PR3)
Solid
Foam
Product
Liquid
Air
Solid
Purge
Waste
Calibration
Waste
Air
Isocyanate
Emissions
(NH2)
(NHS)
Solid
Scrap
Product
Liquid
Air
(Sri)
(cm)
(OT3)
Solid
Liquid
Air
11/93
-------
Level
Time frame
Pollution Prevention Opportunity Assessment
Material Balance Summary
PPOA Title or PPOA ID Code(s): G517-034-Machlne_Mlx
Revision No.:
Revision Date;
Page 1 of
muni, ui— uan — 9£
To: 31-Dec-92
Material
Description
Isocyanate
Resin
Solvent
Supplies
Foam
Totals/Subtotals
Total
Input
313.6
186.4
80.0
94.0
0.0
674.0
Total
Output
124.5
73.5
80.0
94.0
302.0
674.0
Stream
ID Code
Foam
Product
(S)
237.0
237.0
Stream
ID Code
Purge
Waste
@)
98.3
58.9
80.0
94.0
331.2
Stream
ID Code
Calibration
Waste
(HZ2)
24.4
14.6
39.0
Stream
ID Code
Isocyanate
Emissions
(HZS)
1.8
1.8
Stream
ID Code
Scrap
Product
(NHI)
65.0
65.0
Stream
ID Code
o
Stream
ID Code
O
Stream
ID Code
O
Stream
ID Code
O
11/93
-------
Worksheet 5
Level 111 Revision No.: _
Revision Date:
Page 1 of
Pollution Prevention Opportunity Assessment
Material Cost
PPOA Title or PPOA ID Code(s); G517-034-Machine_Mix
Material
Isocyanate Component
Resin Component
Solvent
Supplies (paper cups, etc.)
Stock Number
(if applicable)
Cost Per
Unit
$1.96/lb
$2.25/1 b
$0.27/1 b
$O.S7/lb
Total /
Subtotal
Annual Cost
$614.65
$419.40
$ 21.60
$ 53.60
$1109.25
Waste Disposal Cost:
Material / Waste Stream
Waste Liquid
Waste Solid
Scrap Product
Waste Stream
Category
Haz. Liquid
Haz, Solid
Non Haz. Solid
Cost Per
Unit
$4.60/lb
$2.97/lb
$0.69/lb
Total/
Subtotal
Annual Cost
$179.40
$983.66
$ 44.85
$1207.91
11/93
-------
Worksheet 6
Level III
Pollution Prevention Opportunity Assessment
Option Generation
PPOA Title or PPOA ID Code(s): GS17-034-Machme-Mix
Revision No.:
Revision Date:
Practices &
Procedures
Material
Substitution
New Product
&/or Process
Reduce calibration
Amount & duration.
Reduce solvent
purge time
Increase operator
^awareness & training
Redefine foam
kit requirements
In-line calibration
system
Use submerged
pumps
Equipment
Modification
Pollution
Prevention
Options
11/93
-------
Worksheet 7
Level III Revision No.: 0_
Revision Date:
Page 1 of 2
Pollution Prevention Opportunity Assessment
Option Description
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Option Name and Description
(Include input materials, products affected, and anticipated reduction quantity.)
Option No. 1 : Calibration Reduction. Reduce the amount and duration of the
calibration shots for the foam dispensers. Use new analytical methods "nitrogen
testing" to justify the reduced level.
Consider; Yes X No_
Practices & Procedures X Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation
Option No. 2 : Increase Awareness and Training. Conduct training session to
increase pollution prevention awareness. Instruct in the importance of the individual
in the waste generation process.
Consider: Yes X No_
Practices & Procedures X Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation
Option No. 3 : Use Submerged Pumps. Replace gear pumps on foam
machines with in-tank pumps. Leakage will be into material tanks. This will eliminate
material waste and exposure as the result of clean-up
Consider: Yes X No
Practices & Procedures Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process X Recycling, Reuse, & Reclamation
Option No. 4 : In-Line Calibration System. Purchase new foam equipment
with "in-line" calibration capability. This would replace the open cup method and
would reduce the liquid and solid waste streams
Consider: Yes X No
Practices & Procedures Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification X
New Product &/or Process Recycling, Reuse, & Reclamation
-------
Worksheet 7
Level III Revision No.:
Revision Date:
Page 2 of 2
Pollution Prevention Opportunity Assessment
Option Description
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Option Name and Description
(Include Input materials, products affected, and anticipated reduction quantity,)
Option No. 5 : Substitute for TDI. Lessen the toxicity of the waste stream by
replacing TDI isocyanate with a PMDI based foam system. PMDI is not a carcinogen
and is not a RCRC Hazardous waste.
Consider: Yes X No_
Practices & Procedures Waste Segregation/Hazard Reduction
Material Substitution X Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation
Option No. 6 : Reuse Calibration Material. Retain spent calibration material
for use on low end product requirements. This could include machine tryout parts,
or foam billets used as base material for holding fixtures.
Consider; Yes X No_
Practices & Procedures Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation X
Option No. 7 : Reduce Solvent Purge Time. Reset the solvent timers on the
foam machine to the absolute minimum to flush the mix head. Subsequent soaking
of mixer blade and housing can also reduce the required amount.
Consider; Yes X No_
Practices & Procedures X Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation
Option No. 8 : Redefine Foam Kit Requirements. Set-up separate material
numbers for resin and isocyanate components so ratio/usage of material will be
balanced. Current "matched set" distribution result in waste of excess component.
