United States
Environmental Protection
Agency
An Organizational Guide to
Pollution Prevention

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&EPA
U.S. Environmental Protection Agency, Office of Research and Development
National Risk Management Research Laboratory
Center for Environmental Research Information
Cincinnati, Ohio
 to the Virtual Companion to
 An Organizational Guide to
 Pollution Prevention
EPA/625/C-01/003
   August 2001
                                                        EPA Info on P2
                                        Info on the P2 Tools
                                          P2 Checklists
                                                     P2 and the EMS Model
 Choose your desti
                                For navigation help,
                                double-click on the
                                yellow question marks.
                                              _J
                                       P2 and the Quality Model
                                           P2 Manuals

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                            Green Zia Environmental Excellence Program
                            New Mexico Environment Department
                            PO Box 26110
                            Santa Fe, NM 87502
                            Pat_gallagher@nmenv. state, nm. us
                            505-827-0677
Green Zia Environmental
Excellence Program
Jewelry Manufacturing
Guidance for improved environmental
performance and pollution prevention in
your jewelry manufacturing business

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         Acknowledgements

The material in this booklet is based on the Systems Approach to Pollution
Prevention, developed by Dr. Robert Pojasek of Pojasek and Associates and
the Nothing to Waste Manual developed by US Environmental Protection
Agency Region 1. Process maps were developed by Ms. Alicia Hale of Los
Alamos National Laboratory. Special thanks also to Brynda Lujan of the
City of Albuquerque for her assistance in preparing these maps.

This manual is printed on recycled paper.  The manual jewelry
manufacturing and distribution is supported through funding provided by the
US Environmental Protection Agency. Special thanks to Rob Lawrence, Eli
Martinez and Joy Campbell of the US Environmental  Protection Agency for
their help in funding this project and in supporting pollution prevention in
New Mexico.

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Table of Contents


Introduction to Green Zia Program	Pagel


Green Zia Tools for Jewelry
Manufacturing	Page 5

Process Maps for Jewelry
Manufacturing	Tab 1

Pollution Prevention Ideas, Regulatory Guidance and

Other Resources	Tab 2

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Ill

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The Green Zia Environmental


Excellence Program


Guidance materials for jewelry manufacturing.


Introduction

This workbook contains information on how to establish a pollution prevention program
specific for a jewelry manufacturing operation.  The workbook also contains waste
management and regulatory guidance materials to help assure that you are in compliance
with environmental, health, and safety regulations.  Used together, this information can
help you establish a pollution prevention program that will help you be in compliance and
reduce waste.  Use of the tools from start to finish also helps you qualify for the Green
Zia Environmental Excellence Program.

The Green Zia Environmental Excellence Program is a voluntary program based on
quality management principles that is designed to help New Mexico businesses achieve
environmental excellence through pollution prevention programs.. This program is
administered by a partnership of state, local, and federal agencies, academia, private
industry, and environmental advocacy groups. This packet has been specifically
developed for a jewelry manufacturing operation and is designed to meet the needs of a
small business.

The basic logic of the Green Zia Environmental Excellence Program is that:

    •    waste or pollution is the result of inefficiency;
    •    reducing waste increases profits;
    •            waste that is not created cannot pollute.
This guidance has been developed to aid in your company's understanding of best
management practices to help your company comply with environmental health and
safety regulations and to reduce waste and associated liabilities.

It is important to remember that environmental health and safety regulations are triggered
by the use of equipment and chemicals.  Better use of chemicals, use of safer chemicals,
and efficient operation of machinery can help reduce your regulatory burden—if you
aren't using hazardous materials, then you have fewer regulations to be concerned with!
This program is based on first understanding work processes and materials use and then
improving work practices to reduce cost, waste, and regulatory concerns.

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Working through the Green Zia Environmental Excellence Program will result in a
system that helps address environmental issues in cost effective ways, based on sound
business practices.  The system provides a framework for continuous improvement over
time and contributes to a thorough understanding of environmental issues in your
business.
What is Pollution Prevention?

Simply put, pollution prevention means not creating a waste in the first place.  Pollution
prevention is achieved by the efficient use of resources, including raw materials, energy,
water and even time and distance. The goal is to produce a product or deliver a service as
efficiently as possible, with the least amount of wasted materials and the least possible
environmental impact.

The bottom line is that pollution prevention or improved efficiency can help businesses
save money and help protect the environment at the same time.
What is Environmental Excellence?

Environmental excellence means moving beyond compliance with environmental, health
and safety regulations by establishing an environmental management system that
incorporates pollution prevention into core business practices.

A prevention-based environmental management system will:

   •     Help a business identify all the environmental compliance and health and
       safety concerns as well as costs associated with a waste generating process, and
   •     Use prevention approaches to reduce or eliminate the waste and reduce the
       associated costs.

In the Green Zia Environmental Excellence Program, attention is focused on the process
that generates the waste, not the waste.  Identifying and implementing process
improvements will reduce waste and costs. This is a major shift from the traditional,
reactionary approach that concentrates only on managing wastes or pollutants already
created to an anticipatory approach that concentrates on prevention of wastes or
pollutants to improve environmental and economic performance.  This prevention-first
environmental management system will identify cost effective ways to achieve "beyond
compliance" status, creating a win-win situation between economics and environment.

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    The Green Zia Tools
    The Green Zia Program provides tools to establish a basic prevention-based
    environmental management system. Management and employees walk through the tools
    as a team to gain a complete understanding of their operation. Examples have been
    worked out for the auto repair business.  We encourage you to customize the examples to
    your own operations. The packet includes a series of process maps (Tool 1) for some
    operational areas of the auto repair business.  Tools 2-6 are also explained and illustrated
    to help you develop your program. Use of these tools on a regular basis will help your
    company qualify for the Green Zia Environmental Excellence Program.

    Green Zia Tools:
Knowledge of
  Process
  Full Cost
 Accounting
 Pinpointing
  Problems
  Problem
  Solving
Prioritization
 of Options
  Ensuring
  Success
   Tool 1: Process Mapping:  Illustrates the work steps materials pass
through as they are transformed into your final product. Maps allow for the
identification of all inputs and outputs such as water, chemicals, electricity or
other materials from a process, helping you to understand wastes and their
   sources. Maps also help you understand regulated activities.

Tool 2: Activity-Based Costing: Identifies the true costs of wastes or losses
and helps participants identify areas to target for pollution prevention, by
assigning dollar values to these wastes and losses.

Tool 3: Root Cause Analysis:  Creates a cause and effect diagram to
highlight why and where the losses occur in the process. Understanding why
and where the loss occurs will help participants focus on specific areas for
   improvement.

Tool 4: Brainwriting: Addresses problems by generating as many
alternatives as possible to minimize loss.

Tool 5: Bubble-up-bubble-down: Ranks alternatives to determine the
optimal solution. Factors such as cost, ease of implementation and
effectiveness  are considered in evaluating and ranking the alternatives.

Tool 6: Action Plan: Details each step that needs to be taken to implement
the alternative and reduce or eliminate the loss from the process.

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Tool#l:  Process Mapping
         To begin incorporating pollution prevention into your business,
         you must first get a full understanding of where wastes are being
         generated. This tutorial will discuss the advantages of using
         process maps to logically evaluate each step of your process.
 'arm-up Exercise
                             Maps have been used throughout the ages for many
                             purposes from helping sailors navigate the seas to
                             providing a safe route for climbers hiking to the tallest
                             peaks. You have probably drawn maps to your home
                             or office so that someone could visit. It is important
                             that the information on this map is complete and
                             accurate or, as you may have found, your guest will
                             get lost!
            Take a minute now and think of a coffee shop or restaurant nearby that
            everyone in the group knows. Draw a map from the building you are
            currently in to this establishment - include traffic lights, landmarks, and
            any other important features along the way. Now compare maps with the
            other members of your group. Are they the same? If a per son not familiar
            with the area were to use your map, would they have found their way?

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Introduction

 Are you aware of the amount of waste that your business generates? Could this waste be
 turned into profit? By considering methods of reducing wastes, recycling used and
 unused raw materials, and reusing lost material, you could not only help the
 environment but also reduce your raw material and waste disposal costs.

 This section discusses process mapping, a method of analyzing a process in order to
 catalogue all the materials used and lost in the process. With process mapping, you will
 systematically identify the series of steps materials pass through as they are transformed
 into the final product. Evaluating your process in this manner will  allow you to
 recognize the opportunities to prevent losses and possibly streamline operations. Each
 loss identified during the process mapping is an opportunity to prevent that loss.

 A series of process maps have been developed for jewelry manufacturing operations and
 are included in this packet. You should customize these maps for your operation, since
 no two businesses are exactly alike. These maps become  a reference for you to use for
 your pollution prevention program and can be updated to reflect changes as you improve
 your operations.  These maps are also great for training new employees and for other
 problem solving needs.

 Large businesses and manufacturers use these tools to understand and improve their
 manufacturing processes.  Small businesses can benefit by using these tools as well!

 It is helpful to also prepare a narrative to go along with your process maps to explain the
 process in detail. We recommend that you include regulatory activities in the narratives
 as part  of your environmental management  system. Narratives are also included in this
 packet; please revise to reflect your business operations.

 Create  a team of employees to complete this exercise.  During this exercise you will:

      • Examine and revise the process maps and narratives in the packet to accurately
          reflect your operation
      • Fully understand the functionality of each step of a process
      • Identify the inputs and outputs/losses within the  process
      • Communicate findings in a clear and concise manner to members of the team.

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Example of a process map for jewelry manufacturing:
                        Process Map 3.0: Jewelry Finishing

Water
Energy

Waler Jewelry PPE
\


\
' * 1
3.1
Acid
Pickle
, I •
' 1

^

'
Waste Acid Pickle sludge Energy '
Grind
Pads
• I,
Media
Je
PPE

r i
3.2

\

Deb urring/G rind ing/
Handfinishing

r ]

r
(metal, copper, silver) Waste Energy
Water

\
(ceramic, she
Water
Soap
Energy

'

^


r 1LJ


r 1
3.3
Tumbling

'
Waste 1
I
Waste
Water

1
Is, plastic)


'

^


r
r Energy
Metal Tumbling s,uTae
Spirits


r i
Deionizedwater Mineral Spirits


' 1
3.4

C


Cleaning

f 1
1
oth
r i

^

r
Mineral
Spirits


r 1
Sulfur


' 1
3.5
Ener
Ck
r 1

Jewelry
Treatment

' \

r i
ln PPE Solder
r v v v
3.6


f
' Solder
C|otn/ Wastewater Sulfur Wasle Mineral Used Cloth
Spirits
          Supplies
Please review the process maps in the back of this booklet and make changes to reflect
your operation.
 Once you have reviewed and revised the process maps to your operation,
            move to the next section...Activity-Based Costing!

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Tool #2: Activity-Based
Costing
         Every waste or environmental loss costs you money. By
         determining the activities that cause waste, you can focus your
         pollution prevention efforts to minimize the cost to your business
         and protect the environment.  This tutorial will introduce you to a
         method of evaluating your waste.
Warm-up Exercise
                          Your daughter approaches you one evening and says
                           that she is planning to buy a car. With the $400 she has
                           left over each month, after paying all of her bills, she
                           is sure she will be able to afford the $220 monthly car
                           payment.
            What are the other costs of operating and maintaining a car that she is
           forgetting? Consider not only the annual costs, such as insurance, but also
            the intermittent (once in a while) costs. Can she really afford this car?

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Introduction

Once you have determined the losses in your processes through your process maps, you
can discover how these losses are affecting your "bottom line". How much does it cost
you to discard 10% of your raw materials, or 2% of your finished products? Which
activities have losses that most hurt the profitability of your company?  This tool will
help you look at the cost of the losses in your business and see how much these losses are
costing you. The results may surprise you!

Which losses should you care about? The Pareto Principle suggests that 80% of the
problems in a business come from 20%  of machines, raw materials or operators. (The
same is true for any facet of a business, for example, 80% of sales come from 20% of
your customers, etc.) Once you have assigned costs to your activities, you can figure out
which 20% of your activities are contributing to 80% of your costs. The Pareto Principle
is very important in activity-based costing as it is used to focus on the most important
areas for improvement in your pollution prevention program. Use of the Pareto Principle
for the activity-based costing section will help  you quickly identify areas of your business
to  focus your prevention efforts.

New Terms
Activity based costing (ABC) - An accounting method used to assign the cost of your
losses to the activities that generate these losses. By assigning costs to activities, you will
discover the activities should be targeted for prevention.

Environmental costs -The costs associated with the losses in your process.

Intermittent or support operations - Operations that occur once in a while that are
necessary for the key processes to  operate.

Pareto principle - A principle that  suggests that 80% of anything can be attributed to 20%
of the factors involved. For example, 80% of your environmental costs can be attributed
to 20% of your activities.
                                        10

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Activity-Based Costing

    1.            Make a list of all the activities in your operation. Be sure to include the
       activities from your process map as well as any intermittent operations (such as
       cleaning or maintaining equipment.).

    2.            Regular activities:

          a.             Designing jewelry
          b.             Making molds
          c.             Making casts
c.            iviaKing casts
d.            Melting/pouring metals
e.            Devesting materials
f.            Finishing Jewelry
g.            Packaging and shippibg
   3.    Support activities:

          a.             Managing pickling solution
          b.             Managing devestment wastes
          c.             Equipment maintenance
          d.             Managing cleaning wastes
          e.             Managing various wastes such as molds, waste metals,
              wastewater
          f.             Equipment maintenance

   4.            List all of the losses in your operation. Look on your process map and
       add any others that you think of.

   5.            Reviewing your process maps, identify the operations in your plant
       that generate most of your waste or pollution problems. For example, does
       cleaning solvent use cause most of your environmental problems?  Do pickle
       wastes or air emissions from baking flasks or melting metals result in your biggest
       environmental problem? Does the 80/20 Rule apply? Focus your efforts for now
       on the areas of your operations that you do the most or that create the biggest
       environmental problem for you.

   6.            Use process maps to review material use and losses for your selected
       process or operation. You will use these maps as a guide to assign costs to these
       losses.

   7.            Identify which major costs or general ledger costs apply to the material
       use and losses on the process maps (utilities, metal purchase costs, waste disposal
       costs,  costs that are easy to get information on and that you typically consider
       when looking at your processes).  Enter into Table 1.  (See example provided)
                                        11

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    8.            Identify which other activities are related to the use of these materials
       that are not in the major costs (protective equipment such as gloves or goggles,
       monitoring, record keeping, maintenance, permits, metal recycling services, waste
       management service contracts, fees to the state or city, storage space for
       chemicals, the cost of spill clean-up and reporting). These activities are not
       usually considered when thinking about the cost of a process, yet the costs
       associated with them can be significant.

    9.            Write the activities in the first column of Table 2.  Along the top list
       all the costs or services required for these activities. Add or delete categories as
       appropriate for your business. Put an "x" for every cell that applies.

    10.           Count the total number of "x's" in Table 2. Then circle the x's that
       represent what you estimate to be about the top 20% of the most expensive
       activities in your operation. Again, you are using the  80/20 rule: 20 percent of
       your activities will probably add up to about 80% of your total costs.

    11.           Then estimate only the cost of each of these top 20% of activities that
       you circled and write them in a new table.  Cost estimates are allowable as you
       are using this method to prioritize your most expensive activities.  You can refine
       costs once you have chosen a project to work on. (In the example, the top 20% of
       the cost categories chosen have the estimate beside them.) Add these numbers
       into Table 1 under the appropriate waste stream in the "Hidden costs"  line.

    12.           Add the ledger costs and the hidden costs together to discover the true
       costs.

    13.           Create a Pareto Chart.  Create a chart showing all these costs
       graphically.  On the x axis (vertical), place costs in dollars, on the y axis
       (horizontal), show the true costs of the wastes.  This chart will help graphically
       show how all the costs stack up against each other.  Does the 80/20 Rule apply
       here? Use this chart to identify the most expensive processes.  This can be used
       to identify the first area for improvement. Which waste stream do you think you
       should focus on from this Pareto  chart?
An example of Activity-Based Costing is provided in the next section.  Please note that
this is an example to demonstrate how to assess costs.  The costs included are not from an
actual case study. Water and energy costs are not included in this example but should be
considered in developing improvement and cost saving projects. The example  provided
addresses only the major processes in a jewelry manufacturing operation. Environmental
improvement can be applied to every waste generating activity in your operation!
                                        12

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Activity-Based Costing Example

                          Process Map 3.0: Jewelry Finishing

Water
Energy

Wa
<


i
ler Jewelry
' T '
3.1
Acid
Pickle
• I •
PPE
r i


»f
*
r
Waste Acid Pickle sludge Energy '
Grind
Pads
T i
Med
Je
PPE

' 1
3.2
Deburring/Grin(

r i

ing/
Handfinishing

r \


(metal, copper, silver) Waste Energy
Water


1
ceramic, she
yvelry
Water
Energy503"

, \


»f
*

r V '


r 1
3.3
Tumbling

r
Waste l
Metal Tumblii
1
Waste
_ Water
" 1
9 Slu

1
a
Is, plastic)


r

»..
•^

r
r Energy
Ige
Media
Mineral Spirits


i







r i
Deonizedwater Mineral Spirits


r i
3.4

C
r '

Clean ng


r i


r
1
oth
r <

^


Mineral
Spirits


r '
Sulfur


r


1
Ener
Cl
r '
3.5
Jewelry
Treatment


' <


r
Used Cloth/ Wastewater Sulfur Waste Mineral
Clean ng
Supplies
Sp

rits



\
lh PPE Solder
r v v v
3.6


f

' Solder
Used Cloth


Activities
Materials and Losses
   Acid Pickling
   Deburring
   Tumbling
   Treatment
   Soldering
   Wastewater
   * Spent Pickle Solution
   *Energy (major cost across organization)
   * Metals
   *Waste Cleaning Solutions
   Devestment Waste
   *Paper
(*) indicates most important waste streams and
materials
                                         13

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Table 1. Activity-Based Costing Analysis (Per year)
Workstep
Costs/Losses
Raw material
Disposal fees
Other ledger
costs
Hidden Costs
Total
%of Total
Pickle
Solution
$2,000
$2,500
$500
($2,000)
$5,000
.18
Cleaning
Chemicals
$500
$1,500

($4,650)
$6,650
.240
Investment
materials
$2,500
$3,500

($6,650)
$12,650
.45
Waste-
water
$1,500
$2,0000

($500)
$3,500
.12
Metals
$2,500
0

$2,000
$500
.08
Total
$12,000
$13,500

($11,300)
$28,300
1.0
Table 2. Hidden Cost Analysis (per year)
Pickle Solution
Activities/Cost
Factors
HW Gen. fees
Reporting
Pickle
Recovery Unit
Materials


X($ 1,000)
Space


X
Utilities


X
Services



Total hidden costs for pickle solution
Labor and or
fee costs
X($ 1,000)
X
X
($2,000)
Cleaning Chemicals
Record
keeping
HW Gen. fees
Recycling
services
Cleaning
equip.


X
X


X







X ($3,000)
X
Total hidden costs for cleaning chemicals
X
X ($1,650)

X
($4,650)
Investment Materials
Discharge fees
Handling
Water use fees

X


X


X


X

Total hidden costs for investment materials
X ($1,650)
X ($5,000)
X
($6,650)
Wastewater
Discharge fees



X
Total hidden costs for wastewater
X ($500)
($500)
Metals
Recovery
service



X $3,500
Total hidden costs for metals
X ($1,500)
$2,000
                          14

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             Pareto Chart for Jewelry Manufacturing
   14000
   12000
OT  10000
to   8000
    6000
    4000
    2000
      0
   u


                             Losses
Pareto Chart for Jewelry Manufacturing. The Pareto Chart illustrates
costs relative to each other and helps choose areas to target for pollution
prevention activities.  In this example, investment materials, the most
expensive loss, will be the focus of the pollution prevention efforts in the
following sections.

Now that the process mapping and activity-based costing are completed,
you have a sense of the relative environmental costs of your operations.
Since investment materials are the target, we will use the following
problem-solving and decision-making tools to find a way to reduce
investment use, increase efficiency and save money.
           Most of your work is done.  These two tools can be
          revised as needed.  Use these maps and information
           annually (or more often!) to keep improving your
           operation on an ongoing basis.  Now that you have
          identified your most expensive wastes, you can now
            move towards solving problems and eliminating
              waste... the next tool is Root Cause Analysis!
                        15

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Table 1.  Activity-Based Costing Analysis (Per year)
Workstep
Costs/Losses
Labor
Raw
material
Disposal
fees
Other ledger
costs
Hidden
Costs
Total
%of Total

















































Total







                       16

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Table 2. Hidden Cost Analysis (per year)
Activities/Cost
Factors
Materials
Space
Utilities
Services
Labor
Waste Stream
Monitoring
Reporting
Repairs
Recycling
disposal
service
Spill clean-up
Storage
Record
keeping
Generator fees
































Total hidden costs for (waste stream)









Waste Stream
Monitoring
Reporting
Repairs
Recycling
disposal
service
Spill clean-up
Storage
Record
keeping
Generator fees
































Total hidden costs for (waste stream)









Waste Stream
Monitoring
Reporting
Repairs
Recycling
disposal
service
Spill clean-up
Storage
Record
keeping
Generator fees
































Total hidden costs for (waste stream)









                         17

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18

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         Tool #3: Root
         Cause Analysis
         Now that you have recognized the activities in your
         process that are costly or expensive to your business,
         you can begin to focus your efforts on pollution
         prevention. This tool presents a method of detecting
         the underlying reason for an environmental loss so
         that the loss can be prevented.
Warm-up Exercise
                Think of all of the times that you have been late for
                work and list the different reasons for your delay.
                Maybe your alarm clock did not go off, or perhaps
                your child was sick and you needed to arrange for a
                sitter. Did you spend too much time reading the
                newspaper or did you need to run to the store to pick
                up milk.

                Arrange all these reasons in the categories listed
                below, or create an additional category. Some of the
                items on your list may be entered more than once.
                Now consider the last time you were late for work.
                Why were you late? Circle the reason.
MACHINES
broken alarm clock
PEOPLE
sick child
METHODS
reading the newspaper
MATERIALS
out of milk
                       19

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Introduction

 In the last tool you determined the key losses responsible for the greatest
 amount of environmental costs. In order to try to prevent a loss, you must
 first understand why it is occurring. The underlying reason for a loss is
 also known as its "root cause". The root cause will answer the question:
 What ultimately caused the loss? Determining the root cause of an
 environmental loss is very similar to determining the root cause of being
 late for work

 A cause and effect diagram is one method of determining the root cause
 for a loss. This tool provides a visual description of all possible causes for
 a specific loss. Once all the possible causes are depicted on the diagram,
 the most plausible cause or causes are identified. It is imperative that all
 persons involved in determining the root cause are in agreement. The
 next step is to write a "Dear Abby" letter summarizing the cause or
 causes for a loss will ensure that all participants see the problem in the
 same way.

 During this exercise you will:

       •  Construct a cause and effect diagram with all potential causes
          for a loss.
       •  Discuss the most probable cause or causes.
       •  Write a Dear Abby letter describing the reason for the loss.
Root Cause Analysis

After participating in process mapping and activity based costing
exercises, it was determined that the largest loss, investment materials,
accounts for approximately 80% of all environmental costs in the jewelry
manufacturing operation. The next step is to discover the root cause of this
loss.

To determine the root cause of a loss, you must ask, "Why is the loss
occurring?" One way of gathering information concerning the generation
of a loss is  called a cause and effect diagram, or fish bone diagram, since it
resembles a fish bone. Major categories of possible causes for the loss are
first defined and entered on the diagram as an offshoot from a main
horizontal line. Next, all possible causes of the waste are assigned to a
category and entered on the diagram. Once all the causes are defined, an
agreement is made as to the most plausible reason for the loss.
                          20

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             Divide the causes into four major categories - Methods, Machines,
             Materials, and People - and then write down all the possible reasons why
             investment materials could be lost from the process and assign them to a
             category. Begin the diagram and then write down some of the things that
             immediately come to mind.  An example has been provided in Figure 2.

             Several things may come to mind. Investment is used for each piece of
             jewelry that is processed.  People may not fully utilize the wax trees and
             less jewelry is made per flask and investment materials.  Spills may occur
             often. Investment may not be mixed right and could cause failure. Also
             people operating the various mold and jewelry making processes are
             critical and training and a good work attitude are critical to efficient
             operations.  All of these ideas should be entered under one of the four
             categories in the fishbone diagram: Machines, Methods, Materials and
             People as in the example in Figure 2.

             Now that all the possible causes investment  being lost during the jewelry
             manufacturing process are categorized, it is time to determine the most
             probable cause. Go back to the diagram and circle the most probable
             causes. One of these should be the root cause.  Then, working with
             employees as a team, discuss which one of these major causes is the root
             cause. To come to clear understanding of the root cause, we suggest that
             the team write a short "Dear Abby" letter describing his or her
             interpretation of the problem to ensure that each person sees the problem
             the same way. Once the letter is in place, the group becomes Abby and
             seeks to  solve the problem, (see Figure 3)

             Another method for determining the root cause of a problem is the "5
             whys".

             By asking the question "why?" five times, you may get to the root cause
             of a problem.  An example of how the five whys works is as follows.
The Five Whys:

  1.    Why has the machine stopped forcing an interruption in production?
       A circuit breaker tripped due to an overload.
  2.    Why was there an overload?
       There was not enough lubrication for the bearings.
  3.    Why was there too little lubrication for the bearings?
       The pump was not pumping enough lubrication.
  4.    Why was there not enough lubricant being pumped?
       The pump shaft was vibrating because of abrasion
  5.    Why was there abrasion?
       There was no filter, which allowed chips of metal to get into the pump.

  The solution is then to place a filter on the pump to capture metal chips.
                                       21

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Both tools can be used to find the root cause of the problem. For most
problems to be permanently solved the root cause must be addressed. The
fishbone diagram is a good visual tool that helps you understand all the
areas that contribute to a problem. Understanding all the contributing
factors will help facilitate problem solving.  The Five Whys will also help
you move past dealing with the symptoms of the problem to solving the
real problem.