Consider: Yes X No_
Practices & Procedures X Waste Segregation/Hazard Reduction
Material Substitution Equipment Modification
New Product &/or Process Recycling, Reuse, & Reclamation
-------
Worksheet 8
Level
Revision No.: 0
Revision Date: _
Page 1 of 2_
Pollution Prevention Opportunity Assessment
Options Cost Evaluation
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Option No.:
1
Option No.:
2
Option No.:
3
Option No.:
4
Option No.:
5
Implementation Costs
Purchased Equipment
Installation
Materials
Utility Connections
Engineering
Development
Start up / Training
Administrative
Other
Total Implementation
Cost
$250
$100
$50
$400
$100
$100
$50
$250
$500
$100
$150
$150
$900
$75,000
$10,000
$2000
$3000
$5000
$95,000
$1000
$500
$1500
Incremental Operating Costs
Change in Raw
Materials
Change in Maintenance
Change in Labor
Change in Disposal
Other
Annual Operating
Savings/(Cost)
$215
$500
$50
$765
$100
$50
$150
Incremental Intang
Penalties and Fines
Future Liabilities
Other
Annual Intangible
Savings/(Cost)
Total Annual
Savings/(Cost)
Payback Period
$0
$765
0.5 yrs
$0
$150
1 .6 yrs
$150
($150)
$100
$100
$750
$500
$600
$1850
$500
$500
$1000
ible Costs
$0
$100
9.0 yrs
$0
$1850
51 yrs
$0
$1000
1.5 yrs
11/93
-------
Worksheet 8
Level III
Revision No.: 0
Revision Date:
Page 2 of 2_
Pollution Prevention Opportunity Assessment
Options Cost Evaluation
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Option No.:
6
Option No.:
7
Option No.:
8
Option No.:
Option No.:
Purchased Equipment
Installation
Materials
Utility Connections
Engineering
Development
Start up / Training
Administrative
Other
Total Implementation
Cost
$200
$200
$150
$150
$300
$150
$150
$300
Incremental Operating Costs
Change in Raw
Materials
Change in Maintenance
Change in Labor
Change in Disposal
Other
Annual Operating
Savings/(Cost)
$180
$180
$15
$125
$140
Penalties and Fines
Future Liabilities
Other
Annual Intangible
Savings/(Cost)
Total Annual
Savings/(Cost)
Payback Period
$0
$180
1.1 yrs
$0
$140
2.1 yrs
$350
$350
mm>mfmmmmm:mmmmm] ; • •.
$0
$350
0.9 yrs
11/93
-------
Worksheet 9
Level ill
Revision No.:
Revision Date:
Page 1 of
Pollution Prevention Opportunity Assessment
Weighted Sums Option Evaluation
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Criteria
Public Health, Safety, &
Environment
Employee Health & Safety
Regulatory Compliance
Economic
Implementation Period
Improved Operation /
Product
Other
Subtotal
Likelihood of Technical
Success (Multiplier)
Likelihood of Useful
Results (Multiplier)
Total
Rank
Weight
W
10
10
8
6
4
2
iiiiiiiiiitill
liiiiiiiiiiilif
:-;•:•:•:--•.-:-.• :-:-;-:-:•:-;•:•;•;•:•:•:•:•:•:•:•:•:•:•:
;:;>:-[[[
:^S:?:^:^:^'^SS$!::™'. *:: :•
Option N
Scale
'S1
8
8
7
8
7
5
sssssiisspsss?
X
X
:%::?S:^S;:^^SS::^::::
;;x:x:£:;:x:;:;:;:;:;:|:;:;:;:£:j:;:;:;:
o.: 1
'WxS'
80
80
56
48
28
10
302
0.8
0.9
217
7
Option N
Scale
'S'
6
7
7
9
9
8
X
X
o.: 2
'WxS1
60
70
SB
54
36
16
292
1.0
0.9
262
4
Option N
Scale
•S'
6
5
8
7
6
7
X
X
x*:W:W:*: : ?:v£*:;;::
xl:;:*:*:*:*: : :|: £>:-#
;S:;:;:;:£:;::$- | £ <:;:$:•:
1111 1111
o.: 3
'WxS1
60
50
64
42
24
14
254
0.9
0.9
205
8
Option N
Scale
'S'
7
8
7
5
6
8
lllllllilllll
X
X
o.: 4
'WxS'
70
80
56
30
24
16
276
0.9
0.9
224
5
Option N
Scale
'S'
8
9
9
8
7
8
X
X
'^^?^^^^^^ :¥:
o.: 5
'WxS1
80
so
72
48
28
16
334
1.0
1.0
339
1
-------
IliiiiiBiiiaig^iiiiiiilllKliflaiSllaahi':
Level III
Pollution Prevention Opportunity Assessment
Weighted Sums Option Evaluation
Revision No.:
Revision Date:
Page 2 of
PPOA Title or PPOA ID Code(s): G517-034-Machine Mix
Criteria
Public Health, Safety, &
Environment
Employee Health & Safety
Regulatory Compliance
Economic
Implementation Period
Improved Operation /
Product
Other
Subtotal
Likelihood of Technical
Success (Multiplier)
Likelihood of Useful
Results (Multiplier)
Total
Rank
Weight
W
10
10
8
6
4
2
mi
111 \
• i iiiii
:-;-:-;;:-:|:v:;:::;:;;|x-;::::-:'X:L::^LjLj;j;J;J;J
y;-;J;y;v;J;;;|:;::;::::-:-x-:-:-:-:-;":|:;:':;:j;j:
Option No.: _6
Scale
'S1 'WxS'
6
7
6
7
7
7
1
1
X
X
60
70
48
42
28
14
262
0.9
0.9
212
6
Option No.: 7
Scale
'S1 'WxS'
8
8
7
9
9
6
X
X
5i5:sg;S¥gft;: SSs : f
1111111$ 1 |l M
tp;?SS:tP :w : S
80
80
56
54
36
12
318
1.0
0.9
286
2
Option No.: _8
Scale
'S' 'WxS'
6
7
7
8
8
9
X
X
60
70
56
48
32
18
284
1.0
1.0
284
3
Option No.:
Scale
'S1 'WxS'
X
X
Option No.:
Scale
'S1 'WxS'
X
X
11/93
-------
Worksheet 10
Level HI
Revision No,: 0
Revision Date:
1 of 1
Pollution Prevention Opportunity Assessment
Final Report Check Sheet
PPOA Title or PPOA ID Code(s): G517-034-Machine_Mix
Requirement Completed
Title Page X
PPOA Title
PPOA ID Code(s)
Team members
Issue date/revision date/revision no.
Executive Summary X
Process description
Process assessment
Option summary and analysis
Conclusions
Recommendations
Introduction X
Background of evaluation
Process Description X
Associated equipment
Process flow diagram
Process Assessment X
Methodology
Material Balance
Unusual occurrences
Option Summary and Analysis X
Option description and rank
Upstream/Downstream impacts
Material usage
Anticipated reduction
Estimated costs
Estimated benefits
Feasibility
Waste streams affected
Conclusion X
Concluding evaluation
Option analysis decisions
Concerns
Options already implemented
Lessons learned
Recommendations X
Future work
New equipment
Implementation strategies
Worksheets X
1-10
11/93
-------
APPENDIX G
MODEL PPOA WORKSHEETS
-------
Worksheet 1
Level
Original Issue Date:
Revision No.:
Revision Date:
Pollution Prevention Opportunity Assessment
PPOA Team
PPOA Title:
PPOA ID Code(s):
Name
Job Classification
Phone
*Team Leader
Additional Resources
Name
Phone
PPOA Coordinator
Waste Management
Industrial Hygiene
Environmental Protection
Safety
Fire Protection
Process Engineering
Materials Engineering
Utilities Engineering
Facilities Engineering
Maintenance (Equipment)
Analytical Lab Testing
Scheduling
Purchasing
11/93
-------
Worksheet 1
Worksheet 1 provides the identification of the PPOA assessment team. For the PPOA
to be successful, employees involved with the process should be members of the
team. The assessment team needs a leader, members, and additional resources,
as required.
The team leader should have technical knowledge of the process, knowledge of the
current production operations, and the personnel involved. The leader shall
assemble the team to perform the assessment. Team members may include
process engineers, product engineers, knowledgeable department personnel such
as production operator(s), and material experts. Additional resources may be called
in to provide information not available within the team. The size of the team may be
large for complicated processes, but should be kept to a minimum to maintain focus.
1. Original Issue Date: List the original issue date of the PPOA.
2. Revision No.: List the revision number for this worksheet. {Original issue = 0.}
3. Revision Date: List the most recent revision date for this worksheet.
4. PPOA Title: List the PPOA title selected by the team.
5. PPOA ID Code(s): List the PPOA ID Code(s) selected by the team.
6. Name, Job Classification, Phone: To facilitate team meetings and for future
reference, this information should be completed when the PPOA team is
formed.
-------
Level III
Revision No.:
Revision Date:
Pollution Prevention Opportunity Assessment
Process Description
PPOA Title:
PPOA ID Code(s):
Process Location:
Process Description:
Description of Major Product(s) of Process:
-------
Worksheet 2
Worksheet 2 provides a brief description of the process. The main elements of
the process description are the process location, input materials, equipment,
summary of operations performed, process controls, operator training, major
products, and the waste streams affected.
1. Revision No.; List the revision number for this worksheet,
2. Revision Date: List the most recent revision date for this worksheet.
3. PPOA Title: List the PPOA Title given on Worksheet 1.
4. PPOA ID Code(s): List the PPOA ID Code(s) given on Worksheet 1.
5. Process Location: List the best descriptor of the process location. It may
be a department, building, room, etc..
6. Process Description: The process description should detail important
attributes of the process. Equipment, summary of operations
performed, process controls, input materials, and operator training
(qualification or certification) should be included.
7. Description of Major Product(s) of Process: Describe the major products
which result from this process or the reason the process is being
perfromed.
-------
Worksheet 3
Sty to 1
Revision No.:
Revision Date:
Level III
Pollution Prevention Opportunity Assessment
Process Flow Diagram
PPOA Title or PPOA ID Code(s):
Inputs:
Outputs:
Highlight those sections that apply.
: Use Worksheet 4 to identify and
quantify the appropriate stream.
Non-Hazardous
(PRJ)
(PR2)
(PR3)
Solid
Liquid
Air
(HZI)
(HZ2)
(HZS)
Solid
Liquid
Air
(NHI)
(NH2)
(NH|)
Solid
Liquid
Air
(on)
(012)
(ora)
Solid
Liquid
Air
11/93
-------
Worksheet 3
Worksheet 3 provides a process flow diagram for the PPOA. The flow diagram should identify
all PPOA ID Code(s) associated with the process, all input materiats, and outputs
(products/wastes). The flow diagram should track materials from the time they enter the
process boundary until they leave. This diagram represents a very simplistic flow model; a
more detailed diagram may be required to identify all waste streams, especially for complex,
multi-step processes.
1. Revision No.; List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
4. Process Flow Diagram; List the input materials on the lines provided. Fill in the Process
Name box. Then highlight those outputs that are applicable to the process (e.g.
Product, Hazardous, etc.). Then sub-categorize those outputs into solid, liquid, or air
emission streams by highlighting the corresponding output stream. A Stream ID Code is
provided for each sub-category of waste.
5. Outputs: The Stream ID Code provides a uniform coding scheme for the release
information requested on Worksheet 4. A brief waste description may be recorded in the
box to the right of the Stream ID Code.
-------
Revision No.:
Revision Date:
Level III
Pollution Prevention Opportunity Assessment
Process Flow Diagram
PPOA Title or PPOA ID Code(s):
Inputs:
Solid
Liquid
Air
(on)
(^2)
(OT3)
Solid
Liquid
Air
•tt:vX-^x<<<<<<^x<*x-x-:-:-x*:^;-;-x-X"X"X"X^
m ^^mismmm^^mmmm^^ff^^^^msmmrmmmm
quantify the appropriate stream.
(pm)
(pj§)
(PRS)
Solid
Liquid
Air
Solid
Liquid
Air
(HZI)
(nz2)
(HZS)
Solid
Liquid
Air
(em)
(5^
(RDS)
Solid
Liquid
Air
11/93
-------
Worksheet 3
Worksheet 3 provides a process flow diagram for the PPOA. The flow diagram should identify
all PPOA ID Code(s) associated with the process, all input materials, and outputs
(products/wastes). The flow diagram should track materials from the time they enter the
process boundary until they leave. This diagram represents a very simplistic flow model; a
more detailed diagram may be required to identify all waste streams, especially for complex,
multi-step processes.
1. Revision No.: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
4. Process Flow Diagram: List the input materials on the lines provided. Fill in the Process
Name box. Then highlight those outputs that are applicable to the process (e.g.
Product, Hazardous, etc.). Then sub-categorize those outputs Into solid, liquid, or air
emission streams by highlighting the corresponding output stream. A Stream ID Code is
provided for each sub-category of waste.
5. Outputs: The Stream ID Code provides a uniform coding scheme for the release
information requested on Worksheet 4. A brief waste description may be recorded in the
box to the right of the Stream ID Code.
-------
: •: •: -x—x-^xvx-x>> x-x-x->x •: •
Level
Revision No.:
Revision Date:
Pollution Prevention Opportunity Assessment
Process Flow Diagram
PPOA Title or PPOA ID Code(s):
Inputs:
Solid
Liquid
Air
/Process:
Outputs:
(Jim)
(NH2)
(NH^)
Solid
Liquid
Air
Product
Hazardous- RCRA
Hazard, non RCRA
Toxic, TSCA
Non-Hazardous
Other
to worksheet 3B
(for radioactive wastes)
(pm)
(PR2)
(PR3)
Solid
Liquid
Air
Solid
Liquid
Air
(HRI)
(HR2)
(HRS)
Solid
Liquid
Air
(HNI)
(HN2)
(HN3)
Solid
Liquid
Air
11/93
-------
Worksheet 3A
Worksheet 3 provides a process flow diagram for the PPOA. The flow diagram should
represent all PPOA ID Code(s) associated with the process, all input materials, and outputs
(products/wastes). The flow diagram should track materials from the time they enter the
process boundary until they leave. This diagram represents a very simplistic flow model; a
more detailed diagram may be required to identify all waste streams, especially for complex,
multi-step processes.