Examples of the fishbone diagram and  a Dear Abby letter are included as
well as a blank fishbone diagram for your use.
           The next tool will present brainwriting - a
                 method to generate ideas.
                         22

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Figure 1: Jewelry manufacturing Process - Process Map
                        Process Map 3.0: Jewelry Finishing

Water
Energy

Waler Jewelry PPE
\


1
f T '
3.1
Acid
Pickle
, I -
r i



r
Waste Acid Pickle sludge Energy '
Grind
Pads
-1,
Med a
Je
PPE

' 1
3.2

F 1

Deb urring/G rind ing/
Handfinishing

r ^


(metal, copper, silver) Waste Energy
Water


1
ceramic, she
Water
Soap
Energy

p 1




r v i


r 1
3.3
Tumbling

r
Waste ^
Metal Tumblin
1
Waste
Water
9 Slu

1
Is, plastic)


r




r
r Energy
Ige
Media
neral Spirits


'





J 1
Deonizedwater Mineral Spirits


r ,
3.4
Clean n(

r \

r

C
r '


\
oth
r 1

^


Mineral
Sp rits


r 1
Sulfur


r


1
Ener
Cl
. '
3.5
Jewelry
Treatment

' \

r
Used Cloth/ Wastewater Sulfur Waste Mineral
Clean ng
Supp es
Spi

its


\
lh PPE Solder
r v v v
3.6


f
r Solder
Used Cloth


                         23

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Figure 2: Cause and Effect Diagram
             Root Cause Analysis for Investment Use
               M ethods
 configuration
causes frequent
    spills
       Loading wax trees

          Job type
     Not
   reuseable

 Investment
                                           People
                                                        don't understand
                                                        waste problems
                           24

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Figure 3: Dear Abby Letter
 Dear Abby,

 We run a small jewelry manufacturing operation.  Investment use and
 disposal is our most expensive business issue.  We use lots of investment
 materials that must be managed as a solid waste. That means that lots of
 materials must be thrown in the dumpster.  Our solid waste fees are
 outrageous and it seems bad to be sending so much material to the
 landfill.  These are issues that we wish to take  seriously.

 Our root cause analysis revealed that the root cause of investment use is
 how we load wax trees in the flasks. Much investment is lost through
 defects,  damaged trees and under-utilized flask use.  Also, employees
 tend to create lots of spills and reject materials due to poor investment
 mixing and flask filling.

 Can you help us?
 Signed,

 Invested in Albuquerque
                          25

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            Figure 4.  Root cause analysis: Fishbone Diagram
      Methods
     Machines
Materials
People
                                 26

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          Tool #4: Brainwriting
                   To address an opportunity effectively, it is important
                   to recognize all alternatives. Very rarely is there one
                   "right" way of preventing pollution. Instead, there
                   are many different potential solutions. This tutorial
                   presents a technique of listing many different
                   alternatives for an opportunity.
          Warm-up Exercise
   \\
^ V
You know the old adage "two heads are
better than one". This is especially true
when trying to come up with new ideas.
When you generate ideas in a group you
will notice that each member of the
group brings their unique set of
experiences and strengths to the table.
                   Try the following exercise with your group. Look at the picture
                   below (turn it on it's side and upside-down). What does it
                   remind you of? Write down all the images that come to mind-
                   even images that seem crazy should be included. Now go
                   around the room, each per son sharing one image with the
                   group. One person should volunteer to keep a list of all the
                   images. Repeat this step until every member of the group is out
                   of images. How many images did the group come up with?
                   How does this compare with the number of images you
                   generated alone ?
                                 27

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Introduction

In the last tool you evaluated all the probable causes of a loss and
determined the underlying reason, or root cause. Once the root cause has
been identified, you may be tempted to jump to a premature solution.
When you address a loss without considering all the alternatives of
prevention you may be overlooking the most appropriate option(s).

Looking for alternatives for pollution prevention by addressing its root
cause is the next step towards addressing an opportunity. There are several
tools available to help groups develop alternatives. You already explored
one tool during the warm-up exercise. In this exercise you will explore
another method-brainwriting. Brainwriting requires maximum  interaction
and creativity between group members. The group should consider all
possible alternatives, regardless of how far-fetched they appear to be.
Alternatives raised by the group may  seem contradictory, or they may
build on one another making them better. A comprehensive list of
alternatives can then be compiled.

During this exercise you will:

       •  Conduct a brainwriting session.
       •  Develop a list of all possible alternatives for an opportunity for
          improvement.
Brainwriting

 First you have completed your process map to see how you can optimize
 your processes and reduce losses, (see Figure 1) In the example provided,
 Activity-Based Costing helped to identify that 80% of the environmental
 costs associated with jewelry manufacturing was due to investment use.
 Not only is investment  expensive, it is critical to the process and we use
 large quantities of this material on a daily basis.

 Root cause analysis determined that the greatest losses occurred due to
 employee handling practices.  Employees control the jewelry
 manufacturing processes from the beginning to the end and also must
 deal with environmental, health and safety compliance issues.

 The next step is to develop as many alternatives to solve the problem as
 possible. This is done through the process of brainwriting. Through
 brainwriting, staff works together to generate as many alternatives as
 possible regardless of how crazy they seem. In fact, to make it more
                          28

-------
interesting you can give a prize to the person that comes up with the
craziest idea.

Make copies of the blank brainwriting sheet included at the end of this
chapter. Make enough sheets so that each person on the brainwriting
team has one per person with one blank sheet in the middle of the table.
Place these sheets  in the center of the table. Each person should take a
sheet and write two alternatives on it and then place the sheet back in the
center. Then take another sheet of paper and write two more alternatives
on it. Every time someone picks up a sheet of paper, encourage them to
read what others have written and try to make improvements to the
alternatives listed.  Someone could even say they think someone's idea is
completely out in left field, if they try to make it better. Keep repeating
this process until everyone runs out of ideas.

Now list all the alternatives that were discovered.

The alternatives on each sheet of paper should be read aloud and
discussed.  Many of the ideas may be the same and some may have small
variations. The group should debate the small variations and eliminated
the impossible alternatives. One comprehensive list should be developed-
each idea only written once, although all variations of the same idea
should be included.
            Examples of brainwriting are provided below.
             The next tool will present 'bubble-up-bubble-
           down"...a method for selecting the best option to
                              prevent loss.
                         29

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Figure 1: Jewelry manufacturing Process Map
                 Process Map 3.0: Jewelry Finishing

Water
Energy


Water Jewelry PPE
1


1
Waste Acid Pic
T '
3.1
Acid
Pickle
, 1 1
' \



r
We sludge Energy '

Grind
Pads
,1,

Media
Je

PPE

' \
3.2

' \

Deburring/Grinding/
Handfinishing

' '

r
(metal, copper, silver) Waste Energy
Water


\
ceramic, she
Water

Energyboap

r '




' V 1



f !
3.3
Tumbling

r
Waste i
Metal Tumblir
1
Waste
Water
' 1
9 Slu

\
Is, plastic)



'




r
, Energy
dge
Media
Spirits
r l
De on
' i
zedwater Minerals
Cloth

3.4
Cleaning

f 1
i
r 1

r
Mineral
r Spirits '
pirits
r l
Sulf
r ,
r
Cl
r 1
3.5 '
Jewelry
Treatment

r i

r i
Ener
>th ppE Solder
r v v v
3.6


V
Solder
Used Cloth/  Wastewater
 Cleaning
 Supplies
Sulfur Waste Mineral  Used Cloth
        Spirits
                  30

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           Figure 2: Sample of brainwriting
 1.
Look for reusable investment to
eliminate all environmental problems.
2.
Find a market for waste investment.
 3.
 Set up work area more efficiently to
 reduce carry distances for flasks to
 save time and prevent dropping, etc.
4.
Develop alternative flask design that
uses less investment.
5.
Start a "clean shop" program to train
employees to keep work areas clean to
prevent spills and waste.
6.
Begin an employee incentive program
to reward development of best
operating practices that reduce loss
from rejects and excessive investment
use.
7.
Utilize flasks more effectively to get as
much jewelry as possible per flask.
9.
8.
Develop Standard Operating Practices
for mixing investment to prevent rejects
and failure.
10.
                                  31

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 Figure 3: List of alternatives

1.  Look for reusable investment to eliminate all environmental
   problems.

2.  Find a market for waste investment.

3.   Set up work area more efficiently to reduce carry distances
   for flasks to save time and prevent dropping, etc.

4.  Develop alternative flask design that uses less investment.

5.  Start a "clean shop" program to train employees to keep
   work areas clean to prevent spills and waste.

6.  Begin an employee incentive program to reward
   development of best operating practices that reduce loss
   from rejects and excessive investment use.

7.  Utilize flasks more effectively to get as much jewelry as
   possible per flask.

8.  Develop Standard Operating Practices for mixing
   investment to prevent rejects and failure.
                       32

-------
Figure 4: Brainwriting Sheet
                              8.
                              10.
                         33

-------

-------
Tool #5: Bubble Up-Bubble
Down
         You have now generated a list of alternatives for preventing
         an environmental loss in your business. But how do you
         choose the best alternative? This tutorial presents one
         method of prioritizing alternatives to ensure that the most
         appropriate alternative is selected.
Warm-up Exercise
         important things get done.
                              Most of us use lists from time to time to
                              make sure that we don't forget to do the
                              things that we need to get done. Without a
                              shopping list, for example, we may return
                              from the store without milk, the reason
                              why we went in the first place. Certain
                              limitations, like time or money, may cause
                              us to drop things off our list. We often need
                              to prioritize and make sure that the most
         Make a list of the things that you need to get done tomorrow (try to list
         at least ten things). List these items in the order that they come to
         mind. Now prioritize this list by putting the most important items on
         the top of the list and the least important items on the bottom. You
         should now have a "rank ordered" list. If you only have time to
         complete one of the items on your list, which would it be? You should
         have answered the item on the top of the list the most important item.
                          35

-------
Introduction

A comprehensive list of pollution prevention alternatives was developed in the
last tool using a technique called brainwriting. The alternatives generated during
this tutorial can range from operational changes, such as employee training and
improvements in operations, to technology changes, such as changing a solvent.
The next step is to choose one alternative that is capable of being worked with
successfully. Additionally, it is important to select the optimal solution for your
business. To accomplish this, you must consider the feasibility of each alternative.
Such factors as effectiveness, implementability, cost, and potential ramifications
of each alternative should be discussed. Personal preferences and biased
information should not enter into the decision-making process.

There are several tools available to aid a group in selecting an alternative and
avoid bias. These tools allow a group to rank and prioritize alternatives using a
systematic approach. When all the alternatives are listed, suggestions are made by
the group to improve even the worst alternatives. At this point, many of the
alternatives may be eliminated: every realistic alternative remains on the list.
These remaining alternatives can then be sorted based on the factors presented
above and any other factors that may effect a particular business. The method of
selection presented in the exercise is the bubble-up-bubble-down. This tool uses a
forced pair comparison to rank alternatives. Using this method you will  be able to
find the most effective solution to the selected loss.

During this exercise you will:

       •  Evaluate all alternatives.
       •  Use the bubble-up-bubble-down method to reach a decision on the best
          alternative.
Bubble-Up, Bubble-Down

Take the list of alternatives and compare the first two alternatives. Decide which
of the two is the best and move this alternative to the top of the list. Go to the
next, or third alternative and compare it to the second. If it is better than the
second, move it up and compare it to the first, if not, leave it in the third position.
Continue this process until all the alternatives are rank ordered. This process
should go fairly quickly.  Make sure you listen to everyone's opinions and
objections. Again, factors to consider are cost, effectiveness and the ability to
implement the alternative.

Bubble-up, Bubble-down should generate much discussion among employees on
the best solutions.  These discussions will help to increase buy-in to the
alternatives. As a rule, employees never resist their own ideas.

-------
An example of how the Bubble-Up Bubble-Down method was applied to the list
of alternatives generated in the last tool are listed below.
                             37

-------
Typically, the three or four alternatives that "bubbled-up" to the top of the list are
the easiest and cheapest to implement, the "low-hanging fruit". The alternatives
in the middle may require more research or study to see if they are feasible.  The
ideas at the bottom of the list may require major equipment changes or capital
investments. It is important to keep the entire list on file as part of your
continuous environmental improvement program.
               The next step is to develop an action plan.  Action
          planning is essential to assure that ideas are implemented!

-------
 Figure 2: List of alternatives, prioritized through Bubble-Up, Bubble-
Down
1.  Begin an employee incentive program to reward development of
   best operating practices that reduce loss from rejects and excessive
   investment use.

2.  Utilize flasks more effectively to get as much jewelry as possible
   per flask.

3.  Start a "clean shop" program to train employees to keep work
   areas clean to prevent spills and waste.

4.  Develop Standard Operating Practices for mixing investment to
   prevent rejects and failure.

5.  Set up work area more efficiently to reduce carry distances for
   flasks to save time and prevent dropping, etc.

6.  Develop alternative flask design that uses less investment.

7.  Find a market for waste investment.

8.  Look for reusable investment to eliminate all environmental
   problems.
                         39

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Tool #6: Action Planning
         Being able to successfully manage a project is important
         when trying to accomplish a task, especially when you are
         under a deadline. You need to set up a schedule, ensure that
         you have the necessary resources, and assign the right
         person to each part of the job. In this tutorial you will create
         an "action plan" for the implementation of an alternative to
         prevent pollution.
Warm-up Exercise
                                      Your group has been assigned the
                                      task of making chocolate chip
                                      cookies. The cookies need to be
                                      ready in one hour and the cooking
                                      time is twelve minutes. Pick a
                                      person to manage this project. The
                                      manager must then assign the ten
                                      tasks listed below to individuals in
         the group.
         You will need to know how much time is required for each task, what
         tasks need to be accomplished before others, what resources (i.e.
         bowls, flour etc.) are required, and what the most efficient way of
         organizing these tasks (and remember the clock is ticking). Create a
         schedule.
         Making chocolate-chip cookies:

            Mix dry ingredients
            Mix wet ingredients
            Put the batter on the pan and put pan into the oven
            Combining wet and dry ingredients
            Turn on the oven
            Taste cookies
            Wash tools and utensils
            Grease pan
            Take cookies out of the oven

-------
Developing an Action Plan

Before you begin to implement your alternative you should complete this
questionnaire. It will ensure that you are being thorough in your planning and
have considered all the important issues that may arise such as the resources that
are needed and the problems that may occur, (see Figure 2)

Things to consider in developing an action plan are resources needed, both
financial and human resources; the need for pilot testing or bench scale testing;
information sources from he outside such as trade  associations, vendors and
suppliers and the Environment Department. Other issues such as employee
support and maintaining product or service quality should be  considered.  A list of
questions that should be considered during action planning is as follows:
Action Planning Questionnaire

       1.  What is the overall objective and ideal situation?
       2.  What steps are needed to get there from here?
       3.  What actions need to be done?
       4.  Who will be responsible for each action?
       5.  What is the best sequence of action?
       6.  How long will each step take and when should it be done?
       7.  How can we be sure that earlier steps will be done in time for later
          steps that depend on them?
       8.  What training is required to ensure that all staff have sufficient know-
          how to execute each step in the plan?
       9.  What standards do you want to set?
       10. What volume or quality is desirable?
       11. What resources are needed and how will you get them?
       12. How will you measure  results?
       13. How will you follow up each step  and who will do it?
       14. What checkpoints and milestones should be established?
       15. What are the  make/break vital steps and how can you ensure they
          succeed?
       16. What could go wrong and how will you get around it?
       17. Who will this plan affect and how  will it affect them?
       18. How can the  plan be adjusted without jeopardizing its results for the
          best response and impact?
       19. How will you communicate the plant to generate support?

  Now put all this information in an Action Plan Form. Most of the information
  you need should come from your answers to the questionnaire. The specific
  task, or step, to be accomplished is written in the first column under "Action."
  In the following column list the person who is responsible for completing this

                              41

-------
  task. A performance standard should then be provided. This standard is a way of
  establishing how well a task needs to be performed. Under "monitoring
  technique" enter a measurable goal or target used to track the plan's
  implementation. A firm deadline should then be set, and finally, indicate the
  resources that are needed to perform each task. This form will help you organize
  your thoughts, keep track of all the actions that need to be completed, and
  ensure that the proper quality is being maintained.

  Use the form provided to track implementation of the project and to measure its
  success. A sample action planning form is included at the end of this section.
Overall Target: Employee Incentive Program
Action
1. Develop
Program
incentives
2.Design a
program for
review and
giving
incentives
3. Meet with
employees
4. Set up
improvement/su
ggestion box,
system
5. Review Team
6. Incentives
awarded
Responsible
person
Carol
Marcy
Carol, Mark and
Marge
Carol
Carol and Mark
Marge
Performance
standard
List of incentives
Approved
program by
Marge
Highly interactive
meeting
System in place,
all employees are
aware, easy to use
Review team
reviews
suggestions
monthly
Ideas
implemented,
paying off in $$,
improvements
Monitoring
technique
Discuss ideas
with Marge the
owner
Marge
approves,
allocates
funding.
Question
employees
before and after
Number of ideas
submitted
Marge evaluates
work
Check on
progress,
success
Completion
deadline
Jan 15
Feb 1
Feb 15
March 1
March 7
Junel
Resources
needed
Team of Carol
and Mark
Action #1
complete
Firm date for
meeting;
meeting room
Box, access to
company
computer,
review team
Ideas
accepted/imple
mented
Cash bonuses,
days off, etc
Congratulations!!! You have completed the Pollution Prevention Training. Now it
is time to put these tools to work and remember pollution prevention is an
ongoing process. If you continue to implement pollution prevention in your
business, you will increase the efficiency of your process while helping the
environment. Simply revisiting your process maps and Pareto Chart once a year
and using the tools to continue to make improvements will make a big difference
in your operation. Ongoing use of these tools will help you to participate in the
Green Zia Environmental Excellence Program.

-------
Here are a few suggestions to make pollution prevention continue to
work for you:
   •  Return to the Nothing to Waste activities and concepts as you make
      environmental improvement decisions.

   •  Schedule regular pollution prevention reviews of your business.
Remember: Pollution Prevention saves resources, saves money, and
prevents accidents!
                                     43

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Overall Target
Action
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Responsible
person










Performance
Standard










Monitoring
Technique










Completion
Deadline










Resources
Needed











-------
45

-------
Process Maps for Jewelry
Manufacturing

-------
General Overview Map of Jewelry Manufacturing
1
Design


2
Casting


3
Jewelry Finishing


   4
 Shipping
   &
 Packaging

-------
        Process Map 1.0  Design
Wax
            Energy
                      Rubber
                              Sprues
                                         Wax
I




1
1

Wax
P iece
Design
J
r


^

r ^

.2
Rubber
MolH

1

_,_. 	 WWC1A
r v v
1.3
Gate
^ ^ ^
Sprues
r~ i i
Used Wax Rubber Sprues Wax
Mold

Ene
\


	 ^.
^^

1
PP
gy Wax
r v
1

PP
i
.4
Release
E S
f \

Wax
Mold
Production

r

1
|\

^


' 1
Dray W
r ^






Wax

ax
r
.5

Tree
Production
1




1
r Used Wax


r Energy Wax
old


release
Spray
(VOC's)

-------
Process map 1.0: Jewelry Design


1.1   Wax Piece Design
      During this process, employees design the wax pieces that will be used for molds
later. This process generates used wax waste.

1.2   Gates and Sprues
      Employees design gates and sprues for future casting. During this process, proper
design allows casting metals to move smoothly into casting forms.  This process requires
the usage of sprues and wax. The wastes generated are used sprues and wax.

1.3   Wax Mold Production
      During this process, employees mold the wax to establish the shape for the future
jewelry pieces.  This process requires the use of energy, PPE and mold release spray. The
waste generated during this process is used PPE, mold release spray (may contain VOCs),
energy and wax.

1.4   Create  Rubber Mold
      Employees prepare rubber molds from the wax pieces that have been prepared.
There are many types of molding compounds. These compounds range from standard
natural latex to vulcanizable rubbers to the room temperature vulcanizing silicones. This
process uses energy and rubber. Waste rubber molds are generated in this process.

1.5   Wax Tree Production
      The wax trees are produced to mount future jewelry pieces onto the tree for further
processing.

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Process Map 2.0: Casting
2.1
Dewaxing
^

2. .2
Casting
^

2.3
Devestments

-------
         Process Map 2.1:  Cast Preparation
Flasks
      Wax Trees
   Energy
  2.1.4

Bake Flasks
                        Water
                                Investment
                                                 Energy
                                                          Steam
                                                         Water
                                                            Burning Wax
                                                              Vapors
Heat Loss/Gain

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Process Map 2.1: Cast Preparation
2.1.1  Place Wax Trees in Flasks

      Employees prepare the casting. The wax trees are put into flasks. Wastes generated
include broken trees and rejects.

2.1.2  Pour Investment

      Investment is poured in the flasks to create cast.  Investment is mixed with water to
the proper consistency and is poured into flasks over wax trees. This process requires
investment and flasks/casts. Waste materials may include spilled investment or damaged
molds.

2.1.3  Dewaxing

      During this process, wax is removed from the flasks by heat or steam. Typically
steam is used. The waste generated during this process is energy, water, and wax vapors.

2.1.4  Bake Flasks

      Flasks are baked overnight at high temperatures.  This uses a significant amount of
energy.

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             Process  Map 2.2: Casting
Additives    Metal    Energy   Energy
                                   Metals
\


\
' V 1
2.2.1
MeltMetal
, I
Heat Loss/Gain PPE }
r \



\
f \
r
2.2.2
Pour
Metal into Flasks
r
' Spillage
\
\



2.2.3
FlaskSet-Up
r
PPE
r
             Metal Residuals    Heat Loss/Gain

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Process Map 2.2:   Casting


2.2.1  Melt Metal

      Metal is melted to pour into flasks. Crucibles are used to heat the metal. The
crucibles are heated gradually. This process requires energy, crucibles, tongs, shanks,
metals, and flasks. The wastes generated are spillage, energy and used PPE. Worker
health and safety issues are important in handling heated materials. Wastes generated are
energy, air emissions, spilled metals, and PPE.

2.2.2  Pour Metal  into Flasks

      During this process, employees pour molten metal into flasks or casts using a ladle
or a crane if it is a large operation. This process requires energy, metal, flasks, shanks, and
a ladle or crane. Again safety issues are very important in handling heated materials.  The
wastes generated are spillage, energy and used PPE.

2.2.3  Flask Set-Up

   Flasks are set-up  to allow metal to solidify.

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  Process Map 2.3 (W): Wet  Devestment
                 PPE
          Water
       Waste Devestment
       Water  Sludge
                             PPE
                  i             i

                 i           I
             Cleaning
             Solutions
2.3.1
Flasks Dumped
into Water
I I I

r i
2.3.2
Surface Cleaning
r
]
Devestment
 Sludge
      Waterwater/
     Waste Cleaning
       Solutions
PPE
Process Map 2.3 (D):  Dry Devestment
PPE

I

i
2.3.1B
Clean Flask

r
Damaged
Jewelry

1
\i
Cleaning
Water Solutions
1 1


i, 1
Damaged
Devestment Jewe|ry
waste
r
Damaged
Flasks

\

r

Waterwater/






Waste Cleaning
Solutions


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Management of Devestment Waste 2.3 A
         Waste
         Water
     Waste
     Pickle
              Treatment
             of Devestment
         f
       Holding Tank
                     OR
        Sludge
    Dried out, mixed
with concrete, pooned into
blocks and landfilled (BM)
                 Put Wet
          Sludge in Lined/Plastic
              Box & Landfill

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Process Map 2.3: Devestment


2.3 Devestment is the process of removing the casting investment from the casting flask
and tree. Two methods are generally used 1) Wet devestment; and 2) dry devestment. Wet
processes use water to break apart the investment while dry processes use a flask-
stripping device to push and shake the investment out of the flask and off the tree.

2.3.1 (W) Wet Devestment

      Employees place the flasks into a sink full  of water so they can soften the casts and
break off the investment.  Employees use a high-pressure hose to clean off residual
investment. This process generates used PPE, water, energy, and investment sludge
waste.

2.3.1 (D) Dry Devestment

      The casting tree and investment from the flask are pushed and shaken out of the
flask and off the tree without the need for water. The castings are not as clean and  may
require additional cleaning using water, mineral spirits, or acid pickle. The wastes
generated are dry investment, potential for damaged jewelry, energy and used PPE.

2.3 A Management of Devestment Waste

      Devestment wastes are settled out of the used water by using holding tanks  with
baffles. The devestment sludge is taken out of the settling tanks, dried, put into lined
cardboard boxes, then put into a dumpster. Another option is to dry the sludge, mix with
Quickcrete, put into lined  cardboard boxes and dispose at the local landfill.  Alternatives for
disposal have been investigated through  New Mexico State University. One potential reuse
is finger dust for rock climbing.

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Process Map 3.0: Jewelry Finishing

Water
Energy

Water Jewelry PPE
l


i
, 1 ,
3.1
Acid
Pickle
, I ,
' 1



'
Waste Acid Pickle sludge Energy '
Grind
Pads
r f i
Media
Je
PPE

f \
3.2

' 1

Deburring/Grinding/
Handfinishing

r \

r
(metal, copper, silver) Waste Energy
Water


\
(ceramic, she
Water
EnergySoaP

j 1

	 ^.


r v ,


p 1
3.3
Tumbling

f
Waste \
Metal Tumbli
!
Waste
, Water
* 1
9 Slu

1
Is, plastic)


r

^


r
, Energy
Jge
Media
Mineral Spirits


i



f 1
Deionizedwater Mineral sPirits


r
3.4


1


C
r '

Cleaning



f 1
Used Cloth/ w
Clean ng
Supplies

r
1
oth
r 1

	 ^>

r
Mineral
Sp rits


r 1
Sulfur


r


1
Ener
Clc
r '
3.5
Jewelry
Treatment

' 1

r
astewater Sulfur Waste Mineral

1
th pp^ Solder
r
3.6
	 ^. Solder Parts

v
' Solder
Used Cloth
Spirits





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Process Map 3.1A: Management of Ac id Pickle Waste
             Waste
             Water
                    Energy
                        Waste Pickle
                    3.1A
                  Treatmentof
                Pickle PlaterWaste
           Recycle
            Used
            Pickle
            Platter
                  Or
                          Or
Evaporate
         Pour
        Down
        Drain
              Replenish
              and Reuse
   Process Map 3.3 A:  Management of Tumbling Waste Water
                       Waste  Sludge
                       Water (LowMetal)  Soap
                              3.3A
                          Treat Tumbling
                             Waste
                             Water
                            Settle in one
                          or more tanks with
                        baffles (baffle optional)

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Process Map 3.0 Jewelry Finishing
3.1 Acid Pickle

      The jewelry is placed into a heated acid pickle solution to remove oxides of copper
and zinc. This process generates used acid pickle and energy and produces an acid pickle
waste.