1, Revision No.: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet!
4. Process Flow Diagram: List the input materials on the lines provided. Fill in the
Process Name box. Then highlight those outputs that are applicable to the process
(e.g. Product, Hazardous, etc.). Then categorize those outputs into solid, liquid, or
air emission streams by highlighting the corresponding output stream. A Stream ID
Code is provided for each category of waste.
5. Outputs: The Stream ID Code provides a uniform coding scheme for the release
information requested on Worksheet 4. A brief waste description may be recorded
in the box to the right of the Stream ID Code.
DOE Definitions:
Hazardous Waste - Waste, which because of its quantitiy, concentration, or physical,
chemical or infectious nature may (a) cause or significantly contribute to an increase
in mortality or an increase in serious irreversible, or incapacitating reversible illness,
or (b) pose a substantial present or potential hazard to human health or the
environment when improperly treated, stored, transported, disposed of, or otherwise
managed. Hazardous waste can be further defined as:
RCRA-reguIated - solid waste not specifically excluded from regulation under 40 CFR
261.4, or delisted by petition, that is either a listed hazardous waste (40 CFR 261.30 -
261.33) or exhibits the characteristics of a hazardous waste (40 CFR 261.20 -
261.24).
Non RCRA-regulated - any other hazardous waste not specifically regulated under
TSCA or RCRA, which may be regulated by the state or local authorities, such as
used oil.
TSCA Waste - Individual chemical wastes (both liquid and solid), such as polychlorinated
biphenyls (PCBs).
-------
Revision No.:
Revision Date:
Level
Pollution Prevention Opportunity Assessment
Process Flow Diagram
PPOA Title or PPOA ID Code(s):
Solid
Liquid
Air
from Worksheet 3A
Outputs:
(LMI)
(LM|)
(LMJ)
Solid
Liquid
Air
High Level
Transuranic, (TRU)
TRU, Mixed
Low Level
Low Level, Mixed
Other, Rad
Solid
Liquid
Air
(ryj)
(?U2)
(rua)
Solid
Liquid
Air
(TMI)
(TM2)
(TMS)
Solid
Liquid
Air
(LLJ)
(J£2)
(E)
Solid
Liquid
Air
11/93
-------
Worksheet 3B
Worksheet 3 provides a process flow diagram for the PPOA. The flow diagram should
represent all PPOA ID Code(s) associated with the process, all input materials, and outputs
(products/wastes). The flow diagram should track materials from the time they enter the
process boundary until they leave. This diagram represents a very simplistic flow model; a
more detailed diagram may be required to identify all waste streams, especially for complex,
multi-step processes.
1. Revision No,: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
4. Process Flow Diagram: List the input materials on the lines provided. Fill in the
Process Name box. Then highlight those outputs that are applicable to the process
(e.g. Product, Hazardous, etc.). Then categorize those outputs into solid, liquid, or
air emission streams by highlighting the corresponding output stream. A Stream ID
Code is provided for each category of waste.
5. Outputs: The Stream ID Code provides a uniform coding scheme for the release
information requested on Worksheet 4. A brief waste description may be recorded
in the box to the right of the Stream ID Code.
DOE Definitions:
High Level Waste- Irradiated reactor fuel, liquid wastes resulting from operation of the
first cycle solvent extraction system, or equivalent, and the concentrated wastes
from subsequent extraction cycles, or equivalent, in a facility for reprocessing
irradiated reactor fuel, and solids into which such liquid wastes have been
converted. (10CFR60.2)
Transuranic Waste - Waste that is contaminated with alpha-emitting radionuclides with
(1) an atomic number greater than 92 (heavier than uranium); (2) half-lives greater
than 20 years; and (3) concentrations greater than 100 nanocuries per gram of
waste.
Transuranic Mixed Waste: - Waste which contains both transuranic waste and
hazardous components, as defined by the Atomic Energy Act and RCRA,
respectively.
Low Level Waste: - Radioactive Waste not classified as high level waste, transuranic
waste, spent nuclear fuel, or by-product material [specified as uranium or thorium
tailings and waste in accordance with DOE Order 5820.2A].
Low Level Mixed Waste: - Waste which contains both low level waste and hazardous
components, as defined by the Atomic Energy Act and RCRA, respectively.
-------
Level III
Time frame
From:
To:
Polli
Material
Description
Totals/Subtotals
Total
Input
ution Prevention Opportunity Assessment
Mass Balance Summary
PFOA Title or PPOA ID Code(s):
Total
Output
Stream
ID Code
o
Stream
ID Code
O
Stream
ID Code
O
Stream
ID Code
O
Stream
ID Code
O
Stream
ID Code
O
Revision No.;
Revision Date:
Page
Of
Stream
ID Code
O
Stream
ID Code
O
Stream
ID Code
O
11/93
-------
Worksheet 4
A material balance is a summation of the total quantity of input material
to a process and the releases to the environment, another process, or
made into product. The purpose of Worksheet 4 is to tabulate this
information and total the inputs and outputs for all streams.
1. Revision No.: List the revision number of the PPOA.
2.
3.
Revision Date: List the most recent revision date for the PPOA
worksheet.
PPOA Titie/PPOA ID Code(s):
given on Worksheet 1.
List the PPOA Title or ID Code(s)
4. Page
of
Indicate the page number for this worksheet and
the number of pages for this worksheet.
5. From/To: Report the dates (month and year) for the time period
covered. An annual period is suggested for purposes of averaging
and documenting performance toward facility goals.
6, Material Description: List the material name and stock number
(optional) or the output product if different than originating material.
7. Units : Enter the unit of measure for the input/output summary.
A consistent unit of measurement is suggested. If requirements
dictate mixing units, designate the units for a particular column
under the Stream ID Code heading.
8. Total Input: For the material described in the far left column enter the
weight of material used in the process during the time frame
specified.
i. Total Output: For the material specified in the Material Description
column enter the weight of the output. This is the sum of all waste
streams and any product generated. For processes where chemical
reactions take place, input materials are consumed or changed to
different compounds, a separate entry in the Material Description
column is required to adequately define the output. In these cases,
the input and output quantities will not balance for the listed
material in that row.
10. Output Quantity: Use these columns to break down the total output
into output categories. Refer to Worksheet 3 for the appropriate
Stream ID Code for the output type. Enter the Stream ID Code at
the top of the column (e.g., HZ1 for a hazardous solid waste
stream), then enter the discharge amount for the material described
in the Material Description column that relates to that Stream ID
Code. Continue across the worksheet for all Stream ID Code(s)
utilized in Worksheet 3.
11. Totals/Subtotals: Sum the Total Input, Total Output, and Output
columns. Record the sum at the bottom row of the last worksheet.
Subtotals are recorded at the bottom row for other pages of the
worksheet. The Total Input column should equal the Total Output
column unless there is system accumulation. The Total Output
column should also be the sum of all the Stream ID Code output
streams.
Stream ID Codes:
Designator
Product
Hazardous
Non-Hazardous
Radioactive
Mixed
Other
Hazardous, RCRA
Hazardous, Non-
RCRA
Toxic, TSCA
High Level
Transuranic, TRU
TRU, Mixed
Low Level
Low Level, Mixed
Other, Radioactive
Style 1
PR
HZ
NH
OT
Style 2
PR
HZ
NH
RD
MX
OT
Style 3
PR
NH
OT
HR
HN
TS
HL
TU
TM
LL
LM
OR
Solid Stream = 1, Liquid Stream = 2, Air Stream = 3
Style refers to the version of Worksheet 3 used.
-------
Worksheet 5
Level
Revision No.: _
Revision Date:
Page of _
Pollution Prevention Opportunity Assessment
Material Cost
PPOA Title or PPOA ID Code(s):
Input Material Cost:
Material
Stock Number
(if applicable)
Waste Disposal Cost:
Material / Waste Stream
Waste Stream
Category
Cost Per
Unit
Total /
Subtotal
Annual Cost
Cost Per
Unit
Total /
Subtotal
Annual Cost
-------
Worksheet 5
Worksheet 5 details the cost of the PPOA input materials (use the quantities from
Worksheet 4) and the cost of disposal for these materials. The material cost may be
obtained from Purchasing or Stores. The cost of disposal may be obtained from Waste
Management or Accounting. Annual Cost is calculated from the amount of material placed
in the process or from the amount of disposed material, multiplied by the cost per unit.
1. Revision No.: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. Page of : Indicate the number of this page and the total number of pages for
this worksheet.
4. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
5. Input Material Cost: List the material, stock number (if applicable), cost per unit
($/lb., $/gal, etc.), and the annual cost for this process.
6. Waste Disposal Cost: List the material or waste stream, waste stream category, (e.g.,
hazardous liquid), stock number if applicable, the cost per unit ($/lb., $/gal, etc.),
and annual cost.
7. Totals / Subtotals: Record the sum of the annual costs for the materials or waste
streams listed. There will be a total for both the input material cost and waste
disposal cost.
-------
Worksheet 6
Level III
Pollution Prevention Opportunity Assessment
Option Generation
PPOA Title or PPOA ID Code(s);
Practices &
Procedures
Revision No.:
Revision Date:
Material
Substitution
fidr Prlaceis
Equipment
Modification
Pollution
Prevention
Options
11/93
-------
Worksheet 6
Worksheet 6 provides a tool for option generation.
The purpose of this diagram (sometimes referred to
as a Fishbone Diagram) is to help generate pollution
prevention ideas. It is especially useful in a
brainstorming session to group ideas undersimilar
pollution prevention categories. It also helps insure
that all of the pollution prevention categories are
considered.
1. Revision No.: List the revision number for this
worksheet.
2. Revision Date: List the most recent revision date
for this worksheet.
3. PPOA Title or PPOA ID Code(s): List the PPOA title
or PPOA ID Code(s) given on Worksheet 1.
4. Brainstorming ideas: Using the Fishbone
Diagram, briefly document ideas for pollution
prevention.
The following definitions clarify each of the major
categories.
Practices & Procedures - Good operating
practices and procedures apply to the human
aspect of operations. They are largely
efficiency improvements. Examples are:
Pollution Prevention Programs, personnel
training, material handling & inventory
practices, material loss prevention, scrap
reduction, cost accounting, production
scheduling, etc.
Material Substitution ~ Changes to the input
materials of the process. The result is a
reduction or elimination of a pollutant or
hazard.
New Product &/or Process -- Product changes
which result in the reduction or elimination of
waste. In addition, a different process can be
used to create the same product with the intent
of minimizing waste.
Waste Segregation/Hazard Reduction -- Actions
taken to segregate waste streams to prevent
nonhazardous waste from being designated
and handled as hazardous. Hazard reduction
can result from changes to the physical,
chemical, or biological character or
composition of the waste. These include
neutralization, toxicity reduction, or volume
reduction.
Equipment Modification -- Changes that occur to
the equipment used in a process. These could
include minor adjustments, additions, or
complete replacements.
Recycling - A material is recycled if it is used,
reused, or reclaimed: (1) if it is used for
something other than its original purpose, (2) if
it goes back into the original process, or (3) if it
is chemically or physically treated for use or
reuse.
-------
Level III
Revision No.:
Revision Date:.
Page pf_
Pollution Prevention Opportunity Assessment
Option Description
PPOA Title or PPOA ID Code(s):
Option Name and Description
( Include input materials, products affected, and anticipated reduction quantity.)
Option No. :
Practices & Procedures
Material Substitution
New Product &/or Process
Option No.
Consider: Yes No
Waste Segregation/Hazard Reduction
Equipment Modification
Recycling, Reuse, & Reclamation
Practices & Procedures
Material Substitution
New Product &/or Process
Option No.
Consider: Yes No
Waste Segregation/Hazard Reduction
Equipment Modification
Recycling, Reuse, & Reclamation
Practices & Procedures
Material Substitution
New Product &/or Process
Option No.
Consider: Yes No
Waste Segregation/Hazard Reduction
Equipment Modification
Recycling, Reuse, & Reclamation
Practices & Procedures
Material Substitution
New Product &/or Process
Consider: Yes No
Waste Segregation/Hazard Reduction
Equipment Modification
Recycling, Reuse, & Reclamation
11/93
-------
Worksheet 7
The purpose of this worksheet is to further document the pollution prevention options
identified on Worksheet 6. The process by which options are identified should occur in an
environment that encourages creativity and independent thinking. Brainstorming sessions
are effective ways for individuals to generate options. Consideration of the options
generated in a brainstorming session can lead to questions. Answering these questions
may require additional research. Listed below are some of the sources that can help to
answer questions and/or generate additional options.
Literature searches
Technical conferences
Equipment exhibitions
Trips to other plants
Vendor surveys
Contact with design engineers
Contact with personnel in other departments who have participated in similar
PPOAs
Materials engineers
Benchmarking
1.Revision No.: List the revision number for this worksheet.
2. Revision Date; List the most recent revision date for this worksheet.
3. PPOA Title or PPOA ID Code: List the PPOA Title or PPOA ID Code given on
Worksheet 1.
4. Page of : Indicate the number of this page and the total number of pages for this
worksheet.