3.2 Deburring/Hand Finishing/Grinding

      During this stage, employees remove casting tree spurs or additional casting metals
from the castings. Employees grind off residual metals from the castings using a grinding
wheel and an abrasive pad. While some deburring can be achieved in a mass finishing
operation, hand deburring is common. Most of the metal from a deburring operation is
recoverable either through settling tanks, filtration, or a combination in the recovery
process. The waste generated during this process is PPE, energy, and grinding pads.

3.3Tumbling

      Jewelry pieces are put into a tumbler along with water, soap and media, (media is
either ceramic, steel shot, or natural; ground corncobs, walnut shells, etc.) The jewelry
pieces are tumbled with the media and soap in order to shine and clean the pieces. This
process generates wastewater, sludge, and energy.

3.4Cleaning

      Mineral spirits and other alcohol-based cleaners are sued  as a final product rinse.
They can be replaced by deionized water. The wastes from this process include q-tips,
cloth, mineral spirits or other cleaning solutions.

3.5.   Antiquing

      In some cases, an antiquing process is used to give some jewelry pieces an antique
finish. The waste material from  this process is used mineral spirits, hand cloths, used PPE.

3.6    Soldering

      Soldering can be divided into hand solder (silver or gold solder) or brazing with a
filler metal. Silver solder is used for solder joints. This process uses a solder gun, PPE,
energy, solder, tips and flux. The waste generated from this stage is a small amount of flux
and fumes.

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3.1 (A)   Management of Acid Pickle Waste

3.1.1  Option 1: Treatment of Acid Pickle with Pickle Plater

      The acid pickle can be reclaimed using the pickle plater. The plater is used to
remove the metals from the acidic solution. Once the copper is plated out from the waste
acid pickle the acid pickle can be reused again. The copper may be resold.

3.1.1 Option 2: Treatment of Acid Pickle by Evaporation

      This is an option for small businesses.  Acid pickle is evaporated. The dried sludge
must be tested using the TCLP method.  If testing determines that it is not hazardous, it
may be landfilled.  If the testing determines that the waste is hazardous, it must be
disposed of as hazardous waste.

3.1.1 Option 3: Acid Pickle  is continually replenished.

      As the acid pickle evaporates, more solution is added to the heated pot and it is
used continually.  This may reduce the effectiveness of the pickle solution over time.

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     Process Map 4.0: Packaging and Shipping
               Bubble
               Wrap
           Tape   Paper  Bubble
                      Wrap
Process Map 4.0: Packaging and Shipping

4.1    Packaging

      Jewelry is packaged for shipping. Materials include boxes, invoices, paper, special
      packing materials, labels and tape.

4.2    Shipping

      Packages are shipped using appropriate service.

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Regulatory Guidance Materials
and Pollution Prevention Tips

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City of Albuquerque P2 Program:
                     Red^^
           Areas of opportunity for reducing toxic discharges to the sanitary sewer system
           include:
            1.   Before discharging any type ofwastewater to the sanitary sewer system call your local
                treatment plant, or the Industrial Pretreatment Program to find out if there are any
                restrictions.

            2.   Wastes that affect the treatment system include heavy metal wastes, chemicals that are
                listed as toxic or hazardous.

            3.   All facilities that have materials that are or could be considered hazardous should have a
                written spill prevention plan.

            4.   Training programs regarding proper handling of wastes and chemicals for operators and
                maintenance personnel are essential.

            5.   Records of how wastes are handled is another factor in making sure that you are meeting
                wastewater ordinance requirements.

            6.   Inspection and spill control plans are also required.

            7.   Proper maintenance and operation of your wastewater treatment system(s) are fundamental
                in insuring that your facility is meeting the local wastewater ordinance.

            8.   Ensuring that chemicals and wastes are not stored next to a floor drain, and are elevated
                and contained properly will guarantee that you are not in violation with your local
                wastewater ordinance.

            Cyanide Bombings Hidden Costs

            Cyanide bombing is an outdated process used to remove oxide materials from casting. The
            chemicals used in the bombing process makes this a dangerous operation with potentially
            dangerous consequences. Cyanide is a regulated hazardous material. Cyanide is highly
            toxic. If you are using cyanide to finish jewelry:

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1.    You will need to analyze the waste using the Toxicity Characteristic Leaching Process in
     order to determine if there are hazardous metals present.

2.    You will need to perform full cyanide oxidation or destruction

3.    Most likely the waste will be hazardous and will have to be treated and shipped as
     hazardous waste.

4.    Because cyanide is highly toxic it will need to be stored properly and employees must use full
     Personal Protective Equipment.

Reusing Acid Pickle

Acid Pickle, when used to clean sterling silver and copper alloys, will contain a large
amount of copper. Copper is not hazardous, but could cause major problems for sewer
treatment facilities. Also,  due to their corrosiveness acid  pickles are hazardous wastes. The
primary reason not to discharge acid pickles is that they  can be continuously reused and
the copper can be removed for recycling. The primary method for reuse and recycling is to
use an Acid Pickle Plater. The plater, plates  out the metals from the acidic solution. Once
the copper is removed the acid pickle can be reused. Please call the  City of
Albuquerque's p2 Program at (505)873-7058 for specifications for building and using
the pickle plater.
Why Do I Need A Spill Prevention Plan?

It is required that any business handling materials that are or may be considered
hazardous to have a Hazardous Material Emergency Response Plan (HMERP) in case
of spills. The HMERP should be filed with your local fire department. By preparing and
filing your Spill Prevention Plan with your local Fire Department you will be fulfilling part
of the requirements under RCRA, as well as the requirements of your local treatment
plant.

Some General Spill Control Procedures Include:
1.   Isolating the spill area and limit entry.

2.   Tending to any injured or contaminated personnel

3.   Notifying the proper authorities

4.   If the spill is treated on site, dispose of the spill in accordance with federal state, and local
    regulations.

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Pollution Prevention Factsheet for the Jewelry Industry
Overview of Industry Waste Streams:


   Most of the pollution generated by both small and large jewelry manufacturers can be
categorized as either heavy metal (silver, zinc, nickel, copper, cadmium, etc.) wastes or
spent solvent wastes, some of which contain cyanide from stripping processes.  Much of
the heavy metal wastes and spent cyanide which is not recovered through filtration and
distillation methods, is discharged to wastewater treatment facilities where high
concentrations of these pollutants can cause malfunctions in the water treatment equipment,
leading to poor treated water quality and poor sludge quality (sludge is often reused
agricultural  or incineration processes).  Furthermore, many of these wastes pose serious
health hazards to workers and the general public if allowed to contaminate ground water
sources.  Improper disposal, leaks and spills, inadequate employee training, and process
inefficiencies can all increase the risk of adverse human and environmental exposure to
these toxic  substances.  Reducing this risk by solvent reuse and increased metal recovery,
is a cost effective means of increasing employee safety, while establishing a good public
relations base.   Though initial process alterations or equipment retrofitting may require a
limited capital investment, case studies have demonstrated great returns in the reduction of
regulatory disposal costs, water usage, and regular operational costs, especially raw
material procurement.
   The purpose of this factsheet is to provide information on the hazards associated with
particular pollutants commonly employed or produced by jewelry manufacturing processes,
while offering some guidelines and resources which can aid in the reduction or elimination  of
these materials.  Finally, several case studies will be outlined in order to demonstrate the
potential economic gains of pollution prevention  efforts as well as the ingenuity employed
toward this  goal. As much of jewelry industry is  focused on the artistic expressions of the
individual jeweler, the manufacturing processes  utilized throughout the industry are very
diverse.  For this reason, the creativity of the individual jeweler is often the key to effective
pollution prevention.
Specific Hazards Associated with Major Wastes:


   For a more comprehensive list of hazard descriptions, refer to the U.S. Environmental
Protection Agency web page, http://www.epa.gov .  By searching this page for jewelry
related articles, information on wastes, regulatory codes, and businesses currently being
investigated or cited by the EPA can be accessed.

Silver:  Most commonly found as a ground water contaminant, silver causes a condition
known as Agyria, a permanent blue-gray skin color, as well as causing irritation in the eyes
and mucous membranes which line the human digestive tract.   Effective water treatments to
remove silver are ion exchange systems, in which electrically charged plates are used to
attract the electrically charged silver, reverse osmosis, where a semi-permeable membrane
is used to filter the silver out of the water stream and distillation, where the water is
evaporated leaving the silver behind.

Cadmium:  Cadmium, which occurs naturally as an  impurity in various ores and was
historically used as a solder base, can cause nausea, vomiting,  muscle cramps,

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convulsions, and shock.   Chronic, or long term, exposure can cause kidney, liver, bone,
and blood damage.   According to 1986 figures (these being the most current available),
35% of the cadmium waste is a product of metal plating processes, while 5% is due to alloy
wastes.

1,1,1- Trichloroethane:  Known as both 111-TCE and 111-TCA, 1,1,1-trichloroethane is a
toxic halogenated hydrocarbon solvent, most commonly used as a general purpose cleaner.
The EPA has recently cited a number of jewelry manufacturing businesses for failure to
report the disposal of this RCRA hazardous waste.  Many effective alternative solvents are
available, for suggestions as well as specific toxicity information on 111-TCE refer to the
"General Solvent Factsheet".

Cyanide: Cyanide compounds that contain a complexed carbon-nitrogen functional group
(C^N) are highly toxic and regulated as hazardous wastes. When cyanides come in
contact with  acids, such as many cleaning solvents, hydrogen cyanide gas is emitted.  This
hardly detectable gas will very quickly kill anyone in the vacinity.  Cyanide compounds,
such as sodium cyanide, metal stripping agents, and electroplating chemicals, can be fairly
easily replaced by less harmful chemicals, which though not as convenient are much more
cost effective and safe.

Pollution Prevention Opportunities:


   For a step-by-step pollution prevention process review guideline and pertinent case
studies, refer to the "Jewelry Manufacturing Code of Practice Checklists" distributed by the
City of Albuquerque Pollution Prevention Program.  For a  copy, call the Pollution Prevention
Program Office at (505) 873-7004, or write to Pollution Prevention Program, 4201 Second
St. SW, Albuquerque, NM 87105.

Operational Assessment and Improvement:
   Many common pollution prevention techniques are simply the development and
identification of good operational procedures.  These often include the education and
training of employees who work around or with waste generating procedures, standardizing
all procedures, carefully labeling and  separating waste streams to eliminate cross-
contamination, and the evaluation of solvent usage.  Are cleaning processes completed
unnecessarily or too frequently?  Can the amount of solvent used be reduced? Can the
solvent or wastewater be reused, and if so how many times?  The answers to all of these
questions are dependent on the individual processes employed by the manufacturer.

   The next level of pollution prevention involves an analysis of the manufacturing
processes themselves.  Which steps  create the most costly waste streams?  Are there
suitable alternatives that lower or eliminate the level or toxicity of waste discharge? For
instance, several jewelry manufacturers have found that they can reduce waste water
disposal costs by reusing the solvents used in the acid pickling process or eliminating the
process altogether. Other facilities have increased dissolved metal reclamation by
experimenting with finer filtering apparatus or integrating electrolytic recovery systems which
separate the metal from a solvent by  creating an electric potential which attracts the
conductive metal ions.  These processes often have two fold economic returns, an increase
in reusable metal and a decrease  in costs of wastewater disposal.

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SPECIFIC REGULATORY GUIDANCE FOR JEWELRY MAKERS

         This briefing paper is intended to be attached to the "General Regulatory
         Guidance for New Mexico Small Businesses" to provide additional
         regulatory information specifically to "Jewelry Makers". It is not intended
         to be a substitute for actual regulations. If you have questions concerning
         your regulatory responsibilities, you are encouraged to contact the
         appropriate bureau.

         AIR EMISSION REGULATIONS:

         Jewelry manufacturers usually don't have air emission problems. The
         exceptions may be those facilities that also include a foundry or use
         materials that contain VOCs in large quantities. If in doubt about the air
         regulations, you can contact the NMED Small Business Assistance
         Program at 1-800-810-7227 or the City of Albuquerque Air Quality
         Assistance Program at 505-768-1964 if your business is located in
         Bernalillo County.

         HAZARDOUS WASTE REGULATIONS:

         Attached to this briefing paper is a document entitled "Fact Sheet for
         Jewelry Manufacturing Facilities" that can assist you in being compliant
         with Hazardous Waste Regulations.

         WASTEWATER REGULATIONS:

         The most potential problem for jewelry manufacturers is dealing with the
         rinse water. Since this wastewater can contain recoverable materials, it
         can easily be recycled. Be careful about putting your wastewater into the
         sewer system. Metals can play havoc with Publicly Owned Treatment
         Works (POTWs).

         OSHA REGULATIONS:

         Attached to this document is a checklist entitled "Jewelry Shops (A
         Hazard  Identification Checklist)" that  can assist you in being  compliant
         with OSHA.

         UNDERGROUND STORAGE TANK REGULATIONS:

         There is nothing unique about jewelry making that isn't already covered in
         the General Regulatory Guidelines.

         SOLID WASTE REGULATIONS:

         There is nothing unique about jewelry making that isn't already covered in
         the General Regulatory Guidelines.

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          GENERAL REGULATORY GUIDANCE FOR NEW MEXICO SMALL
BUSINESSES
         The purpose of this briefing paper is to assist small businesses in New
         Mexico in trying to understand the environmental regulatory requirements
         associated with doing business by giving a general overview. It is not
         intended to be a substitute for actual regulations. Businesses are
         responsible for operating their business in full compliance of the law
         (regulations).  Each bureau in the New Mexico Environment Department
         (NMED) have staff available that can help you directly in understanding
         what is expected of your business from a regulatory point of view. It is in
         your best interest to contact the appropriate bureau if you have questions.

         Periodically the Pollution Prevention (P2) Program in NMED will issue
         specific guidance briefing papers as an attachment to this document for
         certain businesses. These will be designed to provide additional
         information to a specific business. For information call the NMED
         Pollution Prevention Program staff at 505-827-0677 or the Technical
         Resource Center in Albuquerque at 505-843-4251.
         AIR EMISSION REGULATIONS:

         The EPA, in an attempt to control air pollution through regulations, has
         created a set of rules with many acronyms. Since businesses can come
         across these acronyms in many publications, they are listed below:

         NESHAP: National Emission Standards for Hazardous Air Pollutants
         NAAQS:  National Ambient Air Quality Standards
         HAP:     Hazardous Air Pollutants
         TAP:      Toxic Air Pollutants
         OEL:      Occupational Exposure Limits
         VOC:     Volatile Organic Compounds
         MSDS:    Material Safety Data Sheet
         CTG:     Control Techniques Guidelines
         MACT:    Maximum Achievable Control Technology
         BACT:    Best Available Control Technology
         GACT:    Generally Available Control Technology
         RACT:    Reasonably Available Control Technology

         Much of the national strategy for controlling air pollution centers around
         the NAAQS. These standards set limits for the concentration in the
         ambient (outdoor) air of the six most common air pollutants: Ozone,
         Carbon Monoxide, Particulate Matter, Sulfur Dioxide, Nitrogen Dioxide,
         and Lead.

         The EPA has established industry based regulatory requirements for the
         most serious air pollutants,  such as HAPs. In many cases the EPA has
         also established Control Techniques Guidelines that require industries to
         use certain technologies, such as MACTs.

         Any business that has the potential  of releasing pollutants to the ambient
         (outdoor) air, such as VOCs, HAPs, or Criteria Pollutants may be subject

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to the Air Quality Regulations depending on the amount of pollutants
being released. These pollutants are used to determine if a facility is a
major or minor source of air pollution and whether or not a business will
need an Air Quality Permit. A major source is determined as a function of
the amount of HAPs or Criteria Pollutants a business has the potential to
emit. For HAPs it is 10 tons per year of any single HAP or 25 tons per
year of the total HAPs. For the Criteria Pollutant it is 100 tons per year of
any criteria pollutant. In addition the State of New Mexico has added
TAPs as a category to be regulated.

Some businesses that would normally be considered a major source can
be classified as a minor source by changing the way they conduct their
business. Businesses classified as a major source have significant
regulatory requirements such as annual fees, maintaining progress
reports, records, and a compliance schedule, monitoring emission limits,
as well as the possible requirement to have specific control technology
installed (MACT, GACT, or RACT). All major sources are required to
obtain a Title V Permit. It is generally desirable for a business not to be
classified as a  major source. An EPA document "Potential to  Emit, A
Guide for Small Businesses" (EPA-456/B-98-003) is available from the
EPA and it may help you to understand Air Quality Regulations.

The State of New Mexico,  in addition to HAPs and Criteria Pollutants, has
also generated regulations on Toxic Air Pollutants (TAPs) with OELs.
These basically limit businesses from allowing TAPs to be emitted to the
outside air around their building. OSHA regulates the same kinds of
exposure limits inside of a building.

Due to the complexities of Air Quality Regulations, the harm air emissions
cause to the environment,  and in many cases the high costs associated
with "end of the pipe" control technology, it is in the best interest of any
business to evaluate their operations with the ultimate  goal of eliminating
all air pollutants as much as possible.

What  all this means is, with few exceptions, the Air Quality Regulations
that apply to your business will mostly be determined by what your
business does. The best way to find out what air quality regulations apply
to your business is to contact the New Mexico Environment Department
(NMED) Small  Business Assistance Program (SBAP) at  1-800-810-7227.
Businesses that are located in Bernalillo  County are locally regulated with
respect to air emissions. For assistance you need to call the City of
Albuquerque/Bernalillo Air Quality Assistance Program (AQAP) at 505-
768-1964.
HAZARDOUS WASTE REGULATIONS:

Any business that generates waste that is classified as "listed" or
"characteristic" in RCRA must deal with this waste as outlined in the New
Mexico Hazardous Waste Regulations. The EPA has generated a list of
chemicals that are considered hazardous. They have also stated that
certain materials that exhibit a hazardous characteristic (ignitibility,
corrosivity, reactivity, or toxicity) should be considered hazardous. To
determine which products used in your business contain hazardous
material, contact either the EPA or the New Mexico Hazardous Waste
Bureau. In some cases this information will be contained on the Material
Safety Data Sheet (MSDS) that came with the product.

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It is important to understand that any product that contains "listed" or
"characteristic" material is only regulated by the hazardous waste
regulations when it becomes a waste. Examples are when the product is
no longer to be used for its  intended purpose and is to be gotten rid of,
the shelf life of the product has expired, the product leaks from a piece of
equipment, or the product is accidentally spilled. It is also important to
note that any product to be  discarded that contains one or more
hazardous materials is also hazardous waste. Examples are hazardous
waste mixed with solid waste, rags to clean up spilled hazardous
materials, or wastewater from a process that used a hazardous material.

All businesses that generate hazardous waste are classified based on the
quantities of hazardous waste they generate monthly. The three
classifications are:

1.  Conditionally Exempt Small Quantity Generator (CESQG): generates
   less than 220 pounds or 100 kilograms of hazardous waste per
   month. A CESQG cannot accumulate more than 2,200 pounds or
   1,000 kilograms of their combined hazardous waste at any one time.
   Usually this amounts to about one-half of a 55-gallon drum. CESQG's
   may dispose of their hazardous waste by mixing it with a solid waste,
   assuming there are no free liquids in the waste, and taking it to a
   permitted municipal solid waste (MSW) landfill. You need to verify that
   the MSW landfill will accept the mixed waste.

2.  Small Quantity Generator (SQG): generates between 220 pounds and
   2,200 pounds or 100 kilograms and 1,000 kilograms of hazardous
   waste per month. No more  than 13,200 pounds or 6,000 kilograms
   may be stored on site any longer than 180 days and must be
   disposed of at a facility permitted to recycle, treat, store, or dispose of
   hazardous waste.

3.  Large Quantity Generator (LQG): generates more than 2,200 pounds
   or 1,000 kilograms of hazardous waste per month.  Hazardous waste
   with no weight limit may be accumulated for no more than 90 days
   unless permitted  by the State.

Each classification has different record keeping, manifesting, and
reporting requirements. Since a businesses' classification is  based on a
monthly generation, it is possible to move from one classification to
another on a regular basis.  All generators of hazardous waste are
required to register with the Hazardous Waste  Bureau  and pay a
generator fee based  on their classification.

The Hazardous Waste Bureau  has an established outreach program that
can assist any business in determining their classification and the
regulatory requirements that go with it. You may contact the  Bureau at
505-827-1511.

It is important for any business generating hazardous waste to
understand that RCRA has  established a "cradle to grave" responsibility
for the generator of said waste. In  effect this means that if the hazardous
waste the business generates contaminates soil, surface water, or ground
water in any manner until it is properly disposed of, the business will be
held responsible for the clean up of the contamination. The cost of clean
up could be substantial. It is therefore imperative for any business to

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make sure trained employees handle their hazardous material properly to
avoid accidental spills, to only use permitted haulers, to make sure their
waste goes to a RCRA permitted facility, to properly store their hazardous
waste, and never dispose of their hazardous waste at their facility. It is
also advisable to seal the floor of the facility if you use a hazardous
material in a liquid form in your operation.

The best way for any business to avoid the costs of contamination clean
up is to eliminate the use of hazardous materials in their operation. A
complete understanding of how a business conducts its processes is
required to determine the best way to eliminate or at least reduce the
amount of hazardous waste being generated. A Pollution Prevention
Program has been established at the New Mexico Environment
Department to assist businesses in evaluating their processes. The
number to call at NMED is 505-827-0677 or you can call the Technical
Resource Center in Albuquerque at 505-843-4251.

The New Mexico Environment Department has a 24-hour emergency
reporting number that can be called in case of an incident dealing with
hazardous material. The  number is 505-827-9329.
WASTEWATER REGULATIONS:

Any business that generates wastewater that contaminates surface water
or ground water can be held responsible for the cost of cleanup. If the
contaminant is a RCRA "listed" or "characteristic" waste above the
concentration value allowed, then the wastewater is by definition a
hazardous waste and must be dealt with under New Mexico Hazardous
Waste Regulations. Placing hazardous wastewater directly onto or into
the ground is strictly prohibited. Since the cost of cleaning up either
surface water or ground water can be substantial, it is in the best interest
of any business to eliminate, minimize, and/or control its wastewater.

If non-hazardous wastewater is being discharged so that it can move
directly or indirectly into  ground water (e.g. septic system, dry sump,
etc.) a business is required to file a "Notice of Intent to Discharge" with
the New Mexico Ground Water Bureau in accordance with the NM Water
Quality Act. The Bureau will then determine if the business requires a
Discharge Permit. In some cases the business may be required to
request a NPDES Permit from the EPA if the discharge is to surface
water.

If non-hazardous wastewater is being place into a sewerage system a
business is required to notify the local Publicly Owned Treatment Works
(POTW) the nature and concentrations of the contaminants in the
wastewater. Attached is a listing of the New Mexico Publicly Owned
Treatment Works. Wastewater that has been determined to be hazardous
is prohibited from being placed in any sewerage system.

Business need to be aware that even though their wastewater going into
the sewerage systems is  allowed by  the POTW, this does not necessarily
relieve them of potential contamination liability. A good example is the
case in which a sewer pipe leaks and the wastewater contains  hazardous
constituents, below RCRA levels, that were generated by your business.
Over time the wastewater seeps into the ground water and the
concentrations exceed State or Federal water quality standards. If the

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contamination source can be traced back to your business, you could be
liable for the cost of cleanup. Most businesses will find that the costs
associated with proper handling of their wastewater are far cheaper than
the cost of cleaning up ground water. Prevention is an inexpensive
insurance policy.

Another potential source of contamination is through the foundation of
your building. An  example would be where a business handles hazardous
material as a regular part of doing business and a spill occurs that seeps
through cracks in the floor. Eventually it reaches ground water and is
detected through monitoring of the ground water. Assuming it can be
traced back to your business,  you could then be held responsible for the
cost of clean up.

Any business that generates wastewater from sources other than
lavatories, cafeterias,  etc., should evaluate ways in which the wastewater
can be eliminated, reduced, recycled, reused or handled in such a fashion
that the risk of liability for contaminating surface water or ground water is
virtually zero. This should include dealing with hazardous waste and all
wastewater in a proper fashion, sealing cracks in floors, training of
employees, and possible treatment of their wastewater before it leaves
their premises.

If you have any questions you can contact the Ground Water Bureau at
505-827-2965 and the Surface Water Bureau at 505-827-0187.

OSHA  REGULATIONS:

Every business is required to provide a safe and healthy working
environment for its employees. The Occupational Health and Safety
Bureau (OHSB) is responsible for making sure businesses are in
compliance with OSHA regulations. OSHA regulates permissible
exposure limits (PEL's) for employees exposed to certain air
contaminants in the workplace. The Bureau conducts regular inspections
of facilities and evaluates the establishment for safety and health
compliance. The OSHB has a consulting program to assist facilities to be
in compliance with OSHA regulations. The service is free of charge to
New Mexico small businesses. Attached is a copy of "Frequently Asked
Questions" about the program, a copy of "General Health & Safety
Issues", as well as a poster you are encouraged to display at your facility.
They can be contacted at 505-827-4230.

UNDERGROUND STORAGE TANK REGULATIONS:

Any business that stores a regulated substance  in an underground
storage tank that is not directly connected to some sort of processing
operation may or may not be regulated by the Underground Storage Tank
Bureau (USTB). If the substance is a hazardous waste, it is regulated
under RCRA and you would need to contact the Hazardous Waste
Bureau. Since there are a variety of circumstances whereby LIST
regulations have jurisdiction, it is best to contact the USTB directly for
guidance. They can be contacted at 505-827-0188.

SOLID WASTE REGULATIONS:

The Solid Waste Bureau (SWB) deals primarily with regulating solid
waste facilities (non-hazardous waste landfills, transfer stations, and

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recycling facilities) and illegal dumping. The only responsibility for a small
business is to see that their non-hazardous waste is either sent to a
recycler or to a permitted landfill by a registered solid waste hauler. For
information the SWB can be contacted at 505-827-0197.