5. Option: Options generated should be numbered consecutively and placed on this
worksheet (reference Worksheet 6). They may or may not be evaluated. Briefly
describe each option, affected materials and product, any roadblocks to
implementation, upstream and downstream impacts if implemented, and
anticipated reduction quantity.
6. Consider Yes/No: If the suggestion is worth further consideration, check
'Yes1. If the suggestion will not be pursued, check 'No' and indicate
briefly in the Option Description why not.
7. Practices & Procedures, Material Substitution, New Product &/or Process, Waste
Segregation/ Hazard Reduction, Equipment Modification, and Recycling, Reuse, &
Reclamation: Check the appropriate descriptions. See Worksheet 6 for definitions.
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Worksheet 8
Level III
Revision No,:
Revision Date:
Page
of
Pollution Prevention Opportunity Assessment
Options Cost Evaluation
PPOA Title or PPOA ID Code(s):
Option No.:
Option No.:
Option No.:
Option No.:
Purchased Equipment
Installation
Materials
Utility Connections
Engineering
Development
Start up / Training
Administrative
Other
Total Implementation
Cost
Option No.:
Incremental Operating Costs
Change in Raw
Materials
Change in Maintenance
Change in Labor
Change in Disposal
Other
Annual Operating
Savincjs/(Cost)
Penalties and Fines
Future Liabilities
Other
Annual Intangible
Savings/(Cost)
Total Annual
Savings/(Cost)
Payback Period
incremental jfritang
|$e Costs
11/93
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Worksheet 8
This worksheet provides a method to compare and contrast the pollution prevention options
generated on Worksheet 6 from a cost perspective. The three major cost categories for
weighing options are: Implementation Costs, Incremental Operating Costs, and incremental
Intangible Costs. These costs are totaled for each option considered from Worksheet 7.
This worksheet will aid in completing the economic evaluation portion of Worksheet 9.
1. Revision No.: List the revision for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. Page of : Indicate the number of this page and the total number of pages for
this worksheet.
4. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
5. Implementation Cost: These are the one-time, first-year costs associated with the
implementation of each option. Installation costs should be reported as an estimate.
Implementation Cost may include materials, utility connections, site preparation,
installation, engineering, procurement, start-up, training, permitting, initial catalysts and
chemicals, and working capital; minus the salvage value of any existing equipment.
6. Annual Operating Savings/(Costs): These are the costs associated with day-to-day
operations. List the incremental costs compared to the current process costs (positive for
savings or negative for increased costs) that would be incurred if this option is
implemented. Incremental operating costs could include waste disposal, raw material
consumption, ancillary catalysts and chemicals, labor, maintenance and supplies,
insurance, incremental revenues from increased / decreased production, and incremental
revenues from marketable by-products.
7. Annual Intangible Savings/(Cost): These include hidden, liability, and other costs not
immediately obvious for each option. List the incremental costs compared to the current
process costs (positive for savings or negative for increased costs) that would be incurred
if this option is implemented. These costs could include penalties and fines, future
liabilities (storage, transportation, and disposal of hazardous waste), reporting, consulting
fees, monitoring/testing, record keeping, preparedness and protective equipment,
medical surveillance, manifesting, inspections, and corporate/public image.
8. Total Annual Cost/Savings: This is the sum of the Annual Operating Savings/(Cost) and
the Annual Intangible Savings/(Cost)
S. Payback Period: Divide the Total Implementation Cost by the Total Annual
Savings/(Cost).
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Worksheet 9
Level Hi
Pollution Prevention Opportunity Assessment
Weighted Sums Option Evaluation
PPOA Title or PPOA ID Code(s):
Revision No.:
Revision Date:
Page of
Criteria
Public Health, Safety, &
Environment
Employee Health &
Safety
Regulatory Compliance
Economic
Implementation Period
Improved Operation /
Product
Other
Subtotal
Likelihood of Technical
Success (Multiplier)
Likelihood of Useful
Results (Multiplier)
Total
Rank
Weight
W
10
10
8
6
4
2
Ilillii I?
1
111 ;
Option N
Scale
'S'
X
X
o.:
•WxS'
Option N(
Scale
'S'
X
X
a.:
'WxS1
Option N<
Scale
'S'
X
X
iililiiii
D.:
'WxS'
Option N
Scale
'S1
X
X
o.:
'WxS'
Option N
Scale
'S*
X
X
o.:
'WxS1
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Many pollution prevention options will be identified in a successful assessment. At this point, it is necessary to identify those
options that offer real potential to minimize waste and reduce costs. Worksheet 9 serves as a screening tool to prioritize or
eliminate suggested options.
1. Revision No.: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. Page
of : Indicate the number of this page and the total number of pages for this worksheet.
4. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on Worksheet 1.
Additional Instructions:
a. The values in the Weight column (designated by W)
represent the facility's priority for the criteria.
b. In the Scale column for each option (designated by 'S'),
rate each criteria by assigning a value from 0-10
(lowest to highest). Use the definitions which follow to
help determine a value.
c. In the 'W x S' column for each option, enter the product of
the weight and scale.
d. Sum the 'W x S1 column for each option to obtain a subtotal.
e. Multiply the subtotal for each option by the Likelihood of
Technical Success.
f. Multiply the value in step e. above for each option by the
Likelihood of Useful Results.
g. Enter the product found in step f. in the Total column for
each option.
h. Assign a priority rank for each option; #1 for the highest
score, #2 for the next highest, and so on.
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Worksheet 9 -- (Scale & Multiplier Definitions)
Scale Factor Definitions (0-10)
10
Reduce the risk of loss of life or long-term
environmental damage. High concentrations of
hazardous materials.
8
Reduce the risk of long-term disability or moderate
environmental damage. Moderate concentrations
of hazardous materials.
Reduce the risk of short-term disability or
unplanned releases to the environment. Low
concentrations of hazardous materials.
No effect.
0
Negative effect.
10
Reduce the risk of loss of life through an accident
or long-term exposure.
8
Reduce the risk of permanent or long-term
disability through an accident or long-term
exposure.
Reduce the risk of short-term disability or lost-time
through an accident or long-term exposure.
No effect.
0
Negative effect.
10
Reduce the risk and avoid criminal penalties.
8
Reduce the risk and avoid civil penalties.
Reduce the risk.
No effect.
0
Negative impact.
10
Large savings and short payback.
8
Moderate savings and moderate payback.
Positive cost savings and extented payback.
No cost savings and no possibility of payback.
0
Negative cost savings.
10
Immediate (e.g., within 1 month).
8
Short-term (e.g., within 1 year).
Intermediate (e.g., within 2 years).
Long-term (e.g., within 3 years).
0
Greater than 3 years.
10
8
6
4
0
Significant improvement.
Moderate improvement.
Positive improvement.