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Pollution Prevention and Regulatory Compliance Contacts for New Mexico
         STATE AGENCIES:

         Green Zia Environmental
         Excellence Program
          Pat Gallagher
          NM Environment Department
          Office of the Secretary
          PO Box 26110
          Santa Fe, NM 87502
          505-827-0677
          FAX: 505-827-2836
          E-mail:
          pat Gallagher(g),nmenv.state.nm.us

         Air Quality Bureau
          Steve Dubyk
          NM Environment Department
          1190 St. Francis Drive
          P.O. Box 26110
          Santa Fe, NM 87502
          505-827-2859
          FAX: 505-827-0045
          E-mail:
          steve dubvktginmenv.state.nm.us


         Hazardous Waste Bureau
         Debby Brinkerhoff
         NM Environment Department
         2044 Galisteo
         P.O. Box 26110
         Santa Fe, NM 87502
         505-827-1511
         FAX: 505-827-1833
         E-mail:
         debbv brinkerhoff(@,nmenv.state.nm.us
 Occupational Health & Safety
 Bureau
 Debra McElroy
 525 Camino de los Marquez, Suite 3
 P.O. Box 26110
 Santa Fe, NM 87502
 505-827-4230
 FAX: 505-827-4422
 E-mail:
 debra mcelroy(g)nmenv.state.nm.us

Ground Water Quality Bureau
 Industrial Waste  Team Leader
 NM Environment Department
 1190 St. Francis  Drive
 P.O. Box 26110
 Santa Fe, NM 87502
 505-827-2900
 FAX: 505-827-2965

Solid Waste Bureau
 Jim Condiss
 NM Environment Department
 1190 St. Francis  Drive
 P.O. Box 26110
 Santa Fe, NM 87502
 505-827-0559
 FAX: 505-827-2902
 E-mail:
 jim condiss(@,nmenv.state.nm.us


Underground Storage Tank
Bureau
Joyce Shearer, Ph.D.
NM Environment Department
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
505-476-3779
FAX: 505-827-0310
E-mail:
Joyce shearer(@,nmenv.state.nm.us

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Please note that a list of all Public Owned Treatment Plants (sewage treatments
plants) are listed for all of New Mexico on the following page.   Waste Treatment
Plant operators are important regulatory contacts for small businesses. Please
refer to the list and contact your local plant operator for information specific to
your community and business.
         City of Albuquerque
        Public Works Department

        Bob Hogrefe
        Southside Water Reclamation Plant
        4210 Second Street, SW
        Albuquerque, NM 87185
        Ph: 873-7030
        Fx: 873-7087
        Rhogrefe(o),cabq.gov
        Environmental Health Department

        John Liberatore
        EHD/APCD
        P.O. Box 1293
        Albuquerque, NM 87103
        505-768-1964
        FAX: 505-768-2617
        E-mail: jliberatore(@,CABQ.gov
         New Mexico State University

         WERC P2 Center
         1155 University Blvd., SE
         Albuquerque, NM 87106
         505-843-4251
         E-mail: chrisc(3)werc.net

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State of New Mexico Wastewater Treatment Facility Contacts
POTW FACILITY
ALAMOGORDO, CITY OF
ALBUQUERQUE, CITY OF
ANTHONY W&SD
ARTESIA, CITY OF
AZTEC, CITY OF
BELEN, CITY OF
BERNALILLO, TOWN OF
BLOOMFIELD, CITY OF
CANNON AIR FORCE BASE
CAPITAN, VILLAGE OF
CARLSBAD, CITY OF
CARRIZOZO, TOWN OF
CHAMA, VILLAGE OF
CIMARRON, VILLAGE OF
CLAYTON, TOWN OF
CLOUDCROFT, VILLAGE OF
CLOVIS, CITY OF
CONCHAS STATE PARK
CUBA, VILLAGE OF
DEMING, CITY OF
DEPARTMENT OF ENERGY, LANL AND U OF CA
DES MOINES, VILLAGE OF
DEXTER, TOWN OF
EAGLE NEST, VILLAGE OF
ECO Resources #3
ECO Resources # 2
ESPANOLA, CITY OF
ESTANCIA, TOWN OF
EUNICE, CITY OF
FARMINGTON,CITYOF
FORT SUMNER, VILLAGE OF
GALLUP, CITY OF
GRANTS, CITY OF
HAGERMAN, TOWN OF
HATCH, VILLAGE OF
PHONE NO.
(505)439-5643
(505) 437-4530
(505)873-7040
(505)882-3922
(505)746-2122
(505)334-8664
(505)864-6081
(505)867-2307
(505)632-8474

(505)354-2247
(505)887-5412
(505)354-2247
(505)756-2184
(505)376-2232

(505)682-241 1
(505)769-7865
(505)868-2900
(505)289-3864
(505)546-8848
(505)665-7855

(505)734-5482

(505)891-1223
(505)891-1223
(505)753-4740
(505)384-2302
(505)394-2576
(505)599-1315
(505)355-2401
(505)863-1210
(505)287-7927
(505)752-3201
(505)267-3021
CONTACT PERSON
Jose Miramontes
Charles Bowman, WW Utilities
Div. Director
Pat Banegas
Ernest Thompson, Mayor
Gary Spickelmier
Robert Rimorin
NickTobey
Casimiro Ruybalid
Lynn Steinle
Terry Cox
Gilbert Ybarbo
Steve Sale
Tony Gonzales, Mayor
Lino Paiz

David Venable, Mayor
Robert Challender
Leo Wilson
Faustino Gallegos
Louis Jenkins, Public Works
Director
Charles Barnett

Joe Alvarez

Donald Thymes
Donald Thymes
Frank Naranjo

Willie Luster
Tom Wethington, WW Director
John McMillan, Mayor
Ray Espinoza
Willie Alire, City Manger
Robert Romero
Clifford Browning

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HOBBS, CITY OF
HOLLOMAN AIR FORCE BASE
JAL, CITY OF
JEMEZ SPRINGS, CITY OF
KIRTLAND AIR FORCE BASE HQ AFSWC/CC
LACUNA, PUEBLO OF
LAS CRUCES, CITY OF
LAS VEGAS, CITY OF
LOGAN, VILLAGE OF
LORDSBURG, CITY OF
LOS ALAMOS, BAYO PLANT
LOS LUNAS, VILLAGE OF
LOVING, VILLAGE OF
LOVINGTON, CITY OF
MAGDALENA, VILLAGE OF
MAXWELL, VILLAGE OF
MELROSE, VILLAGE OF
MORA MUTUAL DOMESTIC WATER & SEWER. WKS.
MORIARTY, CITY OF
MOUNTAINAIR, TOWN OF
ORGAN WATER AND SEWER ASSOCIATION
PECOS, VILLAGE OF
PORTALES, CITY OF
QUESTA, VILLAGE OF
RAMAH DOMESTIC UTILITIES
RATON, CITY OF
RED RIVER, TOWN OF
RESERVE, VILLAGE OF
ROSWELL, CITY OF
ROY, VILLAGE OF
RUIDOSO-RUIDOSO DOWNS REGIONAL WWTP
SAN JON, VILLAGE OF
SANTA FE, CITY OF
SANTA ROSA, CITY OF
SANTA TERESA SERVICES COMPANY
SILVER CITY, TOWN OF
SOCORRO, CITY OF
SPRINGER, TOWN OF
SUNLAND PARK, CITY OF
(505)397-9315
(505)479-7080
(505)395-2222
(505)829-3540


(505)528-3599
(505)454-1401
(505)487-2239
(505)524-8273
(505)662-8147
(505)865-9689

(505)396-2884
(505)854-2261
(505)375-2752
(505)253-4274
(505)387-5401
(505)832-6257
(505)847-2321
(503)825-5423
(505)757-6591
(505)359-3152
(505)586-0694
(505)722-4366
(505)445-2292
(505)754-2277
(505)533-6581
(505)624-6700
(505)485-2204
(505)258-4014
(505)576-2922
(505)984-6509
(505)472-3331
(505)589-0906
(505)388-4981
(505)835-0240

(505)589-1979
James Tulk
Meryle F. Stueve, TSgt, USAF
Fred Seifts
David Sanchez, Mayor

Frank Analla
Gilbert Morales
Andrew R. Jaramillo
Julian Cordova
Alex De La Garza
Paul Pizzoli, Utilities Director
Louis Huning, Mayor

Bob Carter
Vida M. Trujillo
Leroy Quintana, Mayor
Bobby Bennett, Mayor
Manuel B. Alcon President
Rosendo Saiz
Debra Kelly
Charles Jefferson
Joseph Cyde Baca, Mayor
Thomas Howell
Mike Cordova
Ron Morsbach
Mike Baca
Jake Pierce, City Administrator
Lonnie Graham
Roger Cooper, PE, Dir of Public
Works
Alex Deschamps
Gary Jackson, Village Manager
Chris Molyneaux
Qustandi Kassisieh
Gerald Anaya,Water & Sewer
Superintendent
Charles Crowder
Stan Snider
Pat Salome, City Clerk

Mark Boling

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TAOS, TOWN OF
TATUM, TOWN OF
TEXICO, TOWN OF
THOREAU WATER AND SANITATION
TRUTH OR CONSEQUENCES, CITY OF
TUCUMCARI, CITY OF
TULAROSA, VILLAGE OF
TWINING, W&SD
VAUGHN, TOWN OF
WAGON MOUND, VILLAGE OF
(505)758-8401
(505)392-7412
(505)482-3314
(505)862-7136
(505)894-7331
(505)461-3451
(505)585-2771
(505)776-8845
(505)392-1266
(505)666-2408
Mark Swan, Supervisor
F. L. (Roy) Miller
Mathew Meeks
Vidal Brown
Quentin Drunzer, City Manager
Bernadette Moya, City Manager
Margaret Gonzales, Village Clerk
Joe Harvey
F.L. Miller- Con. Engineer
Alfred Romero Mayor

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Online Resources:

City of Albuquerque P2 Program:www.cabq.gov
Additional Sources of Information:

The New Mexico Environment Department's Hazardous and Radioactive
Materials Bureau offers free on-site technical assistance for small businesses to
help address small business hazardous waste issues.  Please contact the
Bureau at 505-827-1558 and ask for the Hazardous Waste On-Site Assistance
Program for a consultation.

The City of Albuquerque Public Works Department has a guidebook on pollution
prevention for the jewelry manufacturing industry.  Please contact Bob Hogrefe at
505- 873-7030 for a copy.

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       Understanding  Solvents:  Common
         Uses and  Chemical Composition
                  Eliminate - Reduce - Reuse - Recycle - Exchange
            Solvents are used to create a fluid environment in which reactions or processes can be run efficiently and
            effectively. Solvents influence pH and temperature factors that affect the binding mechanisms of soiling
            agents.  The following paragraphs are intended to serve as an introduction to the chemical composition,
            general activity mechanisms, and common uses of various types of solvents.
Petroleum -
Based Solvents
            This group refers to a class of solvents that are used as general-purpose cleaners. Most petroleum-based
            solvents consist of a hydrocarbon "backbone" to which chemical functional groups and oxygen groups have
            been added. In these solvents, the inorganic functional groups are responsible for the activity of the
            solvent. The exception to this rule is a subclass of petroleum-based solvents called aromatic and aliphatic
            hydrocarbon solvents, which contain multiple bond arrangements and/or are bonded into ring
            confirmations. In these solvents, it is the carbon confirmation and arrangement of double and triple bonds
            between neighboring carbon atoms that give the solvent its activity.
            Industry has chosen the petroleum-based solvents with low molecular weight, which have high volatility.
            The high volatility and reactivity of these solvents allows maximum removal of soils and contaminants,
            creating compatibility with varied work surfaces and subsequent process requirements while simplifying
            process and technique, thereby minimizing costs. Furthermore, because many soiling agents are organic
            compounds, ex.) grease, motor oil, waxes, and most lubricants, they are miscible in organic petroleum-
            based solvents, allowing for quicker, more effective clean up.
            Due to their high volatility, total containment of petroleum-based solvents during application and waste
            storage is nearly impossible. The atmospheric escape of these solvents, many of which are classified as
            Volatile Organic Compounds (VOC's), has been shown to contribute to stratospheric ozone depletion, air
            pollution through smog formation, and soil and groundwater contamination.

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Types of Petroleum-Based
Solvents:
             Halogenated petroleum-based solvents:
             These solvents consist of the highly reactive functional groups chlorine, fluorine, or bromine. These
             halogens share the same number of electrons available to participate in chemical reactions. For this reason,
             the chemical reactivity of these solvents is less dependent on which halogen atom comprises a functional
             group than on how many functional groups are attached to the hydrocarbon "backbone," a number referred
             to as the degree of halogenation. A solvent with a high degree of halogenation has a high volatility and
             strong cleaning properties.

             Higher energy levels in the bonds make the molecule more reactive, which can cause it to escape from the
             liquid phase into the gas phase and enter the atmosphere. The popularity of halogenated solvents arose
             from their superior contaminant and soil expulsion properties, low flammability, compatibility with
             work surfaces and process equipment, and relatively low cost.
Alternatives that Reduce
Risk:
             Though it is often advisable to seek non-halogenated alternative solvents because halogenated compounds
             are hazardous to human and environmental health, several new halogenated alternatives have been
             developed with short atmospheric lifetimes.

             n-Propyl Bromide:
             Many commercial "green" solvents have replaced their chlorinated solvents with n-butyl bromide because
             it is a nonflammable VOC with a 10-11 day atmospheric lifetime, giving it a low Ozone Depletion
             Potential.  However, despite a low bio-accumulation potential, n-butyl bromide solvents are non-
             biodegradable, and in large volumes have the potential to penetrate soil and contaminate groundwater.
             Furthermore, they may harm some work surfaces, especially aluminum surfaces.
             High-volatility oxygenated solvents:
             In these solvents, the halogen functional group is replaced by an oxygen group such as a hydroxide group,
             such as alcohols; an ethyl group, such as ethers and esters; or a carbonyl group, such as ketones, aldehydes,
             and carboxylic acids. The hydroxide group has a similar chemistry to the halogen groups with one
             important exception: most of the oxygenated solvents are highly flammable and therefore restricted to
             applications such as ambient temperature immersion and manual wipe.

             Oxygenated solvents are also prone to undergo reduction/oxidization (redox) reactions, which is the
             addition or elimination of double bonds or oxygen atoms.  Although redox reactions in these solvents rarely
             result in more toxic compounds, the resulting solvent is less effective and more flammable under
             atmospheric conditions.   For this reason, a warning not to mix with oxidizing agents often accompanies
             the oxygenated and aromatic and aliphatic hydrocarbon solvents.

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Alternatives that Reduce Risk:
       •   Acetone:
           Excluded from the U.S. EPA's definition of VOC's due to its insignificant reactivity in the presence of
           sunlight, Acetone is a nonetheless a highly volatile organic solvent.  Acetone is suitable as a drying agent
           and for ambient immersion or manual cleaning applications of soils such as greases, waxes, and inks. Due
           to its high flammability, safety cautions must be implemented during handling as well as during recycling.
           Although Acetone need not be reported under SARA 113, it is on the RCRA list of hazardous wastes, and
           must be incinerated for disposal.


       •   Alcohols (with perflourocarbons):
           Alcohols, mainly isopropanol, methanol, and ethanol, are excellent cleaning solvents for certain soils.  The
           hydroxide functional group allows the alcohol to exhibit some of the same properties as water, while the
           hydrocarbon "backbone" allows the alcohol to dissolve low-molecular-weight oils. Alcohol solvents are
           often biodegradable and water-soluble.  Alcohols are also flammable VOC's and as a result can only
           be used directly in manual and cold immersion applications, although their greatest efficacy occurs in
           heated or boiling liquid applications.

           This obstacle can be overcome by placing a perfluorocarbon vapor "blanket" above the heated cleaning
           system.  This vapor "blanket" shields the solvent from atmospheric oxygen that causes combustion.
           Perfluorocarbons are nonflammable and have low toxicity, but are costly and have high global warming
           potential.  Though they are immiscible in alcohol and easily separable and reusable, the capital and
           operational costs of perfluorocarbon systems are fairly high and prohibitive when other methods are
           available.  Perfluorocarbons, which can be employed as solvents alone, have greatest potential in cleaning
           equipment that uses fluorinated lubricants or polymeric and elastomeric materials that are easily corroded
           by other solvents.


       •   Glycol Ethers/ Ethyl Lactate:
           Because glycol ethers emulsify well and separate easily, they are prime candidates for the organic
           components of semi-aqueous solvents.  They are also being substituted for both harmful halogenated
           hydrocarbon and high-volatility oxygenated solvents in capacities ranging from dry cleaning to
           degreasing.  Often azeotropic blends and additives such as isoparaffinic hydrocarbons are supplemented in
           to increase the solvent's efficacy rating, work surface compatibility, and/ or decrease the solvents
           flammability.  However, glycol ethers are highly flammable VOC's.
           Commercially important glycol ethers have been separated into two categories: the E-series, or ethylene
           glycol ethers, and P-series, or propylene glycol ethers.  Because they have been linked to miscarriages,
           SARA 113 and OSHA heavily regulate the E-series. Due to these concerns, alternatives are being
           researched.

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         •   n- Methylpyrrolidone (NMP):
             NMP is a combustible VOC listed under the SARA 113 Title III.  Despite this listing, NMP is very useful
             in removing high-molecular-weight greases and carbon deposits as well as coatings (polyurethane, ink, and
             resin), enamels, and many plastics. It can be employed in both immersion and ultrasonic processes.  Since
             many oils are only soluble in NMP above 145 F°, oil soils can be easily separated and the solvent
             reclaimed by lowering the solvent temperature. Furthermore, NMP is biodegradable and can also be
             reclaimed through separation and subsequent vacuum distillation.
 Aromatic and aliphatic hydrocarbon solvents:
 These solvents are also referred to as unsaturated hydrocarbons. Due to their flammability concerns and redox potential,
 aromatic and aliphatic hydrocarbon solvents share the advantages and disadvantages of the oxygenated solvents.
Alternatives that Reduce
Risk
1
         Terpenes:

         Derived from natural sources such as citrus fruit and pine trees, terpenes are biodegradable and are useful in
         semi-aqueous solutions (from which they can often be separated and reused). Terpenes are flammable
         VOC's and very strong cleaners, removing resin, fingerprints, and high-molecular-weight greases. They can
         be used in ambient immersion and ultrasonic applications, though they may be too strong for some work
         surfaces.
         Petroleum Distillates:
         Produced from crude oil cracking, petroleum distillates are also flammable VOC's used to remove high-
         molecular-weight greases, tar, and waxes in immersion or manual applications. This class of solvents includes
         mineral and white spirits, naphtha, kerosene, and Stoddard solvent, which vary in cost and toxicity. Petroleum
         distillates are able to penetrate and clean porous surfaces, and evaporative losses can be minimized through
         the use of a parraffinic hydrocarbon additive. Furthermore, they can serve in some semi-aqueous solutions,
         from which they can be easily reclaimed through separation or distillation techniques.
      ueous Solvents
         Aqueous solvents are a category consisting mainly of water and dissolved inorganic water soluble
         components such as surfactants, chelating agents, emulsifiers, sequestering agents, and corrosion inhibitors.
         Water is a polar compound, meaning that a portion of the water molecule, the oxygen atom, has a greater
         affinity for the molecule's bonding electrons, and hence has a slight negative charge.   As a result, the
         remaining portions of the molecule, the hydrogen atoms, have a slight positive charge. Due to this charge
         separation within their constituent molecules, aqueous solvents are held together by intermolecular forces in
         which the negatively charged oxygen atom of one water molecule creates a weak bond to the positively charged
         hydrogen atom of another water molecule. These intermolecular attractions, referred to as hydrogen bonding, in
         conjunction with its basicity/ acidity allow the solvent to "attack" any soil which contains charged portions.

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         Aqueous solvents are generally superior to organic solvent methods. Due to the benign nature of water,
         aqueous solvents are less hazardous to both human and environmental health than their organic
         counterparts.  Aqueous solvents are often corrosive or harmful to work surfaces, and are often ineffective
         with porous surfaces or soils. Furthermore, due to their immiscibility with organic contaminants, aqueous
         solvents must be repeatedly applied to common organic soiling agents to achieve effective removal. Often the
         process requires high pressure or ultrasonic technology. Therefore, in weighing the environmental factors
         involved in replacing organic solvents with aqueous solvents, the increased volume of wastewater streams
         must be considered.  When utilizing aqueous solvents, it is tempting to dispose of the waste solution down the
         drain; however, the local water authorities should always be consulted about proper waste disposal.
Types of Aqueous
Solvents:
 Alkaline aqueous solvents:

         Alkaline aqueous solvents have a pH greater than 7.  Adding base to an aqueous solution creates an alkaline
         solvent, which contains negatively charged ions. These negatively charged particles disrupt the polar bonds
         binding the contaminants to the work surface, as well as obstruct the intermolecular bonds holding the
         contaminant together, thereby dissolving the contaminant. Due to the corrosive nature of these ions,
         inhibitors must be added to protect metallic work surfaces, especially aluminum surfaces.  With the right
         additives and process optimization, alkaline solvents can be utilized with all types of liquid cleansing processes.
         With thorough filtration and rinsing, very high levels of cleanliness can be achieved, although the process may
         become water intensive. Alkaline aqueous solvents are widely applicable, low waste, and cost effective.


 Neutral Aqueous solvents:
         Having a pH of approximately 7, neutral aqueous solvents are mixtures of water and above-mentioned process
         specific additives. Weaker than alkaline solvents, neutral solvents are effective at removing light oils, salts,
         particles, and soils that are easily removed.  For these contaminants, the dissolving properties of hydrogen
         bonding are sufficient to break up and remove the soil.  Due to their weaker activity, neutral solvents are less
         widely applicable and are most effective in spray and ultrasonic applications, especially in degreasing
         processes.


 Acidic Aqueous solutions:
         Acidic aqueous solutions have a pH less than 7 and may be comprised of mineral acids, chromic acids, or
         organic acids that are miscible in water due to their acidic properties.  Acids have free floating positive charge,
         making them excellent at removing scale, rust, and oxidizing agents from metals.  The positive portions of the
         acid surround and dissolve the aberrant negatively charged metal region. Some metal/ acid combinations cause
         hydrogen embrittlement on the surface of the metal.  This can be significantly reduced or eliminated by
         changing acids or heat-treating the metal before the cleansing treatment.  Because acidic aqueous solvents are
         less adaptable to general cleaning processes, they are less common as cleaning solvents.

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  Semi-Aqueous
  Solvents:
           Two different types of semi-aqueous solvent procedures are commonly used.  The first involves a solvent in
           which hydrocarbon/ surfactant cleaners are emulsified in water, meaning that the hydrocarbon/ surfactant exists
           as droplets suspended in the aqueous support.   This arrangement combines the more effective contaminant
           dissolution and high-molecular-weight soil removal characteristics of petroleum-based solvents, with the
           increased environmental safety of aqueous methods.

           The other semi-aqueous method entails an initial concentrated hydrocarbon application followed by an aqueous
           rinse cycle.  Again, this method utilizes the effectiveness of organic solvents while lessening the
           environmental impact of the overall process by reducing the amount of organic solvent employed.  The
           application techniques for both semi-aqueous methods are similar to those used in aqueous methods, though
           flammability, phase separation, and odor problems can arise with the mixing  of the solvent types, making
           equipment design an important consideration.
Super Critical
Fluids
   Supercritical fluids are common gasses such as carbon dioxide under extreme pressure and temperature.  Under these
   conditions, the fluid no longer exhibits the characteristics of a liquid or a gas, but rather has properties conducive to high
   soil dissolution. The high temperature of a critical fluid confers a high energy level to the individual molecules, which
   under atmospheric pressure would cause the molecules to increase molecular vibrations and velocity, causing the fluid to
   expand.

   However, because critical fluids are also under high pressure, the high-energy molecules are not able to expand and must
   exist in a tightly packed, high-energy configuration.  It is this dense, high-energy arrangement that gives critical fluids
   their high soil dissolution properties. This current technology combines application flexibility with low cost. However,
   it requires large capital investment to design and maintain a system capable of safely withstanding  such high
   temperatures and pressures. More testing must be completed to understand the effects on sensitive work surfaces.

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          New Mexico Occupational
                         Health  & Safety  Bureau
New Mexico Environment Department                          525 Camino de los Marquez - PO Box 26110
   Santa Fe, New Mexico 87502                                  (505) 827-4230 Fax (505) 827-4422

                                  Jewelry Shop Safety Checklist

          YES   NO


          General Conditions

          D  D  Is ventilation strong enough to remove fumes and odors from work areas?
          D  D  Is there good ventilation even when windows are closed on rainy or windy days?
          D  D  Is there a break room away from work areas? Are eating, drinking, and smoking prohibited
                in work areas?


          Chemical Storage

          D  D  Do all containers have labels?
          D  D  Are chemicals stored in fire-resistant cabinets or rooms?
          D  D  Are incompatible chemicals (such as cyanide and acids) stored in separate areas?
          D  D  Are waste chemicals disposed of properly and promptly?


          Waxing

          D  D  Does the waxing area have ventilation to remove paraffin fumes?
          D  D  Is there enough light for the detailed work done by waxers?


          Casting

          D  D  Has a hazard assessment been conducted for metal fume  exposure to determine if respiratory
                protection is needed? (i.e. lead, cadmium air monitoring)
          D  D  Are safety glasses worn while  metals are being melted?
          D  D  Is metal kept molten for the briefest time practical to reduce metal fume exposure?
          D  D  Do casters wear fireproof (but  asbestos free) gloves and aprons while handling hot metals?
          D  D  Is there ventilation in the area where metal is melted to remove metal fumes?
          D  D  For rotary casting machines: Is there a safety switch that prevents operation of the machine when
                the lid is open?  Is the machine bolted securely to the floor?


          Stripping and Knockout

          D  D  Has a hazard assessment been conducted for silica exposure?
          D  D  Are flasks allowed to cool for a few  minutes after casting, before quenching in water?

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D  D  When investment is removed from the flasks, is it kept completely wet to reduce dust?
D  D  Are traces of investment removed from cast trees without using hydrofluoric acid?
D  D      Is this done by using: water-jet cleaning? And ultrasonic bath? Glass-bead blasting?
D  D  If hydrofluoric acid is used to remove investment, are the needed safety measures taken?
D  D      Are gloves and chemical goggles worn whenever the acid is handled?
D  D      Are an acid proof coat, goggles, and face shield worn when concentrated hydrofluoric
           acid is handled?

YES   NO

D  D      Are gloves made of neoprene, nitrile rubber, or natural rubber?
D  D      Are an emergency shower and eyewash station located within 25 feet of the
           concentrated hydrofluoric acid area?
D  D      Has stripping been eliminated by using special gold alloys, or by glass-bead blasting  of the cast
           trees?
D  D      If stripping  is needed,  has bombing been replaced by a cyanide-free stripping process?
D  D      If cyanide stripping is still used, are all necessary safety precautions taken?
D  D      Are employees who handle cyanide trained in its hazards and in safe work practices?
D  D      Are all cyanide containers clearly labeled, indicating the contents and hazards?
D  D      Is the equipment used to  measure and mix cyanide used for those purposes only?
D  D      Is cyanide stored in a locked cabinet to prevent unauthorized use?
D  D      Does the stripping  area have ventilation to remove airborne cyanide?
D  D      Are eating, drinking, and smoking prohibited in the stripping area?


Soldering and Finishing

D  D  Is cadmium free solder used exclusively?
D  D  Has a hazard assessment been conducted for cadmium exposure if solder is not
       cadmium free (i.e. air monitoring) to determine if respiratory protection is necessary?
D  D  Has a hazard assessment been conducted for lead exposure (i.e. air monitoring) to
       determine if respiratory protection is necessary?
D  D  Are the ingredients of all solders clearly identified on their labels?
D  D  If paste solder is used, is the flux free of fluorides, such  as fluoborates and zinc fluoride?
D  D  Is a "safety pickle" (such a sodium bisulfate) used as a pickling agent, instead of
       sulfuric acid?
D  D  Is the lighting strong enough,  but free of glare?


Polishing

D  D  Are the dust collectors  on all polishing machines working effectively? Check for two
       warning signs that the ventilation is not working well enough.
D  D      Does grit accumulate rapidly on surfaces surrounding the polishing wheels?

D  D      If you leave a sheet of paper in the polishing room, does it get covered with dust
           in a few days?
D  D   Are  safety glasses or  other shields always used when polishing to prevent eye injuries?
D  D   Are  vibratory polishers or tumblers  used instead of ordinary polishing wheels where appropriate?
D  D      Are the  noise levels produced by tumblers below the 8 hour time weighted average of
           85dBA (action level)?


Stone Setting

D  D  Are stone setters encouraged to work under magnifying lenses to reduce eye-strain?
D  D  Are setters given tools  that can  be used comfortably without placing strain on the  hands or wrists?

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D  D   Is the lighting strong enough, but free of glare?


Machining

D  D   Are safety glasses worn during all jobs that might produce flying objects?  These jobs include
        drilling, milling, engraving, stamping, stretching, and others.
D  D   Do all presses have safeguards that prevent amputation of hands or fingers? Check to see that at
        least one of the effective safety mechanisms is used:
D  D      Are guards installed that completely prevent placement of fingers between the dies?

D  D      Are there switches that must be pressed with both hands to begin operation, along with
           simple guarding to keep the hands clear during each operating cycle?
YES    NO

D  D   Are all lathe cutting tools solidly mounted on the lathe, rather than being hand-held?
D  D   Do  rolling mills have  an automatic shut-off bar in the pinch point between the rollers?
D  D   Are all drive belts and gears properly guarded?


Plating


D  D   Are the contents of each plating bath clearly labeled?
D  D   Are gloves and goggles worn when handling acids and other corrosive chemicals?
D  D   Is an emergency shower and eyewash installed in the plating room, in case of an accident?
D  D   If cyanide solutions are used for plating, are all the cyanide precautions descried in
        "Stripping and Knockout" being followed?
D  D   For black plating, have  solution that are free of chromium salts (which cause cancer) been tried?


Cleaning

D  D   Are steam tanks inspected and certified yearly?
D  D   If ammonia solution is used, is there ventilation to reduce the amount of ammonia in work areas?
D  D   Are ammonia baths kept covered whenever possible?
D  D   If solvents such as acetone ortrichloroethane are used, is good ventilation and protective
        equipment provided?


Refining

D  D   Have alternatives to  in-house refining been considered?
D  D   Are gloves, goggles, and an acid suit worn while handling corrosive chemicals?
D  D   Is an emergency shower and eyewash installed in the refinery, in case of an accident?
D  D   Are refinery employees trained in the use of acid-gas respirators, for protection when
        handling spills?
D  D   Is a generous quantity  of acid-resistant absorbent stored  nearby, for use on acid spills?
D  D   If cyanide is used, are all the cyanide precautions described in "Stripping and Knockout"
        being followed?

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                       General Health and Safety Issues
YES   NO
D D  Do the employees wear respirators?
       If so,
D D  Does the company have a written respiratory protection program?

D D   Are employees trained to properly wear, clean/maintain, and know in what
   situations the respirators are needed?

       If not,
D D      Is the indoor air quality such that they are not needed?
D D  Is there a written Hazard Communication Program?
D D  Are MSD sheets available for all the hazardous chemicals in the workplace and are
       they updated regularly?
D D  Have employees received Hazard Communication training?
D D  Are there elevated storage/equipment lofts or platforms present?
       If so,
D D     Are signs showing the weight capacity present?
D D     If the floors are more than 4 feet above a lower floor, are guardrails present?
D D  Are all exits marked with signs?
D D  Are exit doors free to access and are routes to these exits kept free of obstructions?
D D  Is there a procedure in place for obtaining medical treatment for injured employees?
D D  Are there first aid supplies readily available?
D D  Are there fire extinguishers on site?
D D  Are they charged and ready for use?
D D  Are employees required to use these extinguishers?
       If yes,
D D     Is the path unobstructed?

YES   NO

D D     Are they subjected to an annual inspection?
D D     Are employees trained to use them?
       If not,
D D     Is there a written policy that requires employee evacuation?

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          D  D     Does the company have an emergency action plan and fire prevention plan?

          D  D     Has the electrical system throughout the facility been assessed for situations where

                    an employee may come into contact with an electrical current, or the electrical

                    system is such that a fire hazard exists (i.e. bare conductors, faulty equipment,

                    exposed electrical equipment where a flammable/explosive environment may exist)?

          D  D     Does the employer (if 10+ employees are employed) record occupational injuries

                    and illnesses on the OSHA-200 log?


  Note: If any of the above questions that are answered with "Yes", then the condition is probably adequate.  If any of
 the above questions are answered "NO", then re-evaluate the situation, as a violation of the standards may exist. For
                                          assistance contact:

                     NEW MEXICO OCCUPATIONAL HEALTH & SAFETY BUREAU
                                     CONSULTATION PROGRAM
                                            505-827-4230

The Consultation Program provides safety and industrial hygiene surveys of workplaces, along with evaluation of, and
assistance with the establishment of safety and health programs. The program is administered by the State but is
operated separately from the Enforcement Program. The services are primarily targeted to smaller businesses, both
public and private. The goal is to reduce workplace injuries and illnesses by helping businesses identify workplace
hazards and find effective, economical solutions for eliminating or controlling them. The service is free and there are
no penalties or fines, even if problems are found. Participation in this voluntary program has helped many New
Mexico Businesses lower their costs associated with worker's compensation claims and increase their efficiency and
productivity.


          OSHA CONSULTATION/TECHNICAL SERVICES


          FREQUENTLY ASKED QUESTIONS

          What is the Consultation Service all  about?

          The Consultation program  provides safety and industrial hygiene surveys of workplaces, along with
          evaluation of, and assistance with establishment of safety and health programs. Although the
          service was established by the same Act that created the Occupational Safety and Health
          Administration, and the associated enforcement/compliance agencies on the federal and state level,
          the Consultation Service does not issue fines or penalties.  Since the same regulations are covered,
          the service allows the employer to benefit from the professional assistance, without fines being
          imposed.

          What does your service cost and who is eligible?

          The Occupational Health & Safety Bureau (OHSB) offers consultation services free of charge to
          New Mexico employers with 250 or less employees on location or 500 statewide.  Limited  services
          are available to larger companies.  Consultation is offered only at the request of an employer.

          What types of places do you visit?

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The extent of the OSHA Act is to protect employees in all places of work.   These include machine
shops, hospitals, offices, chemical manufacturing plants etc. The consultation program is designed
to assist employers (especially small employers) in complying with the requirements of OSHA
regulations.  We therefore, visit any place of employment that has employees.

Where does the Consultation Service get its funding?

The program receives funding from both the federal and the state government.

How long does the consultation process take?

Depending on the size of the company and the scope of the visit, a consultation may take anywhere
from one or two hours to a full day. If exposure monitoring is requested or recommended, another
day is often scheduled.

What kinds of things do you look at?

In order to evaluate the systems in place, sufficient information from the employer may be needed.
This would include assessing existing safety and health programs, the OSHA 200 logs, accident
investigation reports, and a walk-through of the facility to identify potential injury and illness hazards
in the workplace.

Do we have to let you in all areas?

You, the employer makes that determination.  If you requested a comprehensive survey, the
consultant will look at all areas.

Can it be arranged for both the safety and the industrial hygiene visits to be conducted on
the same day?

Visits are scheduled based on the caseload of the consultants. Where the caseloads
permit such an arrangement can be made.

Do I (the employer) have to fix everything you find?

The employer is obligated to correct all serious hazards found by the consultant, within a
reasonable time frame.  Time extensions are granted for abatement of hazards when needed, if the
employer is providing interim protection for employees.

How are hazards classified as "serious" &  "other than serious"?

A serious violation results where there is substantial probability that death or serious physical harm
could result.  An other than serious violation is a hazard that has a direct relationship to job safety
and health, but probably would not cause death or serious physical harm.

How much will it cost to correct/fix the hazards identified?

Usually, it is not prohibitively costly to correct hazards identified by our consultants.
However, where cost becomes an overriding consideration or where the employer can show that
engineering controls are not feasible the employer may seek a variance from OHSB.  In this case
the employer must show that a combination of work practices, administrative controls, and personal
protective equipment will provide equal or better protection for the employees.

Do you come back to verify hazard correction?

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For regular consultation visits, a statement of assurance of correction for each hazard is usually
acceptable. For special program consultations (SHARP) a follow-up visit is usually conducted to
verify correction of hazards.

How do we request an extension of time on corrections?

All extensions have to be requested in writing. The letter should include the reason for the
extension, what has been done to date to correct hazards; and if corrections have not been made,
the employer must state what interim measures have been taken to protect the employees.

What is the SHARP Program all about?

SHARP or Safety and Health Achievement Recognition Program is one of our special programs for
companies wishing to  go the extra mile to establish a fully functional  overall safety and health
program, in addition to the correction of hazards. SHARP is primarily a recognition program for
exemplary companies, but an added incentive for SHARP participants is a one-year exemption from
OHSB's general schedule inspections.

Does Sharp keep OHSB enforcement out in all cases?

    No, At SHARP sites, OHSB will continue to make inspections in the following situations:
       imminent danger;
       fatality/catastrophe;
       formal  complaints;
       referral from other government agencies; or
       follow-up on previously cited violations.

Where can I get information on establishing written programs (i.e. blood borne pathogen,
hazard communication, confined space, etc?

Many of the safety and health programs are available through the New Mexico Occupational Health
& Safety Consultation  Program. They are available upon request.

How do we know which elements of the safety and health program requirements need to be
fixed, if it doesn't show up on your report to us?

It is addressed in the safety & health program management section of the report the employer
receives. These issues are also discussed by the consultant with the employer.

Is it necessary to have a written certification of hazard assessment at work sites that do not
require (PPE) Personal Protective Equipment for any task?

Yes, according to 1910.132(d)(2), the employer shall verify that the required workplace hazard
assessment has been performed through a written certification that identifies the workplace
evaluated.

Can you come to our company and conduct a class or safety meeting?

Onsite training and education by consultants will be based on available resources and the
employers request. The training and education will be tailored to the nature of the hazards or
potential hazards in each specific workplace.  Training in specific areas is also available through
private consultants and the New Mexico Workers Compensation Administration or your insurer.

Can the consultant come back for specific things such as checking new equipment or
processes that we bring on line?

-------
Yes, Visits for specific purposes can be requested, in addition to regular consultation visits.

May I call your office anytime to ask questions?

Consultants are available to answer questions between 7-5pm Monday-Friday

Can anyone gain access to my report?

No, our files are confidential and are destroyed after 3 years.

Will a consultation visit lead to an inspection by OSHA compliance? Will your findings be
passed on them?

All information is kept confidential.  OHSB compliance inspectors cannot discover where we have
been and then inspect those companies. The only time enforcement is contacted, is if a company
neglects to correct serious hazards beyond time extensions. Then we are obligated to refer those
items to enforcement, but only after we  have made every attempt to work with the company.

What determines when a compliance inspection is going to occur? How do they decide
whom they are going to visit?

Factors that may trigger a compliance inspections include:
      formal complaints by employees or their authorized agents;
      fatalities;
      catastrophe or major incidents;
      history of the company (previous OSHA activity);
      referral by other governmental agencies;
      general schedule inspections; or
      special emphasis programs

Have you been or will you go to my competitor?

Our service extends to all eligible companies who request it. All information is kept confidential;
therefore, no hazards, or processes that may be a trade secret, seen in your facility will be
discussed in another place of business.

Where can I get a copy of the regulations?

The Government  Printing Office (GPO)  processes all sales and distribution of the CFR.  For
payment by credit card, call (202) 512-1800, M-F, Sam to 4 pm or fax your order to (202) 512-2250,
24 hours a day. For payment by check, write to the Superintendent of Documents, Attn: New
Orders, PO Box 371954, Pittsburgh, PA 15250-7954. Regulations and other material are available
on the Internet at  www.osha.gov.

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Previously Released  EPA Publications
  Waste Minimization Opportunity Assessment Manual (EPA/625/7-88/003)




  Facility Pollution Prevention Guide (EPA/600/R-92/088)
                                    Back to Manuals Page

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Other P2  Manuals
  Department of Energy P2 Manual




  EPA Federal Facility P2 Planning Guide




  Canadian P2 Handbook




  Joint Services P2 Opportunity Handbook  WWW




  State of Texas P2 Manual




  State of Minnesota P2 Manual




  State of Ohio P2 Manual




  State of Washington P2 Manual




  Kentucky Development of a P2 Plan




  Air Force Materiel Command - Compliance Through Pollution Prevention
Back to Manuals Page

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P2   Manuals
     The U.S. Environmental Protection Agency (EPA) has published two P2
     manuals prior to the publication of this Guide. Both of these publications are
  available on this CD-ROM. In addition, a link is provided to an electronic version
  of this EPA manual. A number of other excellent P2 manuals and sample P2 plans
  are also available to help guide an organization that seeks to follow Chapter 8 in
  the Guide and prepare its own unique P2 program.
      Back HOME
Prev. Released EPA Manuals
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Management
                     Environmental
     v                 — —
   \           j      Management
  Checking   Implementation
  Corrective
   Action
                     Systems
Home EMS FAQs  ISO 14001 Information I EMS Design Tools I Sector-Specific Information I EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
EMS  Case Studies

  • Novozymes, North America Inc.
    December 2000 - three pages
  • Philips Communication Security Imaging Inc.
    December 2000 - two pages
  • Gastonia Wastewater Treatment Division
    January 2001 - two pages
  • U.S. Postal Service
    November 1999 -  12 pages
  • Saturn and five of its suppliers
    describes efforts of automobile manufacturer Saturn and five of its suppliers in Tennessee to implement an
    EMS as part of a pilot program of the Tennessee Manufacturing Extension Program. Lessons learned, benefits
    and costs of implementation - Fall 1999 - eight pages
  • Printed Wiring Board Case Study 7 - Identifying Objectives for Your Environmental Management Systems
    Materials
    6/99 - six pages
  • Printed Wiring Board Case Study 8 - Building an Environmental Management System: H-R Industries'
    Experience
    6/99 - six pages
  • IBM's Experience Implementing ISO 14001 on a Global Basis: Does ISO 14001 Achieve Its Intended Goals?
    2/99 - FELSEF Newsletter - seven pages
  • Environmental Management System Demonstration Project
    This final report on NSF International's Environmental Management System (EMS) Demonstration Project
    summarizes the EMS implementation experiences of 18 organizations of a variety of types and sizes. The
    goals of the project were to: (1) document the experiences of a variety of organizations as they attempted to
    develop an EMS based on ISO 14001; (2) demonstrate the benefits and challenges of, and incentives for, EMS
    implementation; (3) determine what types of tools and assistance organizations need to be successful with

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      EMS implementation; and (4) provide a forum for organizations to learn from each others' EMS experiences.
      12/96- 112 pages

      The following are workshop presentations available in both PowerPoint and HTML:
   •  IBM's Environmental Management System by Susan Clarke
   •  Dawn B. Sudmeyer, Camp Lejeune
   •  David Rachels, Exide Electronics Large System Group
   •  Doug Gaylord, Honda Power Equipment Manufacturing Inc.
   •  Matt Caton, Lufkin/CooperTools, Apex, N.C.
   •  Sean Bir, Konica Manufacturing USA Inc.
   •  Environmental Management System Development and Implementation by Don E. Carmichael, City of
      Gastonia Wastewater Treatment Division
   •  ISO 14001 Management Perspective by Bob Danhauser, Charleston Commissioners of Public Works
   •  Covered Anaerobic Digester: Case Study  from Barham Farm by Julian Barham
Home EMS FAQs  ISO 14001 Information | EMS Design Tools | Sector-Specific Information | EMS Case Studies
 Workshop Presentations  Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links  Hot Topics
                                    Please provide your opinion of this site
                          Environmental Management Systems Home Page. This page was last modified on 04/09/2001.
                             Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                       1639 Mail Service Center - Raleigh NC 27699-1639
                                       (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                              Pollution prevention or EMS question or comment? Send e-mail to:  Beth Graves
                                  Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

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Management
  Review
  Checking
  Corrective
   Action
  Pbnning
    f
Implementation
Environmental
 Management
Systems
          EMS FAQs
          Answers to common questions
          about EMS
                    ISO 14000 Information
                    Detailed information about ISO
                    14000 including a list and
                    description of the standards,
                    components of ISO 14001 and
            information on how to purchase the standards
          EMS Design Tools
          Technical assistance in planning
          and implementing an EMS
                    EMS Case Studies
                    Experiences from companies
                    implementing an EMS
          Workshop Presentations
          Presentations about EMS
                    Articles and Reports
                    Publications regarding EMS
                               ssiF
          North Carolina ISO 14001
          Certified Facilities
          Complete list of state facilities
          certified to ISO 14001
                     North Carolina Pilot Program
                     Project involving North Carolina
                     agencies, the EPA and several
                     North Carolina companies that
                     aims to evaluate the effectiveness
                              of an EMS
          Links
          Links to useful Web sites
                     Hot Topics
                     Calendar, upcoming workshops
                     and latest news
An Environmental Management System (EMS) is a tool that provides organizations with a method to systematically

-------
manage their environmental activities, products and services and helps an organization achieve its environmental
obligations and performance goals. An EMS follows a Plan-Do-Check-Act Cycle, or PDCA, and is a model that can
be used by a wide range of organizations from manufacturing facilities to service industries and government
agencies. Many organizations have chosen to adopt an EMS based on the international voluntary standard ISO
14001.

This site serves to provide background and technical information regarding the ISO 14000 family of standards, ISO
14001 and Environmental Management Systems.
                                       Please provide your opinion of this site
                            Environmental Management Systems Home Page. This page was last modified on 04/04/2001.
                               Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                          1639 Mail Service Center - Raleigh NC 27699-1639
                                         (919) 715-65007(800) 763-0136 - fax (919) 715-6794
                                Pollution prevention or EMS question or comment? Send e-mail to:  Beth Graves
                                    Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

-------
Management
               Environmental
    v            — —
  \       j    Management
  Checking   Implementation
  Corrective
  Action
              Systems
Home EMS FAQs ISO 14001 Information I EMS Design Tools I Sector-Specific Information I EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
EMS Frequently Asked Questions

What is the definition of an Environmental Management
System (EMS)?
What is the EMS Model?
What are some key elements of an EMS?
What are ISO, ISO 14000 and ISO 14001?
How are these standards developed? What are the 17
elements of the ISO 14001 Standard?
What are some of the potential benefits of an EMS based
on ISO 14001?
Can existing environmental management activities be
integrated into the EMS under 14001?

What is the definition of an Environmental Management
System (EMS)?
  • Serves as a tool to improve environmental performance
  • Provides a systematic way of managing an organization's environmental affairs
  • Is the aspect of the organization's overall management structure that addresses immediate and long-term
   impacts of its products, services and processes on the environment

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   • Gives order and consistency for organizations to address environmental concerns through the allocation of
     resources, assignment of responsibility and ongoing evaluation of practices, procedures and processes
   • Focuses on continual improvement of the system
What is the EMS  Model?

     An EMS follows a Plan-Do-Check-Act Cycle, or PDCA. The
     diagram shows the process of first developing an environmental
     policy, planning the EMS, and then implementing it. The process
     also includes checking the system and acting on it. The model is
     continuous because an EMS is a process of continual improvement
     in which an organization is constantly reviewing and revising the
     system.
     This is a model that can be used by a wide range of organizations —
     from manufacturing facilities to service industries and government
     agencies.

What are some key elements of an
EMS?
    EMS Model
          Policy
 \
Checking
Corrective
  Adion
                 Panning
Empletmenfafion
   • Policy Statement - a statement of the organization's commitment to the environment
   • Identification of Significant Environmental Impacts - environmental attributes of products, activities and
     services and their effects on the environment
   • Development of Objectives and Targets - environmental goals for the organization
   • Implementation - plans to meet objectives and targets
   • Training - ensure that employees are aware and capable of their environmental responsibilities
   • Management Review
What are  ISO, ISO 14000 and  ISO 14001?
     ISO stands for the International Organization for Standardization, located in Geneva, Switzerland. ISO
     promotes the development and implementation of voluntary international standards, both for particular
     products and for environmental management issues. ISO 14000 refers to a series of voluntary standards
     in the environmental field under development by ISO. Included in the ISO 14000 series are the ISO
     14001 Environmental Management System (EMS) standard and other standards in fields such as
     environmental auditing, environmental performance evaluation, environmental labeling and life-cycle
     assessment.
How are these standards developed?
     All the ISO standards are developed through a voluntary, consensus-based approach. ISO has different
     member countries across the globe. Each member country develops its position on the standards and
     these positions are then negotiated with other member countries. Draft versions of the standards are sent
     out for formal written comment and each country casts its official vote on the drafts at the appropriate
     stage of the process. Within each country, various types of organizations can and do participate in the
     process. These organizations include industry, government (federal and state), and other interested

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     parties, like various non-government organizations (NGOs). For example, EPA and states participated in
     the development of the ISO 14001 standard and are now evaluating its usefulness through a variety of
     pilot projects.

What are  the 17  elements  of the ISO 14001 Standard?

   • Environmental Policy - develop a statement of the organization's commitment to the environment
   • Environmental Aspects and Impacts - identify environmental attributes of products, activities and services
     and their effects on the environment
   • Legal and Other Requirements - identify and ensure access to relevant laws and regulations
   • Objectives and Targets - set environmental goals for the organization
   • Environmental Management Program - plan actions to achieve objectives and targets
   • Structure and Responsibility - establish roles and responsibilities within the organization
   • Training, Awareness and Competence - ensure that employees are aware and capable of their environmental
     responsibilities
   • Communication - develop processes for internal and external communication on environmental management
     issues
   • EMS Documentation - maintain information about the EMS and related documents
   • Document Control - ensure effective management of procedures and other documents
   • Operational Control - identify, plan and manage the organization's operations and activities in line with the
     policy, objectives and targets
   • Emergency Preparedness and Response - develop procedures for preventing and responding to potential
     emergencies
   • Monitoring and Measuring - monitor key activities and track performance
   • Nonconformance and Corrective and Preventative Action - identify and correct problems and prevent
     recurrences
   • Records - keep adequate records of EMS performance
   • EMS Audit - periodically verify that the EMS is effective and achieving objectives and targets
   • Management Review - review the EMS

What are  some of the potential  benefits of an  EMS based
on ISO 14001?

   • Improvements in overall environmental performance and compliance
   • Provides a framework for using pollution prevention  practices to meet EMS objectives
   • Increased efficiency and potential cost savings when  managing environmental obligations
   • Promotes predictability and consistency in managing environmental obligations
   • More effective targeting of scarce environmental management resources
   • Enhances public posture with outside stakeholders
   • Gives competition/trade advantages
   • Increases employee morale
   • Enhances the company's image with regulators
   • Reduces insurance rates

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     Workshop presentations discussing the benefits of an EMS - available in PowerPoint and HTML or PDF
     form:
        • Ford Motor Company by Bob Devlin and Gary Davis
        • Ford - Norfolk Assembly Plant by Gary Davis
        • Mercedes-Benz U.S. International Inc. by Mark L. Warner
        • NCI Inc. by Jack Rockstad
        • Purolator Products Inc. by Steve Ross
        • Benefits of an EMS to a Local Government by Steve Shoaf, et al., City of Burlington
        • Eaton - Cutler-Hammer: Gaining Competitive Advantage Through Environmental Management
           System by Jim Takac


Can  existing environmental management activities  be

integrated into the  EMS  under 14001?

     Yes. The standard is flexible and does not require organizations to necessarily "retool" their existing
     activities. The standard establishes a management framework by which an organization's impacts on the
     environment can be systematically identified and  reduced. For example, many organizations, including
     counties and municipalities, have active and effective pollution prevention activities underway. These
     could be incorporated into the overall EMS under ISO 14001.
Home  EMS FAQs  ISO 14001 Information | EMS Design Tools | Sector-Specific Information | EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities  N.C. Pilot Program  Links  Hot Topics


                                Please provide your opinion of this site
                       Environmental Management Systems Home Page. This page was last modified on 06/07/2001.
                          Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                   1639 Mail Service Center - Raleigh NC 27699-1639
                                   (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                           Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                              Site question or comment? Send e-mail to: Webmaster(a!p2pavs.org

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            N    Environmental
   eview        Plannin9   _ —i
   \          j     Management
Policy
   •>


    Planning
   Checking   Implementation
   Corrective
    Action
           Systems
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ISO 14000 Information


General Information

Requirements of the ISO 14000 Family of Standards

How to Purchase the Standard


General Information

   ISO stands for the International Standards Organization, located in Geneva, Switzerland. ISO is a
   non-governmental organization established in 1947. The organization mainly functions to develop
   voluntary technical standards that aim at making the development, manufacture and supply of goods and
   services more efficient, safe and clean.

   ISO 14000 refers to a family of voluntary standards and guidance documents to help organizations address
   environmental issues. Included in the family are standards for Environmental Management Systems
   (EMS), environmental and EMS auditing, environmental labeling, performance evaluation and life-cycle
   assessment.

   In September 1996, the International Organization of Standardization (ISO) published in final form ISO
   14001, the Environmental Management Systems standard. This is an international voluntary standard
   describing specific requirements for an EMS. ISO 14001 is a specification standard to which an
   organization may receive certification or registration. ISO 14001 is considered the foundation document of
   the entire series.