No improvement.
Negative effect.
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Worksheet 9 - (Scale & Multiplier Definitions)
Multiplier Definitions (0-1)
High likelihood: No major technical breakthrough
required. Well-designed plans to meet objectives
and successful track record exists.
0.5
Medium likelihood: Technical advancements may
be necessary. Key issues are identified but no
specific contingency plans have been made.
0.1
Low likelihood: Major technical breakthroughs are
required. Adequate plans for meeting objectives or
key problems have not been Identified.
^^: M^
High likelihood: Project has demonstrated that it
can meet production requirements. There is a high
confidence that implementation will not create
unacceptable risks. Benefits outweigh the costs.
0.5
Medium likelihood: Project has not yet
demonstrated that it can meet production
requirements. There are reservations that
implementation can be achieved without creating
unacceptable risks. Benefits do not clearly
outweigh the costs.
0.1
Low likelihood: The option is not capable of
demonstrating that it can meet production
requirements. Serious reservations are present
that implementation can be achieved without
creating unacceptable risks. Costs significantly
outweigh the benefits.
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Level III
Revision No.:_
Revision Date:_
Page of.
Pollution Prevention Opportunity Assessment
Final Report Check Sheet
PPOA Title or PPOA ID Code(s):
Requirement Completed
Title Page
PPOA Title
PPOA ID Code(s)
Team members
Issue date/revision date/revision no,
Executive Summary
Process description
Process assessment
Option summary and analysis
Conclusions
Recommendations
Introduction
Background of evaluation
Process Description
Associated equipment
Process flow diagram
Process Assessment
Methodology
Material Balance
Unusual occurrences
Option Summary and Analysis
Option description and rank
Upstream/Downstream impacts
Material usage
Anticipated reduction
Estimated costs
Estimated benefits
Feasibility
Waste streams affected
Conclusion
Concluding evaluation
Option analysis decisions
Concerns
Options already implemented
Lessons learned
Recommendations
Future work
New equipment
Implementation strategies
Worksheets
1-10
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Worksheet 10
A final report is required for each PPOA. The final report is a compilation of essential facts
about the process, pollution prevention options, feasibility and impact of those options, and
future implementation costs. The report documents the work performed and identifies
funding requirements necessary to implement pollution prevention options. The length of
the final report will depend on the complexity of the PPOA.
1. Revision No.: List the revision number for this worksheet.
2. Revision Date: List the most recent revision date for this worksheet.
3. Page of : Indicate the number of this page and the total number of pages for
this worksheet.
4. PPOA Title or PPOA ID Code(s): List the PPOA Title or PPOA ID Code(s) given on
Worksheet 1.
5. While writing the final report, check the blank next to each major requirement as all
elements of that task are completed.
Title Page
Executive Summary
Introduction
Process Description
Process Assessment
Option Summary
& Analysis
Conclusion
Recommendations
Uniquely identify the PPOA, including team members and
issue/revision date.
This should be an overview of all of the elements of the final
PPOA report. It should relate to the reader any information that
is critical about this PPOA.
Present background information and efforts taken to initiate the
PPOA.
Detail process flow and associated equipment. Include
process flow diagram, if desired.
Describe the approach used to complete the PPOA. Document
any assumptions made. Include information on the material
balance.
Present the options generated, impacts if implemented, and
their respective pollution prevention possibilities.
Provide closure to the report. The team's consensus on the
benefits achieved from this PPOA or any concerns respective to
the process should be included.
Describe any actions that will be taken to further advance the
results of this PPOA.
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Level I Date:
Page of.
TOe:
Pollution Prevention Opportunity Assessment
Team & Process Description
PPOAIDCode:
Team Members ('Leader) Job Classification Phone
Process Description:
Potential for Pollution Prevention or Recommendations:
11/93
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Worksheet 1S
This worksheet provides the scope arid identification of the pollution prevention
opportunity assessment (PPOA) team. For the PPOA to be successful,
employees involved with the activity being assessed should be members of the
team. The assessment team needs a leader, members, and additional
resources, as required.
The team leader should have technical knowledge of the area's operations and
the personnel involved. The leader shall assemble the team to perform the
assessment. Team members may include engineers, waste generators,
waste management specialists, scientists, laboratory technicians, and other
line personnel. Additional resources may be utilized to provide information not
available within the team. The size of the team may be large for complicated
operations, but should be kept to a minimum to maintain focus.
1. Date: List the initiation date for this PPOA.
2. Title: List the PPOA title selected by the team.
3. PPOA ID Code: List the PPOA ID Code selected by the team. This should
be a unique identifier.
4. Team Members, Job Classification, Phone: To facilitate team meetings
and for future reference, this information should be completed when the
PPOA team is formed.
5. Process Description: This should detail important attributes of the
operation. Equipment, summary of operations performed, controls,
input materials, and operator training (qualification or certification) may
be included.
6. Potential for Pollution Prevention or Recommendations: For this process,
describe the potential for pollution prevention, source reduction, and/or
waste minimization. (Is there any pollution prevention potential for the
following changes: material substitution, procedures, process
parameters, equipment, general practices, recycling, reuse, reclamation,
etc.?) Are there any recommendations for this process?
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Level I
Date:
Pollution Prevention Opportunity Assessment
Process Flow Diagram
Title or Assessment ID Code:
Inputs:
(MXI)
(MX2)
(MXS)
Solid
Liquid
Air
Solid
Liquid
Air
Solid
Liquid
Air
Solid
Liquid
Air
(NHI)
(NH2)
(NH3)
Solid
Liquid
Air
Solid
Liquid
Air
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Worksheet 2S
This worksheet provides a method to document the process flow diagram for
the assessment. The flow diagram should identify all Assessment Code(s)
associated with the process, all input materials, and outputs
(products/wastes). The flow diagram should track materials from the time they
enter the process boundary until they leave. This diagram represents a very
simplistic flow model; a more detailed diagram may be required to identify all
waste streams, especially for complex, multi-step processes.
1. Title or Assessment ID Code(s): List the PPOA Title or PPOA ID Code given
on Worksheet 1S.
2. Page of.
Indicate the page number for this worksheet and the
number of pages for this worksheet.
3. Inputs: List the input materials on the lines provided. Fill in the Process
Name box. Then highlight those outputs that are applicable to the process
(e.g. Product, Hazardous, etc.). Then sub-categorize those outputs into
solid, liquid, or air emission streams by highlighting the corresponding
output stream. A Stream ID Code is provided for each sub-category of
waste.