Requirements of the Final Adopted  International  Standard

in the ISO 14000 Family

-------
ISO 14001
Environmental Management Systems - Specification with Guidance for Use

ISO 14004
Environmental Management Systems - General Guidelines on Principles, Systems and Supporting
Techniques

ISO 14010
Guidelines for Environmental Auditing - General Principles on Environmental Auditing*

ISO 14011
Guidelines for Environmental Auditing - Audit Procedures - Auditing of Environmental Management
Systems*

ISO 14012
Guidelines for Environmental Auditing - Qualification Criteria for Environmental Auditors*

ISO 14020
Goals and Principles of All Environmental Labeling

ISO 14021
Environmental Labels and Declarations - Self-Declaration Environmental Claims - Terms and Definitions

ISO 14024
Environmental Labels and Declarations - Type 1 - Guiding Principles and Procedures

ISO 14025
Type 3 Eco-Profile Labeling Technical Report

ISO 14031
Environmental Management - Environmental Performance Evaluation - Guidelines

ISO 14032
Environmental Management - Environmental Performance Evaluation- Case Studies Illustrating the Use of
ISO 14031 Technical Report

ISO 14040
Environmental Management - Life Cycle Assessment - Principles and Framework

ISO 14041
Environmental Management - Life Cycle Assessment - Goal and Scope Definition and Inventory Analysis

ISO 14042
Environmental Management - Life Cycle Assessment - Impact Assessment

ISO 14043
Environmental Management - Life Cycle Assessment - Interpretation

ISO 14049
Environmental Management - Life Cycle Assessment - Examples of Application of ISO 14041 to Goal and
Scope Definition and Inventory Analysis Technical Report

-------
        ISO 14050
        Terms and Definitions - Guide on the Principles for Terminology Work
        ISO 14061
        Information to Assist Forestry Organizations in the Use of Environmental Management System Standards
        ISO 14001 and ISO 14004 Technical Report
        * It should be noted that a new standard, ISO 19011, is in development and once adopted, will replace ISO 14010, ISO 14011, and ISO 14012. It is anticipated that ISO
        19011 will be a final standard by 2001.
How to Purchase  the  Standard

      Within the United States, the American National Standards Institute (ANSI), the American Society for
      Quality (ASQ), and NSF International make the final published ISO 14000 standards available to the
      public. All standards are under copyright; therefore you must purchase the standard from one of the
      organizations below.
         •  NSF
            ISO 14001 ($42), ISO 14004 ($52)*
         •  ASQ
            ISO 14001 ($38.50), ISO  14004 ($49.50), set of three including ISO 14001, ISO 14004 and ISO
            14010 ($49.75), entire ISO 14000 series ($129)*
         •  ANSI
            ISO 14001 ($53), ISO 14004 ($85)*
            * Prices quoted June 2000
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                           Environmental Management Systems Home Page. This page was last modified on 04/03/2001.
                              Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                        1639 Mail Service Center - Raleigh NC 27699-1639
                                       (919) 715-65007(800) 763-0136 - fax (919) 715-6794
                               Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                                   Site question or comment? Send e-mail to: Webmaster(g),p2pays.org

-------
       Policy
 Management
  Review
   \
  Checking  Implementation
  Corrective
   Action
       Environmental
   J  Management
       Systems
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EMS Design Tools
      r& Sample Gap Analysis
               Design and
               Implementation
Integrating Your
QMS and EMS
^ Sample Policy
^^^^ Statement


Internal and
~^^*r External
Communication

^•^^ Aspects and Impacts
**-*t
Internal Auditing,
* %fc> ... Management Review
^" and Corrective
Action
*^» Legal Requirements

Sample EMS
_^^"- Manuals and
^^ Procedures


Common Areas of
Non-Conformance
                      Simplify the EMS
                                     Additional Resources
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-------
              Please provide your opinion of this site
Environmental Management Systems Home Page. This page was last modified on 04/03/2001.
   Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                  1639 Mail Service Center - Raleigh NC 27699-1639
                 (919) 715-65007(800) 763-0136 - fax (919) 715-6794
     Pollution prevention or EMS question or comment? Send e-mail to:  Beth Graves
           Site question or comment? Send e-mail to: Webmaster(gjp2pavs.org

-------
Management
                 Environmental
    v              — —
   \         j     Management
  Checking   Implementation
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   Action
                 Systems
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EMS Sector-Specific Information

  • Agriculture
     O Pork Production
  • Furniture and Wood Finishing
  • Fleet Operations
  • Metal Finishing
  • Publicly Owned Treatment Works (POTWs)
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                   Please provide your opinion of this site
              Environmental Management Systems Home Page. This page was last modified on 05/18/2001.
               Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                    1639 Mail Service Center - Raleigh NC 27699-1639
                    (919) 715-65007(800) 763-0136 - fax (919) 715-6794
                Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                  Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

-------
Management
                      Environmental
      v                 — —
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   Corrective
   Action
                     Systems
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EMS Workshop Presentations

This page lists EMS workshops or presentation sponsored by the N.C. Division of Pollution Prevention and
Environmental Assistance (DPPEA) or its staff. Each workshop has unique presentations on specific EMS topics.
There is a variety of information provided by companies, local governments, auditors, consultants and others
involved in design and implementation of an EMS.

  • Strategies for Governmental EMS (Environmental Management System) Workshop
    Gastoma, N.C., Jan. 31, 2001
    Topics Include: EMS/ISO 14001 design and implementation, the National Biosolids Partnership, and case
    studies from two local governments

  • Environmental Management Systems and Enforcement
    Raleigh, Jan. 24-25, 2001

  • Developing an Environmental Management System (EMS) Approach for Agriculture and Agribusiness
    Raleigh, Dec. 18,2000
    Topics Include: EMS basics, EMS in agriculture and agribusiness, existing North Carolina management
    requirements for animal waste systems, and case studies from industry.

  • Regulatory Innovation: EMSs as Environmental Regulatory Tools
    presented by Jason Morrison at Roundtable on EMS for Non-Governmental Organizations (NGOs), Raleigh,
    May 22, 2000

  • ISO 14001 EMS: The Nuts and Bolts of Getting It Done
    Asheville, May 10, 2000; Greenville, May 23, 2000; Kernersville, May 25, 2000
    Topics Include: Benefits of an EMS, EMS design, integrating QS/ISO 9000 and ISO 14001, common areas of
    non-conformancies, continual improvement and cost and benefits of an EMS

  • Environmental Management Systems: North Carolina's Approach
    presented by Gary Hunt at Carolinas Environmental Conference, Charlotte, Sept. 10, 1999

  • EMS Models and Strategies: ISO 14001 and Beyond
    Charlotte, Aug. 24, 1999

-------
      Topics Include: Benefits of an EMS, EMS design, continual improvement and experiences from industry

   •  Pilot Project Implementation Workshop
      Gary, May 14-15, 1998
      Topics Include: Information about the Multi-State Working Group and the Pilot Project and information from
      five different companies that participated in the Pilot Project

   •  ISO 14001 Environmental Management Systems Workshop for Non-Governmental Organizations and
      Academic Researchers
      Chapel Hill, May  13, 1998
         O  Agenda
         O  Speaker's Presentation: Beth Graves, N.C. DPPEA
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                                     Please provide your opinion of this site
                           Environmental Management Systems Home Page. This page was last modified on 05/17/2001.
                             Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                        1639 Mail Service Center - Raleigh NC 27699-1639
                                        (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                               Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                                   Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

-------
Management
                 Environmental
    v              — —
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   Action
                 Systems
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EMS Articles and Reports


General Information

Public Policy and EMS

North Carolina EMS Pilot Program

General Information:

  • The ISO 14000 Family of Standards: Environmental Management Systems
   August 1999 - 3 pages
  • EMS Can Improve Economic and Environmental Performance
   December 1996 - 2 pages - FOCUS: Waste Minimization
  • Environmental Non-Governmental Organizations and Environmental Management Systems: North Carolina
   Groups Share Their Views
   July 2000
  • Implementing ISO 14001 Environmental Management Systems at the Municipal Level
   October 1998-3 pages
  • Implementation Guide for the Code of Environmental Management Principles for Federal Agencies (CEMP)
   June 1998
  • Final Report: The US EPA Environmental Management System Pilot Program for Local Government Entities
   January 2000 - 136 pages
Public Policy and EMS:
  • Improving Environmental Performance and Compliance: 10 Elements of Effective Environmental
   Management Systems

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     This document represents the first joint statement from Canada, Mexico and the United States on how
     voluntary EMS designed for internal management purposes can also serve the broader public policy goals of
     compliance assurance and improved environmental performance in regulated and non-regulated areas. The
     guidance document focuses on only two public policy issues: compliance assurance and improved
     environmental performance in regulated and non-regulated areas. - 6/00 - 9 pages
     N.C. DENR Policy on EMS/ISO 14001
     August 1999 - 2 pages
     Second Generation of Environmental Improvement Act of 1999
     This proposed bill, HR 3448, is "an act to improve the management of environmental information and to
     encourage innovation in the pursuit of enhanced environmental quality, and for other purposes." - Nov. 18,
     1999-32 pages
     Legal Issues With EMS Implementation & Registration
     What are the legal ramifications of a registered ISO 14001 EMS, vis-a-vis the U.S. Environmental Protection
     Agency  (EPA) and its state counterparts? Will ISO 14001 offer protection, or offer evidence against a
     company's environmental dealings? By Jim Kolka
     Summary of State Innovation Laws and EMS
     Aug. 16, 1999-2 pages
     State Performance Track Programs
     Describes the characteristics of State Performance Track Programs
     Summary of ISO 14001 State Activity
     Provides an overview of state activities relating to EMS. - November 1998 - 14 pages
     EPA Performance Track
     The National Environmental Performance Track is a new program designed to motivate and reward top
     environmental performance by companies and facilities of all types - public and private.
     EPA Press Release: June 26, 2000
     "Cooperative Effort With Business Will Reward Higher Environmental Performance"
     "EPA Position Statement on Environmental Management Systems and ISO 14001 and a Request for
     Comments on the Nature of the Data To Be Collected from Environmental Management System/ISO 14001
     Pilots"
     Federal Registrar Notice - March 12, 1998
     Six Companies Participate in Environmental Management Systems Pilot Project Program
     November 1998 - 8 pages - FOCUS: Waste Minimization
North  Carolina EMS Pilot Program:
     Six Companies Participate in Environmental Management Systems Pilot Project Program
     The N.C. Department of Environment and Natural Resources (DENR), with the Division of Pollution
     Prevention and Environmental Assistance (DPPEA) as the lead agency, is closely evaluating the effectiveness
     of an EMS in improving environmental performance and compliance as well as pollution prevention. This
     evaluation is being performed through an internal DENR EMS working group that has partnered with six
     companies and one federal facility. 11/98 - 8 pages - FOCUS: Waste Minimization
     Multi-State Working Group on Environmental Management Systems Research Roundtable Process
     Describes the process used to identify a research strategy for the National Database on Environmental
     Management Systems.
     EPA and State Regulatory Framework for EMS Pilot Projects
     May 14, 1998 - 1 page

-------
      Press Release
      Release of EMS Database and Analysis of Baseline Data from 50 Facilities - 6/5/00
Home  EMS FAQs  ISO 14001  Information | EMS Design Tools | Sector-Specific Information | EMS Case Studies
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                                         Please provide your opinion of this site
                             Environmental Management Systems Home Page. This page was last modified on 06/07/2001.
                                Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                            1639 Mail Service Center - Raleigh NC 27699-1639
                                           (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                                  Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                                      Site question or comment? Send e-mail to: Webmaster(a!p2pavs.org

-------
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   \
  Checking
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   Action
   ^
Implementation
Environmental
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Systems
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ISO 14001 Certified Facilities in North Carolina


The information presented was last updated on June 7, 2001 and is correct as to our knowledge. If you are aware of an
organization that is certified to ISO 14001 in North Carolina that does not appear on this list or if you have any
corrections to this list, please call Beth Graves, (919) 715-6506 or (800) 763-0136 or e-mail at
Beth.Graves@ncmail.net
No.

1




2
3
Facility Name




New Breed Leasing
Corp.

Lockheed Martin
Electronics
Matsushita
Compressor Corp.

Site
Location


Greensboro

Fayetteville
Mooresville
SIC
Code


4214

3761

3563
Single or
Multiple
Site
Registration
Single

Multiple - covered
by Orlando, FL
office registration

Single
Date
Certified


10/10/97

12/4/97
12/17/97
Registrar


INTERTEK

British
Standards
Institution
(BSI)
ABS Quality
Evaluations
Inc.

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4
5

6

7

8
9
10

11
12
ASMO North
Carolina Inc.
ASMO North
Carolina Inc.

ASMO North
Carolina Inc.

Allergan Lenoir

IBM
Konica
Manufacturing USA
Inc.
International Paper -
Forest Resources
Division, Eastern
Region

ABB Combustion
Engineering
ASMO Greenville of
N.C. Inc.
Statesville
Mount Airy

Thomasville

Lenoir

Research
Triangle Park
Whitsett
North Carolina

Kings
Mountain
Greenville
3621
3621

3621

3827

3571
3861
0811

3567
3621
Multiple -
includes Mount
Airy and
Thomasville sites
Multiple -
includes
Statesville and
Thomasville sites
Multiple -
includes Mount
Airy and
Statesville sites

Single

Multiple - covered
by global
corporate
registration
Single
Multiple

Single
Single
1/22/98
1/22/98

1/22/98

2/10/98

6/9/98
7/29/98
9/1/98

10/20/98
10/28/98
Det Norske
Veritas
(DNV)
DNV

DNV
National
Standards
Authority of
Ireland
(NSAI)
Bureau of
Veritas
Quality
International
Inc. (BVQI)
Quality
Management
Institute
(QMI)
BVQI
Advanced
Waste
Management
Systems Inc.
DNV

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13

14
15
16
17

18

19
20

21

22
23
Chicago Rawhide
Manufacturing
Universal
Manufacturing and
Logistics (formerly
Polygram)
Kyocera Industrial
Ceramics Corp.
Philips
Communication
Security & Imaging
Inc.
Purolator Products
Inc.

NCI Inc.

Uniroyal Chemical
Co.
Eaton- Cutler
Hammer - Asheville
Plant

United Chemi-Con
Inc.

Crompton
Manufacturing
Company Inc.
DJB Construction
Group (Beers
Construction
Company)
Franklin

Grover
Mountain
Home
Winston-Sal em
Fayetteville

Asheville

Gastonia
Arden

Lansing

Gastonia
Raleigh
3053

3652
3299
3669
3714

3462

2821
3613

3675

2821
1629
Multiple - covered
by registration of
parent company in
Gothenburg,
Sweden

Single
Single
Single
Single

Single

Single
Single

Single


Multiple - covered
by Atlanta, GA
office registration
11/1/98

1/19/99
2/12/99
4/26/99
5/8/99

6/7/99

6/21/99
6/23/99

6/24/99

7/21/99
8/25/99
Lloyd's
Register
Quality
Assurance

BSI
BSI
NSAI
BVQI
Performance
Review
Institute
(PRI)
QMI
DNV
National
Quality
Assurance
USA Inc.
(NQA)
QMI
REMA
Registered
Quality Inc.

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24
25
26
27
28
29
30
31
32
33
34
35
36
Beers Construction
Company
Eaton Corp. Actuator
and Sensor Division
Firestone Fibers and
Textiles Co.
Bridgestone/Firestone
Inc.
Hurst Jaws of Life (a
umtoflDEX
Corporation)
Nortel Networks
Carrier Solutions
Eaton Corporation
Clutch Division
Nortel Networks:
Real Estate - Raleigh
ABB Automation
Inc.
Mayville Metal
Products
Carolmet Cobalt
Products
Cutler-Hammer
Power and Control
Systems
SCI Systems Inc.
Charlotte,
Winston-Sal em
and Raleigh
Sanford
Kings
Mountain
Wilson
Shelby
Research
Triangle Park
Harrisburg
Morrisville
Raleigh
Creedmoor
Maxton
Fayetteville
Graham
1629
3822
2296
3011
3546
3661
3714
6512
3825
3499
2819
3625
3672
Multiple - covered
by Atlanta, GA
office registration
Single
Single
Single
Single
Single
Single
Single
Single
Multiple - with
Wisconsin and
Arizona facilities
Single
Single
Single
8/25/99
9/30/99
10/1/99
10/22/99
11/5/99
11/19/99
12/1/99
12/3/99
1/28/00
3/1/00
3/16/00
3/23/00
4/28/00
REMA
Registered
Quality Inc.
NSF-ISR
Lloyd's
Register
Quality
Assurance
Lloyd's
Register
Quality
Assurance
Underwriters
Laboratories
Inc. (UL)
QMI
DNV
QMI
UL
UL
BVQI
DNV
NSAI

-------
37
38
39
40
41
42
43
44
45
46
47
48
49
Novozymes North
America Inc.
C-Mac Network
Systems Inc.
Eaton Corporation
Eaton Corporation
BASF Automotive
OEM and Industrial
Coatings
Intek Inc.
GKN Automotive
Inc., Alamance
Facility
Square D - Schneider
Electric
NACCO Materials
Handling Group Inc.
Saturn Electronics
and Engineering
Dana Corporation,
Spicer Heavy Axle
and Break Division
Square D Company
Carroll's Foods
Franklinton
Creedmoor
Roxboro
Kings
Mountain
Morganton
Aberdeen
Mebane
Asheville
Greenville
Rocky Mount
Morganton
Knightdale
Warsaw
2869
3661
3714
3714
2851
2221
3714
3699
3537
3679
3714
3625
2048
Single
Single
Single
Single
Single
Single
Single
Single
Single
Single
Single
Single
Multiple - N.C.
company-owned
farms covered by
division
registration
5/15/00
6/8/00
6/9/00
7/3/00
9/20/00
10/3/00
1/10/01
1/17/01
1/19/01
1/23/01
2/21/01
2/28/01
3/21/01
UL
QMI
DNV
Perry
Johnson
Registrars
Inc.
ABS
UL
UL
UL
UL
Entella Inc.
UL
UL
SGS
International
Certification
Services Inc.
(SGS ICS)

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50
51
52
53
54
Nortel Networks
Central Distribution
Center
Nortel Networks
Plaza Distribution
Center
Hyster Company
Yale Materials
Handling
Cooperation
The Wesbell Group
of Companies Inc.
Gary
Morrisville
Greenville
Greenville
Durham
3661
3661


5093
Single
Single


Single
4/19/01
4/19/01
4/25/01
4/25/01
5/18/01
QMI
QMI
UL
UL
QMI
Note: The N.C. Department of Environment and Natural Resources supplies this list of ISO 14001-certified companies
as a public service. Inclusion on this list does not represent endorsement by the department.
  Home I EMS FAQs I ISO 14001 Information  EMS Design Tools  Sector-Specific Information I EMS Case Studies
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                                         Please provide your opinion of this site
                              Environmental Management Systems Home Page. This page was last modified on 06/07/2001.
                                 Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                            1639 Mail Service Center - Raleigh NC 27699-1639
                                            (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                                  Pollution prevention or EMS question or comment? Send e-mail to:  Beth Graves
                                      Site question or comment? Send e-mail to: Webmaster(g),p2pays.org

-------
Management
                   Environmental
     v               —  —
   \          j    Management
  Checking   Implementation
  Corrective
   Action
                   Systems
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North Carolina EMS Pilot Program

General Information
Companies Participating in the Pilot Program
Articles and Press Releases
Data Collection Information
Interested in Participating in the Program?

General Information on the Pilot Program

The N.C. Department of Environment and Natural Resources (DENR), with the Division of Pollution Prevention and
Environmental Assistance (DPPEA) as the lead agency, is closely evaluating the effectiveness of an EMS in
improving environmental performance and compliance as well as pollution prevention.
In addition, DENR's interest in the pilot program is to:
  • Determine if EMS implementation results in improved environmental performance
  • Participate in public policy discussion
  • Encourage pollution prevention
  • Investigate leveraging of DENR resources
  • Encourage "beyond compliance."
  • Develop partnerships between environmental groups, industry, trade associations and academia.
Through this pilot program, DENR hopes to better understand the implementation of an EMS, particularly the ISO
14001 model. DENR's pilot program is being supported by a grant from the U.S. Environmental Protection Agency's
Office of Water. Each pilot participant has agreed to provide data on its environmental performance, compliance,
pollution prevention, environmental conditions, costs/benefits of EMS implementation, and stakeholders

-------
involvement/confidence. These are key areas identified by MSWG for data collection. Baseline data are being
collected from North Carolina pilots as well as about 80 other organizations nationwide. Data are being compiled
into a national database, maintained by the University of North Carolina at Chapel Hill.

Companies Participating in the EMS  Pilot  Program

   • Konica Manufacturing USA: Whitsett, N.C.
   • Novozymes North America Inc. (formerly Novo Nordisk BioChem North America): Franklinton, N.C.
   • Duke Power - Buck Steam Station: Salisbury, N.C.
   • Marine Corps Base Camp Lejeune: Jacksonville, N.C.
   • City of Gastonia - Wastewater Treatment Plant: Gastonia, N.C.
   • City of Burlington - Wastewater Treatment Plant: Burlington, N.C.

Articles and Press  Releases

   • Six Companies Participate in Environmental Management Systems Pilot Project Program
     The N.C. Department of Environment and Natural Resources (DENR), with the Division of Pollution
     Prevention and Environmental Assistance (DPPEA) as the lead agency, is closely evaluating the effectiveness
     of an EMS in improving environmental performance and compliance as well as pollution prevention. This
     evaluation is being performed through an internal DENR EMS working group that has partnered with six
     companies and one federal facility. 11/98 - eight pages - FOCUS: Waste Minimization
   • Multi-State Working Group on Environmental Management Systems Research Roundtable Process
     Describes the process used to identify a research strategy for the National Database on Environmental
     Management Systems.
   • EPA and State Regulatory Framework for EMS Pilot Projects
     May 14, 1998 - one page
   • Press Release
     Release of EMS Database and Analysis of Baseline Data from 50 Facilities - 6/5/00
   • Other EMS Articles not specific to the Pilot Program

Data  Collection  Information

   • Project Summary 2
     The Effects of Environmental Management Systems on the Environmental and Economic Performance of
     Facilities - 6/5/00 - 81 pages
   • Project Summary 1 - National Database on Environmental Management Systems
     The Effects of ISO 14001 Environmental Management Systems on  the Environmental and Economic
     Performance of Organizations
   • Data Categories
     Describes the six primary dimensions focused on by data collection protocols and research
   • Data Collection Protocols
     Describes the three protocols used to collect and compare data from different facilities
   • Glossary for Data Collection
     Provides definitions of terms used in the protocols and data collection

-------
   • Voluntary Project Evaluation Guidance
     Identifies the six key research areas for data collection for the EPA and state research efforts
   • Environmental Law Institute
     Information about the National Database on Environmental Management Systems (NDEMS).
   • Research questions to be addressed through data collected in EMS/ISO 14001 Pilot Projects

Interested  in Participating in the National  Pilot Program?
Home  EMS FAQs  ISO 14001 Information | EMS Design Tools | Sector-Specific Information | EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program  Links Hot Topics
                                  Please provide your opinion of this site
                         Environmental Management Systems Home Page. This page was last modified on 04/09/2001.
                           Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                     1639 Mail Service Center - Raleigh NC 27699-1639
                                    (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                            Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                                Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

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Management
                   Environmental
     v               —  —
   \          j    Management
  Checking   Implementation
  Corrective
   Action
                   Systems
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EMS Links


General EMS and ISO Information

State EMS Web Sites

EMS and Government

EMS and Agriculture

Corporate Environmental Reports


General EMS and ISO Information

  • ISO Support Group
   The ISO Support Group, a chapter of the American Society for Quality (ASQ) Raleigh Section 1113, sponsors
   programs in the ISO 9000 and ISO 14000 realm. Meetings are in Research Triangle Park between September
   and May each year. Attendees are typically from nearby companies with similar programs.
  • Multi-State Working Group on Environmental Management Systems (MSWG)
   The mission of this voluntary group of states, EPA, non-governmental agencies, and industries is to understand
   the use of EMS in public policy and its ability to improve the environment.
  • EMS-Plus Environmental Management System Evaluation Tool
   Developed by Research Triangle Institute in Research Triangle Park, N.C. to assist facilities in evaluating an
   EMS based on whether it incorporates components known to promote environmental improvement.
  • U.S. EPA Office of Water - ISO 14001 Information
   The Office of Water has funded a number of projects, including an EMS pilot projects with 10 states, an EMS
   pilot project with municipalities nationwide, and is beginning new projects that focus on EMSs with the
   biosolids industry and a study of the EMS registration process in the United States.
  • ISO 14001 Pilot Projects

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      Official Web site providing information on the ISO 14001 national pilot projects. The site provides a copy of
      database protocols used by facilities, links to various state EMS sites, public reports on the pilot project, etc.
   •  ISO - International Organization of Standardization
      Home page of the international standards body responsible for the development and publication of the ISO
      14000 family and other standards.
   •  American National Standards Institute (ANSI)
      ANSI serves as an administrator and coordinator of the United States voluntary standardization system.
   •  U.S. Standards Group on Quality, Environment, Dependability and Statistics (QEDS)
      The U.S. Standards Group on Quality, Environment, Dependability and Statistics (QEDS) is concerned with
      the development and effective use of generic and sector-specific standards for quality management,
      environmental management, dependability and the application of statistical methods.
   •  Registration Accreditation Board (RAB)
      Web site that provides accreditation services in the United States on the ISO 14001 standard. Maintains a
      current list of accredited registrars and accredited course providers to ISO 14001.
   •  ISO World
      Provides a current total of ISO  14001 registrations by country.
   •  ISO 14001 list serve
      Designed for the discussion of ISO 14000 and EMS design and implementation. Members of the list serve
      include organizations certified to ISO 14001, registrars, consultants, academics and other interested parties. To
      subscribe, send a message to the following address: To subscribe to the ISO14001 list, address an e-mail
      message ONLY to our automated server: majordomo@quality.org with the following text ONLY in the BODY
      of the message: subscribe iso 14000
   •  IESU Online
      International Environmental Systems Update is a newsletter that follows issues related to ISO 1400 and EMS
      in general. The site includes current and past issues of the newsletter. (Requires a subscription)
   •  CEEM's ISO 14000 Frequently Asked Questions
      Provides answers to frequently  asked questions about ISO 14000.
   •  Globenet
      Site provides EMS Design Tools, News, training resources, and other ISO/EMS information.
   •  ISO 14000 Infocenter
      Provides lists of Accredited Registrars for ISO 14000, companies registered/certified to ISO 14000, discussion
      and implementation support groups, and available EMS/ISO 14000 resource books and newsletters.


State EMS/ISO 14001  Sites

   •  California
      Environmental Protection Agency Web  site that provides information on Environmental Management
      Systems.
   •  Illinois
      Environmental Protection Agency Regulatory Innovation Pilot Program. Describes voluntary EMS
      Agreements between the state and Illinois businesses.
   •  Indiana
      Office of Pollution Prevention and Technical Assistance ISO 14000 site.
   •  Kentucky
      Pollution Prevention  Center Web site with information on the Kentucky EMS Alliance and other EMS

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     information.
   • Minnesota
     Pollution Control Agency site that provides a summary report of federal and state environmental innovations
     legislation.
   • Oregon
     Department of Environmental Quality Web site with information on its green permits and the EMS Incentives
     Project.
   • Pennsylvania
     Web site on ISO 14001/EMS and Pennsylvania.
   • Virginia
     Virginia Environmental Excellence Program and EMS efforts Web site.
   • Wisconsin
     ISO 14000  and Environmental Cooperation Pilot Program Web site.


EMS and  Government

   • Sector-Specific EMS Information - Publicly Owned Treatment Works (POTWs)
     Provides information about EMS and POTWs including design tools, articles, reports, case studies, workshop
     presentations, and related links.
   • Charleston  Commissioners  of Public Works
     Environmental Management System Policy. Policy statement and implementation information regarding the
     EMS for the city of Charleston, S.C.
   • City of Scottsdale Environmental Management System
     Site provides detailed information about the EMS implemented for the city of Scottsdale, Ariz. The site
     follows the ISO 14001 standard and provides documents for each of the standard's 17 components.
   • EPA's Environmental Management System site
     This Web page contains links to key  information about EPA's efforts to develop policies and related materials
     about Environmental Management Systems (EMS).
   • GETF's Municipal Environmental Management System Project
     GETF (Global Environment and Technology Foundation) completed a pilot project in partnership with the
     EPA to implement an EMS in nine local government entities. This site provides information about the pilot
     project and information about local governments and EMS.
   • Implementation Guide for the Code of Environmental Management Principles for Federal Agencies (CEMP)
     Site provides information about the Code of Environmental Management Principles, which is a collection of
     five principles and performance objectives that provide a basis for federal agencies to move towards
     responsible environmental management. The site also provides information about EMS.
   • National Biosolids Partnership
     The goal of the National Biosolids Partnership (NBP), a not-for-profit alliance formed in 1997 with the
     Association of Metropolitan Sewerage Agencies (AMSA), Water Environment Federation (WEF), and U.S.
     Environmental Protection Agency (EPA), is to advance environmentally sound and accepted biosolids
     management practices. Biosolids producers, service contractors and users — together with stakeholders from
     regulatory agencies, universities, the farming community, and environmental organizations — will have input
     into shaping NBP priorities through scientific and technical support and communications linkages relating to
     biosolids issues.
   • LGEAN Toolbox for Local Governments
     The Local Government Environmental Assistance Network (LGEAN) provides environmental management,

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     planning and regulatory information for local government elected and appointed officials, managers and staff.
     LGEAN provides this toolbox as a resource to assist local government officials in their efforts to protect the
     environment and public health. The tools are designed to help users perform operations and calculations
     necessary to fulfill environmental reporting requirements or guide the development of a helpful environmental
     program.
EMS and  Agriculture
   • Sector-Specific EMS Information - Pork Production
     Provides information about EMS and Pork Production including workshop presentations, news, and related
     links.
   • America's Clean Water Foundation's projects page
     Provides a list of agricultural projects at America's Clean Water Foundation, including the National
     Environmental Dialogue on Pork Production and an On-Farm Assessment and Environmental Review Project.
     The on-farm assessment techniques are based in part on an On-Farm Odor/Environmental Assistance Program
     developed by the National Pork Producers Council through the use of "Checkoff' funds. This program is free
     to pork producers.
   • Sustainable Industry Project for the Meat and Poultry Processing Sector
     This project provides an alternative approach to developing environmental policies that impact meat
     processing. The project has established a cooperative effort to identify factors that drive or are barriers to
     environmental performance in the meat and poultry processing sector. A basic EMS model for meat processors
     is to be developed.
   • United Egg Producers Project XL Agreement
     The EPA has a national pilot program called Project XL (excellence and Leadership) that allows state and
     local governments, businesses and federal facilities to develop with EPA innovative strategies or more
     cost-effective ways to achieve environmental and public health protection in exchange for regulatory, program,
     policy or procedural flexibilities. The EPA has recently signed a Project XL agreement with the United Egg
     Producers to help participating facilities achieve "superior environmental performance" by implementing an
     environmental management system (EMS) through a general permit issued by individual  states or EPA.
   • Farm*A*Syst
     With offices in every state, Farm*A*Syst is a partnership between government agencies and private business
     that enables farmers to prevent pollution on farms,  ranches and in homes using confidential environmental
     assessments. Farm*A*Syst has also received funding from the Initiative for Future Agriculture and Food
     Systems (IFAFS) for a four-year project called Partnerships for Livestock Environmental Management
     Assessment Systems in which it will develop EMS tools for the poultry, dairy and beef industries.
   • Adding Value Through Environmental Marketing Conference - ISO 14001 and Agriculture contributed papers
     A listing of papers and articles on EMS/ISO 14001 and agriculture given at a 1999 workshop sponsored by the
     Institute for Agriculture and Trade Policy. The site contains 10 papers on the topic, including "Environmental
     Management Systems and ISO 14000 in Australia- On and Off-farm Implementation and Policy
     Development," "Environmental Management Systems (ISO 14001): A Promising Tool for Farms?," and
     "Environmental Management Systems in Agriculture."
   • N.C. Department of Agriculture and Consumer Services Agronomic Division
     The Agronomic Division provides science-based, land management information to all those who need
     it—from large-scale farmers to homeowners and weekend gardeners.
   • N.C. State University Cooperative Extension Service
     Cooperative Extension works to assist clients in environmentally managing water, waste,  nutrients, pesticides
     and petroleum products by providing research-based information, technical assistance and engineering support.

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Corporate Environmental  Reports
   •  Links to corporate environmental reports
      Site provides links to corporate environmental reports for many companies.
   •  The following are environmental reports from companies with facilities in North Carolina:
         O The Novo Group Environmental and Social Report 2000
         O Environmental Preservation Activities of Matsushita Electric Group
         O IBM'S Environment and Weil-Being Report
         O International Paper's Environment, Health, and Safety Annual Report
Home EMS FAQs ISO 14001 Information | EMS Design Tools I Sector-Specific Information | EMS Case Studies
  Workshop Presentations  Articles and Reports I N.C. Certified Facilities  N.C. Pilot Program  Links  Hot Topics
                                   Please provide your opinion of this site
                         Environmental Management Systems Home Page. This page was last modified on 05/17/2001.
                            Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                      1639 Mail Service Center - Raleigh NC 27699-1639
                                     (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                             Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                                 Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

-------
Management
                   Environmental
     v               — —
   \           j     Management
  Checking    Implementation
  Corrective
   Action
                   Systems
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EMS Hot Topics


Upcoming Workshops

Recent News


Press Releases


DPPEA Calendar


Upcoming Workshops and Training Opportunities

   Monday - Wednesday, June 4-6, 2001
   Learning Together 2001 and Covenanting the Future - Philadelphia, PA
   Two consecutive and overlapping events on regulatory innovation, environmental management systems
   (EMSs), covenants, environmental contracts, natural resources management and sustainability are set for
   June 4-6, 2001, at the University of Pennsylvania Law School in Philadelphia. Registration for one or
   both is possible. The first event, June 4-5, is "Learning Together," the premier EMS workshop for
   industry, government and NGOs that taps the people who have "been there" to share experiences about
   using EMSs to add value to their organizations and communities. The second event, June 5-6, is
   "Covenanting the Future," a conference to explore cooperative approaches to environmental
   regulation and resource management that reconcile separated pollution and conservation laws with
   science-based ecosystem, watershed and adaptive management principles. Register online through the
   MSWG web site www.mswg.org. Contact Dawn Jenkins, University of Florida TREEO Center, at (352)
   392-9570 ext. 127, or e-mail djenkin@treeo.doce.ufl.edu for general information. Location:
   Philadelphia, Pa., $235 per person.

   Wednesday - Thursday, June 20-21, 2001
   Environmental Management Systems Workshop - Mobile, AL

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     The 1 :/2 day EMS course, designed for industry, business and federal and tribal facilities, defines an
     Environmental Management System (EMS), provides information on ISO 14001, and includes hands-on
     exercises to teach about elements of an EMS.

     The course includes student handouts. Learning is reinforced through group discussions and exercises,
     and will include discussion of EMS case studies. Instructors will provide support documents to
     workshop participants in electronic format for review prior to attending. For more information, please
     contact Tony Shelton, U.S. EPA, (404) 562-9636.

     EMS Development Course for Government and Small Businesses

     Beginning Summer 2001
     The Division of Pollution Prevention and Environmental Assistance (DPPEA) is offering a free course
     for local, state and federal government agencies and small businesses to design and implement an EMS,
     using the ISO 14001 model. DPPEA staff will coordinate training sessions and lead instruction. In
     addition, guest speakers from government and industry who have implemented an EMS for their
     operations will be invited to speak. Participants will meet every four to six weeks. No direct financial
     assistance to participants will be provided. This class is modeled on EPA's program to assist local
     governments with EMS implementation.
     The N.C. Department of Environment and Natural Resources (DENR)  supports implementation of EMS
     by organizations, both private and public, and feels there are benefits to the environment as well as to
     the organization. DPPEA is the lead agency within DENR working on  EMS.

     To express interest  in becoming a participant in the EMS Development Course, organizations  should
     contact DPPEA or return registration form by April 30, 2001. To learn more about EMS and ISO
     14001, there will be a free three-hour overview given on Tuesday, April 10 from 9 a.m. to noon in the
     Parker-Lincoln Building, 2728 Capital Blvd., Raleigh, N.C.  For more  information on this project or the
     overview class, please contact Julie Woosley, DPPEA, (919) 715-6527 or (800) 763-0136, e-mail
     Julie.Woosley@ncmail.net.


Recent  News

     Smithfield and Premium Standard Agreements

     North Carolina's largest hog producers have both signed agreements with the  Attorney General's office
     to reduce waste and implement an EMS on company owned hog farms:
         •  October 2, 2000 - Premium Standard
           Press Release
         •  July 25, 2000 - Smithfield Foods Inc.
           Press Release
           Full Agreement

     United Egg Producers and Project XL - October 25, 2000
     The U.S. EPA signed a Project XL agreement with the United Egg Producers. Through this XL project,
     the United Egg Producers (UEP), a farmer cooperative that represents egg producers nationwide, has
     entered into an agreement with EPA to provide a comprehensive program to help participating
     egg-producing facilities achieve superior environmental performance by implementing an environmental
     management system (EMS) and complying with the terms of a general permit issued by individual states
     or EPA. This more  comprehensive approach will require participating facilities to comply not only with
     the terms of a National Pollutant Discharge Elimination System (NPDES) general permit,  but  also to
     implement a multi-media EMS that controls  a range of significant environmental impacts, including

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     those not subject to regulation under the Clean Water Act (CWA). The project also includes a
     third-party auditing component and on-farm management practices most likely to result in superior
     environmental performance.
     Project XL allows state and local governments, businesses and federal facilities to develop with EPA
     innovative strategies or more cost-effective ways to achieve environmental and public health protection.
     In exchange, EPA will issue regulatory, program, policy or procedural flexibilities to conduct the
     experiment.
         • Information on the project
         • Summary of the project
         • Final Project Agreement between the EPA and United Egg Producers

     September 1999
     Several automotive companies now require their suppliers to be ISO 14001 certified by specific dates:
         • Ford Motor Company Press Release
         • General Motors Press Release

Press Releases

   • Pollution Prevention Agency Receives Funding to Assist Pork Producers in Managing Environmental
     Activities                                                                         May 14, 2001

   • Release of EMS Database and Analysis of Baseline Data from 50 Facilities
     June 5, 2000
   • State Adopts New Policy, Recognizes Companies for Partnership in Environmental Protection Program
     August 23, 1999
   • State Partners with Burlington and Gastonia to Reduce Pollution
     March 30, 1999
   • National Group Honors North Carolina Agency for Environmental Efforts (ISO 14000)
     September 28, 1998
   • North Carolina, Other States to Work on Pollution Prevention Approaches (ISO 14000)
     June 3, 1998
   • State Joins in Test of Environmental Management Systems (ISO 14000)
     February 2, 1998
Home  EMS FAQs  ISO 14001 Information I EMS Design Tools I Sector-Specific Information I EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities  N.C. Pilot Program  Links Hot Topics

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              Please provide your opinion of this site
Environmental Management Systems Home Page. This page was last modified on 06/08/2001.
   Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                  1639 Mail Service Center - Raleigh NC 27699-1639
                 (919) 715-65007(800) 763-0136 - fax (919) 715-6794
     Pollution prevention or EMS question or comment? Send e-mail to:  Beth Graves
           Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

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Management
                     Environmental
      v                 —  —
   \           j     Management
   Checking    Implementation
   Corrective
   Action
                     Systems
   EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
Sample Gap Analysis
  • ISO 14001 Environmental Management System Self-Assessment Checklist
    This checklist is based on the ISO 14001 standard and allows for a rapid self-assessment of an organization or
    facility to determine how closely existing management practices and procedures correspond to the elements of
    the standard. In addition to a brief guide to self-scoring, a fuller description of what is required by the
    standard's criteria is included in the appendix. 1996. 54 pages.
    Order Form $25 each - Item No. ISO-111

  • Environmental Process Self Survey
    Conducting business in an environmentally proactive manner can create many benefits for the company and its
    stakeholders. Among these benefits are competitive advantages such as cost savings and improved efficiency,
    but other fringes like favorable public perception may also be enjoyed. This survey incorporates the tenets of
    ISO 9000 and ISO 14000. TVA encourages you to take the time to complete this survey in order to better
    judge how your company ranks in environmental competitiveness.

  • Mini Gap Analysis
    This mini-gap-analysis presents 16 statements based on the ISO 14001 standard. By indicating your
    company's degree of compliance with each statement, an overall score, comment about status and next steps
    are provided. This is a high-level analysis which should not replace a detailed one.

Back to Design Tools
   EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics

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              Please provide your opinion of this site
Environmental Management Systems Home Page. This page was last modified on 04/04/2001.
   Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                  1639 Mail Service Center - Raleigh NC 27699-1639
                 (919) 715-65007(800) 763-0136 - fax (919) 715-6794
     Pollution prevention or EMS question or comment? Send e-mail to:  Beth Graves
           Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

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Management
                      Environmental
      v                 — —
   \           j     Management
   Checking    Implementation
   Corrective
   Action
                     Systems
   EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links  Hot Topics
Design  and Implementation

Workshop Presentations:
  • Bridgestone/Firestone by Dennis Hargens
  • Uniroyal Chemical Company by Ron Lak
  • Philips Communication Security and Imaging Inc. by Joe Fleming
  • EMS Design and Performance Beyond Compliance of BMW by Gary Weinreich
  • ISO 14001 Structure and Implementation by Uniroyal Chemical Company Inc. by Ron Lak
  • Sustainable Community EMS Design Including Pollution Prevention by Michelle M. Wyman, Reed Smith
    Shaw & McClay LLP
  • Environmental Management System Development and Implementation by Don E. Carmichael, City of
    Gastonia Wastewater Treatment Division
  • EMS in Agriculture and Agribusiness by John Thorne, Capitolink LLC

Guidance Documents:
  • Integrated Environmental Management Systems: Implementation Guide
    This guide has been designed to help companies integrate environmental concerns into business decision
    making using the Design for the Environment Program's Integrated Environmental Management System
    (IEMS). This guide follows the guidelines of ISO 14001, an international standard for EMS, and it is designed
    to help businesses set up and implement a simple, straightforward EMS. This guide does not intend to give
    guidance for ISO 14001 certification. EPA Office of Pollution Prevention and Toxics, Design for the
    Environment Program, October 2000 - 301 pages.
  • Ford Motor Company
    This workbook was developed to aid Ford Motor Company suppliers in implementing ISO 14001. It includes a
    PowerPoint presentation, procedure documents, work practices and other components of an EMS manual.
    December 1999 - 161 pages
  • Environmental Management Systems: A Guide for Metal Finishers
    This project involved 11 metal finishing companies in a pilot project with the following objectives: 1) to

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      demonstrate Environmental Management Systems (EMS) implementation in the metal finishing industry, and
      2) to better define the resulting costs and benefits. The ISO 14001 (1996) Environmental Management System
      Standard was used as the basis for defining an environmental management system. December 1998 - 103
      pages
   •  Environmental Management Systems: An Implementation Guide for Small and Medium-Sized Organizations
      This guide is intended to support and facilitate the development of environmental management systems (EMS)
      among small and medium-sized organizations. The guide explains how you can develop and implement an
      effective EMS  and how it can support your organization's mission and goals. Development of an EMS is a
      voluntary approach to improving your organization's environmental performance. December 1996 - 166 pages
   •  A Design for the Environment Approach
      The design for  the environment program can help your company or small business build an environmental
      management system (EMS). The DfE Program has developed a comprehensive how-to manual (March 1999)
      to help small businesses develop an effective EMS based on a DfE approach. March 1999 - 204 pages
         O  DfE Policy Commitments
            Guidance for including DfE commitments in your environmental policy. April 1999 - three pages
         O  DfE and Gap Analysis
            A series  of questions to help you incorporate DfE into your gap analysis. April 1999 - five pages
   •  Environmental Management Systems Primer for Federal Facilities
      This guide will be of particular interest to environmental managers responsible for implementing
      environmental  management systems at federal facilities. 1998 - 71 pages
   •  Implementing an EMS in Community-Based Organizations — Part 1: Project Report
      This report is intended to assist other community-based organizations with EMS development. Implementation
      advice and guidance is provided in Chapter 1 "Early Warning Signs," Chapter 2 under "What Helps/Hinders
      Implementation?," "Overcoming Implementation Challenges"  in the real world examples in Chapter 3, and in
      the highlighted text boxes throughout the text. December 1998 - 137 pages

Back to Design Tools
    EMS FAQs I ISO 14001 Information I EMS Design Tools  Sector-Specific Information EMS Case Studies
  Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links  Hot Topics
                                   Please provide your opinion of this site
                          Environmental Management Systems Home Page. This page was last modified on 06/06/2001.
                            Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                      1639 Mail Service Center - Raleigh NC 27699-1639
                                      (919) 715-65007(800) 763-0136 - fax (919) 715-6794
                             Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                                 Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

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Management
                  Environmental
     v              — —
   \          j    Management
  Checking   Implementation
  Corrective
   Action
                  Systems
  EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
Integrating Your QMS and EMS

The following are workshop presentations available in PowerPoint and HTML:
  • Novo Nordisk Biochem North America by Jennifer Pierce
  • Konica Manufacturing USA by Chris Kappert
Back to Design Tools
  EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics

                    Please provide your opinion of this site
              Environmental Management Systems Home Page. This page was last modified on 04/04/2001.
               Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                     1639 Mail Service Center - Raleigh NC 27699-1639
                     (919) 715-65007(800) 763-0136 - fax (919) 715-6794
                Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                  Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

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Management
                   Environmental
     v               — —
   \          j     Management
  Checking   Implementation
  Corrective
   Action
                  Systems
  EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations  Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
Sample Policy Statements
Some of these sample policy statements meet the three major requirements as specified in ISO 14001 for
commitment to comply with all regulations, support pollution prevention and strive for continual improvement. The
others are generic environmental policy statements.
  • North Carolina Companies:
     O Beers Construction/Skanska (ISO 14001)
     O Bndgestone/Firestone (ISO 14001)
     O IBM (ISO 14001)
     O International Paper (ISO 14001)
     O Nortel (ISO 14001)
     O Purolator (ISO 14001)
     O Duke Energy
     O Phillips Communication, Security, & Imaging
     O ABB
  • Companies outside of North Carolina:
     O Digital Equipment Corporation (ISO 14001)
     O Hewlett -Packard (ISO 14001)
     O Subaru (ISO 14001)
     O Baxter International
     O SGS-Thomson Microelectronics Inc.
     O Xerox
  • Environmental Policies of ISO 14000 Certified Companies
   Link to a list of environmental policies for companies that are ISO 14000 certified - Singapore Productivity
   and Standards Board - March 1999

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    •  Municipalities
          O City of Gastonia Wastewater Treatment Division
          O Charleston Commissioners of Public Works

Back to Design Tools
     EMS FAQs I ISO 14001 Information I EMS Design Tools  Sector-Specific Information  EMS Case Studies
  Workshop Presentations   Articles and Reports I N.C. Certified Facilities N.C. Pilot Program  Links  Hot Topics
                                         Please provide your opinion of this site
                              Environmental Management Systems Home Page. This page was last modified on 05/02/2001.
                                Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                            1639 Mail Service Center - Raleigh NC 27699-1639
                                            (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                                  Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                                      Site question or comment? Send e-mail to: Webmaster(a!p2pavs.org

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Management
  Review
   Checking
   Corrective
   Action
   Pbnning
     f
Implementation
Environmental
  Management
Systems
   EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations  Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
Aspects and Impacts
Bique Pens. This imaginary business was developed by N.C. Division of Pollution Prevention and Environmental
Assistance staff as a learning tool. Bique Pens manufactures brass ink cartridges for ballpoint pens and employs 15
workers. They are in compliance with all environmental regulations and seek ISO 14001 certification in order to
remain in international markets.
  • Sample Flow Chart of Manufacturing Process
  • Ranking of Environmental Aspects and Impacts
The following are workshop presentations available in PowerPoint and HTML:
  • Flow-Charting Your Process to Identify Your Environmental Aspects and Impacts presented by DPPEA staff
  • Environmental Aspects and Impacts of Novo Nordisk by Wendy Laing
  • Dames & Moore Ranking of Environmental Health and Safety Aspects and Impacts by Jim Messelbeck

Back to Design Tools
   EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations  Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics

                       Please provide your opinion of this site
                 Environmental Management Systems Home Page. This page was last modified on 04/04/2001.
                  Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                         1639 Mail Service Center - Raleigh NC 27699-1639
                         (919) 715-65007(800) 763-0136 - fax (919) 715-6794
                   Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                      Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

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Management
                     Environmental
      v                 — —
   \           j     Management
  Checking    Implementation
  Corrective
   Action
                     Systems
   EMS FAQs I ISO 14001 Information I EMS Design Tools  Sector-Specific Information EMS Case Studies
 Workshop Presentations  Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links  Hot Topics
Legal Requirements
  • N.C. Department of Environment and Natural Resources' Customer Service Center
    The DENR Customer Service Center has information on its Web site about federal and state laws and
    regulations for all media programs from air and water quality to dam safety, erosion and sedimentation control
    and hazardous and solid wastes. The Customer Service Center serves as a central clearinghouse of information
    for DENR and also has links to information on permit fees and division fact sheets. Contact CSC toll free at
    1-877-623-6748.

  • Environmental Regulations Checklist
    The National Environmental Achievement Track Application includes a list of environmental regulations to
    help facilities identify the major federal, state, local and tribal environmental requirements that are applicable
    to them. The National Environmental Achievement Track is a component of EPA's National Environmental
    Performance Track.

The following are workshop presentations available in PowerPoint and HTML:
  • Knowing Your Legal Requirements workshop presentation by Beth Graves, N.C. Division of Pollution
    Prevention and Environmental Assistance
  • Duke Power EMS and Legal Requirements by Mark Hollis
  • Regulatory Innovation: EMSs as Environmental Regulatory Tools presented by Jason Morrison at Roundtable
    on EMS for Non-Governmental Organizations (NGOs), Raleigh, May 22, 2000
  • Existing North Carolina Management Requirements for Animal Waste Systems by Carroll Pierce, N.C.
    Division of Soil and Water Conservation

Back to Design Tools

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   EMS FAQs I ISO 14001 Information I EMS Design Tools   Sector-Specific Information  EMS Case Studies
Workshop Presentations   Articles and Reports I N.C.  Certified Facilities  N.C.  Pilot Program  Links  Hot Topics
                                         Please provide your opinion of this site
                             Environmental Management Systems Home Page. This page was last modified on 04/04/2001.
                                Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                            1639 Mail Service Center - Raleigh NC 27699-1639
                                           (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                                 Pollution prevention or EMS question or comment?  Send e-mail to: Beth Graves
                                      Site question or comment? Send e-mail to: Webmaster(a!p2pavs.org

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Management
                  Environmental
     v              — —
   \         j    Management
  Checking   Implementation
  Corrective
   Action
                  Systems
  EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
Internal and External Communication

The following is a workshop presentation available in PowerPoint and HTML:
  • Peter Wise, Kestrel Management Services LLC and Jason Morrison, Pacific Institute
Back to Design Tools
  EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations Articles and Reports | N.C. Certified Facilities N.C. Pilot Program Links Hot Topics

                   Please provide your opinion of this site
              Environmental Management Systems Home Page. This page was last modified on 04/04/2001.
               Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                     1639 Mail Service Center - Raleigh NC 27699-1639
                     (919) 715-65007(800) 763-0136 - fax (919) 715-6794
                Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                  Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

-------
Management
                    Environmental
     v               — —
   \          j     Management
  Checking    Implementation
  Corrective
   Action
                    Systems
  EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations  Articles and Reports I N.C. Certified Facilities N.C. Pilot Program  Links Hot Topics
Internal Auditing, Management Review and

Corrective Action

The following are workshop presentations available in PowerPoint and HTML:
  •  ASMO Greenville Inc. by Jim Laney
    This presentation shows corrective action taken by ASMO Greenville in its emergency preparedness and
    procedure following Hurricane Floyd.
  •  ASMO North Carolina Inc. by Danny Yount
    Environmental performance and the process of findings and corrective action in post-certification surveillance
    audits are explained in this presentation.
  •  Eaton Cutler-Hammer by Scott Plemmons
    This presentation covers general internal auditing and reporting to management topics.
  •  United States Marine Corp EMS: An Auditing Perspective by Capt. David Cook

Back to Design Tools
  EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations  Articles and Reports | N.C. Certified Facilities N.C. Pilot Program  Links Hot Topics


                      Please provide your opinion of this site
                Environmental Management Systems Home Page. This page was last modified on 04/04/2001.
                 Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                       1639 Mail Service Center - Raleigh NC 27699-1639
                       (919) 715-65007(800) 763-0136 - fax (919) 715-6794
                  Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                    Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

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Management
                 Environmental
     v              — —
   \         j     Management
  Checking   Implementation
  Corrective
   Action
                 Systems
  EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
Sample EMS Manuals and Procedures

Sample EMS Manuals:
  • Uniroyal Chemical Company
   Gastoma, N.C., May 2000
  • Alcoa-Mt. Holly
   May 1999
  • City of Gastonia Wastewater Treatment Division
Sample Procedures:
  • The Ford Motor Company Workbook
   provides excellent procedure documents and explanations for their use.
  • Pfizer, Inc.
     O Documentation of Compliance with Regulations
     O Administration of Environmental Programs
     O Operation and Control of the Environmental
     O Management System
     O Aspect and Impact Determinations
     O Identifying Legal and Other Requirements
     O Developing Objectives and Targets
     O Developing Environmental Management Programs
     O Environmental Training, Awareness and Competence
     O Internal and External Communications
     O Addressing Operational Control
     O Emergency Preparedness and Response

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          O Monitoring and Measurement
          O Corrective and Preventive Action
          O Auditing Management Systems
          O Management Review
    • City of Gastonia Wastewater Treatment Division
          O EMS Review
          O Document Control
          O Aspect and Impact Analysis
          O Corrective Preventive Action
          O Employee Training
          O Roles and Responsibilities
          O Objectives and Targets
          O External Communication
          O Environmental Management System Audit
          O Monitoring and Measuring
          O Legal and Other Requirements
Back to Design Tools
    EMS FAQs I ISO 14001 Information I EMS Design Tools  Sector-Specific Information  EMS Case Studies
  Workshop Presentations  Articles and Reports | N.C. Certified Facilities  N.C. Pilot Program  Links  Hot Topics

                                      Please provide your opinion of this site
                            Environmental Management Systems Home Page. This page was last modified on 04/04/2001.
                              Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                         1639 Mail Service Center - Raleigh NC 27699-1639
                                        (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                                Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                                    Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

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Management
                  Environmental
     v              — —
   \         j    Management
  Checking   Implementation
  Corrective
   Action
                  Systems
  EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
Common Areas of Non-Conformance

The following are workshop presentations available in PowerPoint and HTML:
  • BVQI by Karen Czor
  • NSF International by Rick Gehrke
  • Underwriters Laboratories Inc. by Steve Freeman
Back to Design Tools
  EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations Articles and Reports | N.C. Certified Facilities N.C. Pilot Program Links Hot Topics

                   Please provide your opinion of this site
              Environmental Management Systems Home Page. This page was last modified on 04/04/2001.
               Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                     1639 Mail Service Center - Raleigh NC 27699-1639
                     (919) 715-65007(800) 763-0136 - fax (919) 715-6794
                Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                  Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

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Management
                   Environmental
     v               — —
   \          j     Management
  Checking    Implementation
  Corrective
   Action
                   Systems
  EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
Simplify the EMS
The following are workshop presentations available in PowerPoint and HTML:
  •  Simplify/Visualize Your EMS
    This is a presentation by Suzanne Sessoms, an auditor from Excel Inc. The presentation includes a
    participation portion using the following two excel spreadsheets:
     O Spreadsheet 1
     O Spreadsheet 2
  •  EMS — Keep it Simple!
    Susan Graff, Environmental Resources Services Inc.