4. Outputs: The Stream ID Code provides a uniform coding scheme for the
release information. A brief waste description may be recorded in the box
to the right of the Stream ID Code. The code information is summarized in
the table below:
Stream ID Codes
Designator
Product
Hazardous
Non-Hazardous
Radioactive
Mixed
Other
Code
PR
HZ
NH
RD
MX
OT
Solid Stream = 1, Liquid Stream = 2, Air Stream = 3
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Level I
Page
of
Pollution Prevention Opportunity Assessment
Material & Waste Stream Summary
Title:
PPOA ID Code:
Input
Material
Annual
Quantity
Used
%
Product
%
Recycled
Total Releases
%
Air
%
Liquid
%
Solid
Does the process require further analysis based on the site's Priority
Material/Waste Stream List? Yes No
Level II Level
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Worksheet 3S
This worksheet provides a brief summary of the input materials and output
streams from the operation or activity being assessed. Its purpose is to
provide the pollution prevention team an overview of the waste streams
resulting from the PPOA.
1. Title: List the PPOA title given on Worksheet 1S.
2. Assessment ID Code: List the PPOA ID Code given on Worksheet 18.
3. Input Material: List the material names which enter the operation.
4. Annual Quantity Used: Enter the annual quantity used for each material
listed - include the unit of measure, e.g., Ibs, curies, etc. For input
material from another process, it may be helpful to also identify the
release components of those materials.
5. % Product: For each input material, estimate the percent of the annual
quantity used which goes to product.
6. % Recycled: For each input material, estimate the percent of the annual
quantity used which is recycled.
7. % Air: For each input material, estimate the percent of the annual quantity
used which is an air waste stream.
8. % Liquid: For each input material, estimate the percent of the annual
quantity used which is a liquid waste stream.
i. % Solid: For each input material, estimate the percent of the annual quantity
used which is a solid waste stream.
10. Does the process require further analysis based on the site's Priority
Material/Waste Stream List? Using your site's Priority Material/Waste
Stream List and the DOE Graded Approach Logic Diagram, determine if
further assessment is necessary. If yes, indicate the level of
assessment required.
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Worksheet 45
Level II
Page
of.
Pollution Prevention Opportunity Assessment
Option Summary
Title or PPOA ID Code(s)
Option h
o. :
Type
<*)
Option N
Consider?
Feasibility
Estimated
Cost
Estimated
Savings
Anticipated
Reduction Qty
o. :
Type
n
Option N
Consider?
Feasibility
Estimated
Cost
Estimated
Savings
Anticipated
Reduction Qty
o. :
Type
(*)
Consider?
Feasibility
Estimated
Cost
Estimated
Savings
Anticipated
Reduction Qty
(*) Type = Source Reduction, Recycling, Treatment, or Disposal
11/93
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Worksheet 4S
This summary sheet serves as a method to record and evaluate the options that have been
identified during brainstorming sessions or other option generating techniques.
1. Title or PPOA ID Code{s): List the PPOA Title or PPOA ID Code given on Worksheet 1S.
2. Option : Options generated should be numbered consecutively. Briefly describe each
option, affected materials, waste streams, upstream/downstream impacts if
implemented, and anticipated reduction quantity if implemented.
3. Type: Indicate whether the option is source reduction, recycling, treatment, or disposal.
4. Consider?: If the option is worth further consideration, enter YES. If not, enter NO and
briefly indicate in the Option Description why not.
5. Feasibility: Provide a brief description. (Excellent, good, fair, poor)
6. Estimated Cost: Estimate an implementation cost.
7. Estimated Cost Savings: Estimate the cost savings.
8. Anticipated Reduction Qty.: Estimate the weight or volume of the waste that will be
reduced.
Note: Typically, it is difficult to estimate the anticipated waste reduction or cost avoidance in
the initial phases of implementation because of many factors. However, for some options,
especially in cases where the option provides complete elimination of a hazardous material
or waste stream, these estimates can be accurately completed.
The process by which options are identified should occur in an environment that encourages
creativity and independent thinking. Brainstorming sessions are effective ways for
individuals to generate options. To make these sessions beneficial, research is often
necessary. Provided below is a fishbone diagram that will help the team generate ideas.
Pollution
Prevention
Options
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Level II
Date:
Page of.
Pollution Prevention Opportunity Assessment
Final Summary
Title:
PPOA ID Code(s):
Assessment:
Conclusions:
Recommendations:
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Worksheet 5S
This sheet provides a brief summary of other pertinent information about the activity
being assessed. Its purpose is to document how this assessment was performed,
the conclusions reached by the team, and the recommendations for further actions.
1. Date: List the date this sheet was completed,
2. Title: List the title given on Worksheet 1S.
3. PPOA ID Code(s): List the ID Code(s) given on Worksheet 1S.
4. Assessment: Briefly describe the approach (methodology) used to complete this
assessment and any assumptions made.
5, Conclusions: Briefly describe the waste streams or input material to be
minimized, benefits achieved from this assessment, and any concerns
(environmental or health risks) associated with the material or operation.
6. Recommendations: Briefly describe any actions that should or will be taken in
respect to this assessment.
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APPENDIX H
REFERENCES
1. U.S. Department of Energy, General Environmental Protection Program, DOE
Order 5400.1 (November 9, 1988).
2. U.S. Department of Energy, Hazardous and Radioactive Mixed Waste Program,
DOE Order 5400.3 (February 22, 1989).
3. U.S. Department of Energy, Radioactive Waste Management, DOE Order
5820.2A (September 26, 1988).
4. U.S. Department of Energy, Environmental Restoration and Waste Management
Five-Year Plan, DOE/S-0070 (1989).
5. U.S. Department of Energy, Applied Research Development, Demonstration,
Testing and Evaluation Plan (Draft) (November 1989).
6. U.S. Department of Energy, Model Waste Minimization and Pollution Prevention
Awareness Plan (1990).
7. U.S. Department of Energy, Process Waste Assessment Guidance (ISO).
8. U.S. Environmental Protection Agency, Facility Pollution Prevention Guide
EPA/600/R-92/088 (May 1992).
9. M.I. Baker and F.E. Kosinski, Process Waste Assessments for Waste Minimization
Planning, U.S. Department of Energy, Oak Ridge Y-12 Plant, Y/DZ-532
(November 21, 1989).
10. E.A. Kjeldgaard, J.H. Saloio, and G.B. Varnado, Development and Test Case
Application of a Waste Minimization Project Evaluation Method, U.S. Department
of Energy, Sandia National Laboratories, SAND90-1178 (August 1990).
11. H.M. Freeman, Hazardous Waste Minimization, McGraw-Hill Publishing
Company (1990).
12. U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation
and Office of Solid Waste, Pollution Prevention Benefits Manual, October 1990.
13. U.S. Department of Energy/Defense Program's, Office of Production Facilities
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