Back to Design Tools
  EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics

                     Please provide your opinion of this site
               Environmental Management Systems Home Page. This page was last modified on 04/04/2001.
                 Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                       1639 Mail Service Center - Raleigh NC 27699-1639
                       (919) 715-65007(800) 763-0136 - fax (919) 715-6794
                 Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                    Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

-------
Management
                     Environmental
      v                 —  —
   \           j     Management
   Checking    Implementation
   Corrective
   Action
                     Systems
   EMS FAQs I ISO 14001 Information I EMS Design Tools Sector-Specific Information EMS Case Studies
 Workshop Presentations  Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links  Hot Topics
Additional Resources
  • Sector-Specific EMS Information
    Provides information about EMS in different industry sectors, such as Furniture and Wood Finishing, Fleet
    Operations, Metal Finishing, Pork Production, and Publicly Owned Treatment Works (POTWs).

  • EMS-Plus
    Environmental Management Systems Evaluation Tool helps users evaluate an EMS based on whether it
    incorporates components known to promote environmental improvement. EMS-Plus leads the users through a
    series of questions about his or her EMS, and then provides a report based on the key EMS components, such
    as whether the EMS is oriented towards regulatory compliance and control technologies, and whether it is
    more comprehensive and pollution prevention -oriented.

  • Information by Industry Sector
    This is the online collection of pollution prevention core references for selected industry sectors. The core
    references collection includes technical references, fact sheets and case studies on pollution prevention for
    these industry sectors. These documents are deemed to be the "best" by the entities that compiled them.

  • Vendor Database
    This database lists consultants for ISO 14001 implementation and vendors for pollution prevention equipment.
    It is fully searchable and contains useful resources.

  • Workshop Presentations
    Presentations from N.C. Division of Pollution Prevention and Environmental Assistance workshops on other
    EMS topics

  • Articles and Reports
    Articles and reports on several EMS Topics

Back to Design Tools

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   EMS FAQs I ISO 14001 Information I EMS Design Tools   Sector-Specific Information  EMS Case Studies
Workshop Presentations   Articles and Reports I N.C.  Certified Facilities  N.C.  Pilot Program  Links  Hot Topics
                                         Please provide your opinion of this site
                             Environmental Management Systems Home Page. This page was last modified on 05/22/2001.
                                Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                            1639 Mail Service Center - Raleigh NC 27699-1639
                                           (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                                 Pollution prevention or EMS question or comment?  Send e-mail to: Beth Graves
                                      Site question or comment? Send e-mail to: Webmaster(a!p2pavs.org

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Management
               Environmental
    v            — —
  \       j   Management
  Checking  Implementation
  Corrective
  Action
               Systems
Home EMS FAQs ISO 14001 Information I EMS Design Tools I Sector-Specific Information I EMS Case Studies

 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
EMS Sector-Specific Information -

Agriculture


Workshop

Sub Sectors

Links

Workshop - Developing an Environmental Management

System for Agriculture and Agribusiness, December 18,

2000

Speaker Presentations:
  • EMS Basics
   Beth Graves, Division of Pollution Prevention and Environmental Assistance
  • EMS in Agriculture and Agribusiness
   John Thorne, Capitolink LLC
  • Existing North Carolina Management Requirements for Animal Waste Systems
   Carroll Pierce, N.C. Division of Soil and Water Conservation
  • Covered Anaerobic Digester: Case Study from Barham Farm
   Julian Barham, Barham Farms Inc.

Sub Sectors

  • Pork Production

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   •  Meat Processing - coming soon


Links

   •  Adding Value Through Environmental Marketing Conference - ISO 14001 and Agriculture contributed papers
      A listing of papers and articles on EMS/ISO 14001 and agriculture given at a 1999 workshop sponsored by the
      Institute for Agriculture and Trade Policy. The site contains 10 papers on the topic, including "Environmental
      Management Systems and ISO 14000 in Australia- On- and Off-farm Implementation and Policy
      Development," "Environmental Management Systems (ISO 14001): A Promising Tool for Farms?" and
      "Environmental Management Systems in Agriculture."
   •  Environmental Management Systems and Agriculture and Agribusiness Related Initiatives
Home EMS FAQs  ISO 14001 Information I EMS Design Tools I Sector-Specific Information I EMS Case Studies
  Workshop Presentations  Articles and Reports I N.C. Certified Facilities  N.C. Pilot Program  Links  Hot Topics
                                     Please provide your opinion of this site
                          Environmental Management Systems Home Page. This page was last modified on 05/23/2001.
                             Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                       1639 Mail Service Center - Raleigh NC 27699-1639
                                       (919) 715-65007(800) 763-0136 - fax (919) 715-6794
                              Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                                  Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

-------
Management
                Environmental
    v            — —
  \        j    Management
  Checking   Implementation
  Corrective
  Action
                Systems
Home EMS FAQs ISO 14001 Information I EMS Design Tools I Sector-Specific Information I EMS Case Studies

 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
EMS Sector-Specific Information -

Agriculture: Pork Production


News

Workshop

Links


News

Pollution Prevention Agency Receives Funding to Assist Pork Producers in Managing Environmental Activities,
May 14, 2001 PDF HTML

North Carolina's largest hog producers have both signed agreements with the Attorney General's office to reduce
waste and implement an EMS on all of their hog farms:
  • Smithfield Foods Inc., July 25, 2000
   Press Release
   Full Agreement
  • Premium Standard, October 2, 2000
   Press Release


Workshop

Developing an Environmental Management System (EMS) Approach for Agriculture and Agribusiness
Raleigh, Dec. 18,2000

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Links
      America's Clean Water Foundation's projects page
      Provides a list of agricultural projects at America's Clean Water Foundation, including the National
      Environmental Dialogue on Pork Production and an On-Farm Assessment and Environmental Review Project.
      The on-farm assessment techniques are based in part on an On-Farm Odor/Environmental Assistance Program
      developed by the National Pork Producers Council through the use of "Checkoff' funds. This program is free
      to pork producers.
      N.C. Department of Agriculture and Consumer Services Agronomic Division
      The Agronomic Division provides science-based, land management information to all those who need
      it—from large-scale farmers to homeowners and weekend gardeners.
      N.C. State University Cooperative Extension Service
      Cooperative Extension works to assist clients in environmentally managing water, waste, nutrients, pesticides
      and petroleum products by  providing research-based information, technical assistance and engineering support.
Home EMS FAQs  ISO 14001 Information | EMS Design Tools I Sector-Specific Information | EMS Case Studies
  Workshop Presentations  Articles and Reports I N.C. Certified Facilities  N.C. Pilot Program  Links  Hot Topics
                                     Please provide your opinion of this site
                          Environmental Management Systems Home Page. This page was last modified on 06/07/2001.
                             Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                       1639 Mail Service Center - Raleigh NC 27699-1639
                                       (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                              Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                                  Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

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Management
                Environmental
    v             — —
  \        j    Management
  Checking   Implementation
  Corrective
  Action
                 Systems
Home EMS FAQs ISO 14001 Information I EMS Design Tools I Sector-Specific Information I EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
EMS Sector-Specific Information
Furniture and Wood Finishing
   EMS information coming soon; see our Core Sector Page
Home EMS FAQs ISO 14001 Information | EMS Design Tools | Sector-Specific Information | EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics

                  Please provide your opinion of this site
             Environmental Management Systems Home Page. This page was last modified on 04/03/2001.
              Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                   1639 Mail Service Center - Raleigh NC 27699-1639
                   (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
               Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                 Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

-------
Management
                 Environmental
    v             — —
  \         j    Management
  Checking   Implementation
  Corrective
  Action
                 Systems
Home EMS FAQs ISO 14001 Information I EMS Design Tools I Sector-Specific Information I EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
EMS Sector-Specific Information
Fleet Operations
   EMS information coming soon; see our Core Sector Page
Home EMS FAQs ISO 14001 Information | EMS Design Tools | Sector-Specific Information | EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics

                  Please provide your opinion of this site
             Environmental Management Systems Home Page. This page was last modified on 04/03/2001.
              Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                    1639 Mail Service Center - Raleigh NC 27699-1639
                    (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
               Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                 Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

-------
Management
                   Environmental
     v               — —
   \           j     Management
  Checking    Implementation
  Corrective
   Action
                   Systems
Home EMS FAQs ISO 14001 Information I EMS Design Tools I Sector-Specific Information I EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links  Hot Topics
EMS Sector-Specific Information -
Metal Finishing

  • Environmental Management Systems: A Guide for Metal Finishers
   This project involved 11 metal finishing companies in a pilot project to 1) demonstrate environmental
   management systems (EMS) implementation in the metal finishing industry, and 2) to better define the
   resulting costs and benefits. The ISO 14001 (1996) Environmental Management System Standard was used as
   the basis for defining an environmental management system. December 1998 - 103 pages
  • North Carolina's Strategic Goals Program for Metal Finishers
  • see our Core Sector Page
Home EMS FAQs ISO 14001 Information I EMS Design Tools I Sector-Specific Information I EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links  Hot Topics

                     Please provide your opinion of this site
               Environmental Management Systems Home Page. This page was last modified on 05/22/2001.
                 Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                       1639 Mail Service Center - Raleigh NC 27699-1639
                       (919) 715-65007(800) 763-0136 - fax (919) 715-6794
                 Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                    Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

-------
Management
                 Environmental
     v              —  —
   \         j     Management
  Checking   Implementation
  Corrective
   Action
                 Systems
Home EMS FAQs ISO 14001 Information I EMS Design Tools I Sector-Specific Information I EMS Case Studies

 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
EMS Sector-Specific Information  -

Publicly Owned Treatment Works (POTWs)


EMS Development Course for Government and Small

Businesses

Design Tools

Articles, Reports, and Case Studies

Workshops

Links


EMS Development Course for Government and Small

Businesses

The Division of Pollution Prevention and Environmental Assistance (DPPEA) is offering a free course for local, state
and federal government agencies and small businesses to design and implement an EMS, using the ISO 14001 model.
DPPEA staff will coordinate training sessions and lead instruction. In addition, guest speakers from government and
industry who have implemented an EMS for their operations will be invited to speak. Participants will meet every
four to six weeks. No direct financial assistance to participants will be provided. This class is modeled on EPA's
program to assist local governments with EMS implementation.

The N.C. Department of Environment and Natural Resources (DENR) supports implementation of EMS by
organizations, both private and public, and feels there are benefits to the environment as well as to the organization.
DPPEA is the lead agency within DENR working on EMS.

To express interest in becoming a participant in the EMS Development Course, organizations should contact DPPEA

-------
or return registration form by April 30, 2001. For more information on this project, please contact Julie Woosley,
DPPEA, (919) 715-6527 or (800) 763-0136, e-mail: Julie.Woosley@ncmail.net.
Design Tools
   • Sample Procedures: City of Gastonia Wastewater Treatment Division
        O EMS Review
        O Document Control
        O Aspect and Impact Analysis
        O Corrective Preventative Action
        O Employee Training
        O Roles and Responsibilities
        O Objectives and Targets
        O External Communication
        O Environmental Management System Audit
        O Monitoring and Measuring
        O Legal and Other Requirements
   • Sample Policy Statements
        O Charleston Commissioners of Public Works
        O City of Gastonia Wastewater Treatment Division
   • Sample EMS Manual: City of Gastonia Wastewater Treatment Division

Articles,  Reports, and Case Studies

   • Implementing ISO 14001 Environmental Management Systems at the Municipal Level
     10/98 - 3 pages
   • Final Report: The US EPA Environmental Management System Pilot Program for Local Government Entities
     1/00-  136 pages
   • Case Study: Gastonia Wastewater Treatment Division
     January 2001-2 pages
Workshops
   • Strategies for Governmental EMS (Environmental Management System) Workshop
     Gastonia, N.C., Jan. 31, 2001.
   • Benefits of an EMS to a Local Government
     by Steve Shoaf, et al., City of Burlington

Links
   • See our Core Sector Page for Local Governments and POTWs

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   •  Charleston Commissioners of Public Works
      Environmental Management System Policy. Policy statement and implementation information regarding the
      EMS for the city of Charleston, S.C.
   •  City of Scottsdale Environmental Management System
      Site provides detailed information about the EMS implemented for the city of Scottsdale, Ariz. The site
      follows the ISO 14001 standard and provides documents for each of the standard's 17 components.
   •  EPA's Environmental Management System site
      This Web page contains links to key information about EPA's efforts to develop policies and related materials
      about Environmental Management Systems (EMS).
   •  GETF's Municipal Environmental Management System Project
      GETF (Global Environment and Technology Foundation) completed a pilot project in partnership with the
      EPA  to implement an EMS in nine local government entities. This site provides information about the pilot
      project and information about local governments and EMS.
   •  Implementation Guide for the Code of Environmental Management Principles for Federal Agencies (CEMP)
      Site provides information about the Code of Environmental Management Principles, which is a collection of
      five principles and performance objectives that provide a basis for federal agencies to move towards
      responsible  environmental management. The site also provides information about EMS.
   •  National Biosolids Partnership
      The goal of the National Biosolids Partnership (NBP), a not-for-profit alliance formed in 1997 with the
      Association of Metropolitan Sewerage Agencies (AMSA), Water Environment Federation (WEF), and U.S.
      Environmental Protection Agency (EPA), is to advance environmentally sound and accepted biosolids
      management practices. Biosolids producers, service contractors and users — together with stakeholders from
      regulatory agencies, universities, the farming community, and environmental organizations — will have input
      into shaping NBP priorities through scientific and technical support and communications linkages relating to
      biosolids issues.
   •  LGEAN Toolbox for Local Governments
      The Local Government Environmental Assistance Network (LGEAN) provides environmental management,
      planning and regulatory information for local government elected and appointed officials, managers and staff.
      LGEAN provides this toolbox as a resource to assist local government officials in their efforts to protect the
      environment and public health. The tools are designed to help users perform operations and calculations
      necessary to fulfill environmental reporting requirements or guide the development of a helpful environmental
      program.


Home EMS FAQs  ISO 14001 Information I  EMS Design Tools I  Sector-Specific Information I EMS Case Studies
 Workshop Presentations Articles and Reports | N.C.  Certified Facilities  N.C. Pilot Program  Links Hot Topics


                                   Please provide your opinion of this site
                          Environmental Management Systems Home Page. This page was last modified on 05/22/2001.
                            Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                      1639 Mail Service Center - Raleigh NC 27699-1639
                                      (919) 715-65007(800) 763-0136 - fax (919) 715-6794
                             Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                                 Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

-------
Management
                Environmental
    v            — —
  \        j    Management
  Checking   Implementation
  Corrective
  Action
                Systems
Home EMS FAQs ISO 14001 Information I EMS Design Tools I Sector-Specific Information I EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
EMS Workshop Presentations -

Strategies for Governmental Environmental

Management System Workshop


Speaker Presentations:

  • EMS Basics
   Beth Graves, N.C. Division of Pollution Prevention and Environmental Assistance
  • National Biosolids Partnership EMS Program
   Rebecca West, Western Carolina Regional Sewer Authority
  • Environmental Management System Development and Implementation
   Don E. Carmichael, City of Gastonia Wastewater Treatment Division
  • ISO 14001 Management Perspective
   Bob Danhauser, Charleston Commissioners of Public Works
See our Sector-Specific EMS page on Publicy Owned Treatment Works (POTWS)


Home EMS FAQs ISO 14001 Information | EMS Design Tools | Sector-Specific Information | EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics

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              Please provide your opinion of this site
Environmental Management Systems Home Page. This page was last modified on 05/02/2001.
   Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                  1639 Mail Service Center - Raleigh NC 27699-1639
                 (919) 715-65007(800) 763-0136 - fax (919) 715-6794
     Pollution prevention or EMS question or comment? Send e-mail to:  Beth Graves
           Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

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Management
                Environmental
    v            — —
  \        j    Management
  Checking   Implementation
  Corrective
   Action
                Systems
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EMS Workshop Presentations -

ISO 14001: The Nuts and Bolts of Getting It

Done

Speaker Bios

Pictures from the Workshop

Workshop Topics and Speaker Presentations:

  • Why Seek Certification? What Do You Get Out of Having an EMS?
    O Mercedes-Benz U.S. International Inc. by Mark Warner
    O Purolator Products Inc. by Steve Ross
    O Ford Motor Company by Bob Devlin
    O Ford - Norfolk Assembly Plant by Gary Davis
  • Flow Charting Your Process To Identify Your Environmental Aspects and Impacts
    O Division of Pollution Prevention and Environmental Assistance staff
  • Simplify Your EMS
    O Environmental Resources Services Inc. by Susan Graff
    O Excel by Suzanne Sessoms
  • Integrating Your QS/ISO 9000 and ISO 14001 Programs
    O Uniroyal Chemical Company Inc. by Ron Lak
    O Novo Nordisk Biochem North America by Jennifer Pierce

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         O  Konica Manufacturing USA by Chris Kappert
   •  Common Areas of Non-Conformancies — A Registrar's Perspective
         O  NSF International by Rick Gehrke
         O  BVQI by Karen Czor
         O  Underwriters Laboratories Inc. by Steve Freeman
   •  Cost and Benefits of an  EMS Including Pollution Prevention
         O  NCI Inc. by Jack  Rockstad
         O  Bridgestone/Firestone Inc. by Dennis Hargens
         O  Philips Communication Security and Imaging Inc. by Joe Fleming
   •  Internal and External Communication
         O  Peter Wise, Kestrel Management Services LLC and Jason Morrison, Pacific Institute
   •  Internal Auditing, Management Review and Corrective Action
         O  Eaton Cutler-Hammer by  Scott Plemmons
         O  ASMO Greenville Inc. by Jim Laney
         O  ASMO North Carolina Inc. by Danny Yount
   •  Knowing Your Legal Requirements
         O  Beth Graves, Division of Pollution Prevention and Environmental Assistance
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                                     Please provide your opinion of this site
                          Environmental Management Systems Home Page. This page was last modified on 05/18/2001.
                             Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                        1639 Mail Service Center - Raleigh NC 27699-1639
                                       (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                              Pollution prevention or EMS question or comment?  Send e-mail to:  Beth Graves
                                  Site question or comment? Send e-mail to: Webmaster(a!p2pavs.org

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Management
                 Environmental
    v             — —
   \         j    Management
  Checking   Implementation
  Corrective
   Action
                Systems
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EMS Workshop Presentations -

EMS Models and Strategies: ISO 14001 and

Beyond

August 24,1999

  • Agenda
  • Speaker Profiles
  • N.C. ISO 14001 Certified Facilities - As of April 18, 2000
  • Summary of State Innovation Laws and EMS - 8/16/99
  • The ISO 14000 Family of Standards: Environmental Management Systems
  • Web Address Resource List

Speaker Presentations:

  • Linking Economic and Environmental Performance: Translating an EMS Into the Language of Business by
   Edward L. Quevedo, Pillsbury Madison & Sutro LLP
   Benefits of an EMS to a Local Government by Steve Shoaf, et al., City of Burlington
   Ford Motor Company Quest for EMS by Chris Porter
   Nortel Networks Strategic Planning on EMS policy by Shyam Banik
   Environmental Aspects and Impacts of Novo Nordisk by Wendy Laing
   Dames & Moore Ranking of Environmental Health and Safety Aspects and Impacts by Jim Messelbeck
   EMS Design and Performance Beyond Compliance of BMW by Gary Weinreich

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   •  ISO 14001 Structure and Implementation by Uniroyal Chemical Company Inc. by Ronald J. Lak
   •  Eaton-Cutler-Hammer: Gaining Competitive Advantage Through Environmental Management System by Jim
      Takac
   •  Sustainable Community EMS Design Including Pollution Prevention by Michelle M. Wyman, Reed Smith
      Shaw & McClay LLP
   •  Employment Involvement in EMS at Konica Manufacturing USA Inc. by John E. Moore
   •  Duke Power EMS and Legal Requirements by Mark Hollis
   •  United States Marine Corp EMS: An Auditing Perspective by Capt. David Cook
   •  How to Approach Registration and Auditing by Suzanne Sessoms
   •  Upgrading and Sustaining the EMS: Western Digital  Case Study by Edward L. Quevedo, Pillsbury Madison &
      Sutro LLP
   •  IBM's  Environmental Management System by Susan Clarke
Home EMS FAQs  ISO 14001 Information | EMS Design Tools I Sector-Specific Information | EMS Case Studies
 Workshop Presentations  Articles and Reports I N.C. Certified Facilities  N.C. Pilot Program Links  Hot Topics
                                    Please provide your opinion of this site
                          Environmental Management Systems Home Page. This page was last modified on 04/09/2001.
                             Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                       1639 Mail Service Center - Raleigh NC 27699-1639
                                       (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                              Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                                  Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

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Management
                Environmental
    v            — —
  \        j    Management
  Checking   Implementation
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  Action
                Systems
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EMS Workshop Presentations -

Environmental Management System

Implementation Workshop

May 14-15, 1998

First national workshop on environmental management systems sponsored by the Multi-State Working Group and
the United States Environmental Protection Agency
 • Agenda
 • Proceedings
 • Speakers' Presentations:
     O Dawn B. Sudmeyer, Camp Lejeune
     O David Rachels, Exide Electronics Large System Group
     O Doug Gay lord, Honda Power Equipment Manufacturing Inc.
     O Matt Caton, Lufkin/CooperTools, Apex, N.C.
     O Sean Bir, Konica Manufacturing USA Inc.
Home EMS FAQs ISO 14001 Information I EMS Design Tools I Sector-Specific Information I EMS Case Studies
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              Please provide your opinion of this site
Environmental Management Systems Home Page. This page was last modified on 04/09/2001.
   Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                  1639 Mail Service Center - Raleigh NC 27699-1639
                 (919) 715-65007(800) 763-0136 - fax (919) 715-6794
     Pollution prevention or EMS question or comment? Send e-mail to:  Beth Graves
           Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

-------
Management
                      Environmental
      v                  — —
   \            j     Management
   Checking    Implementation
   Corrective
    Action
                      Systems
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Data Categories
The research conducted with information from the database will seek to answer a fundamental question: To what
extent does the implementation of an environmental management system change a facility's behavior? To answer this
question, the data collection protocols and research will focus on six primary dimensions:

  • Environmental Performance: Does adoption of an EMS improve environmental performance and/or change a
    facility's use of environmental performance indicators? Is there a difference if the EMS conforms with ISO
    14001?

  • Environmental Condition Indicators: How are indicators of local, regional, and global environmental
    conditions incorporated into the design of a facility's EMS?

  • Pollution Prevention: Does the adoption of an EMS change a facility's use of pollution prevention techniques?
    Do significant changes in environmental performance after EMS adoption result from greater use of pollution
    prevention practices?

  • Regulatory Compliance: Does a facility's record of regulatory compliance change as a result of the adoption of
    an EMS? How does an EMS affect a facility's regulatory status and its ability to identify or prevent instances
    of non-compliance?

  • Economic Performance (Costs and Benefits): What economic costs and benefits — both direct and indirect —
    does a facility accrue as a result of EMS adoption? Does the adoption of an EMS change a facility's use of
    economic performance indicators and/or advanced environmental and materials accounting techniques?

  • Interested Party Involvement: How does a facility's involvement of outside parties, such as environmental
    Non-Governmental Organizations (NGOs) and the general public, change as a result of the adoption of an
    EMS? How does this involvement benefit a facility or influence its decisions?

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                                          Please provide your opinion of this site
                              Environmental Management Systems Home Page. This page was last modified on 04/23/2001.
                                 Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                             1639 Mail Service Center - Raleigh NC 27699-1639
                                             (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                                   Pollution prevention or EMS question or comment?  Send e-mail to: Beth Graves
                                       Site question or comment? Send e-mail to: Webmaster(a!p2pavs.org

-------
Management
                     Environmental
     v                — —
   \           j     Management
  Checking   Implementation
  Corrective
   Action
                     Systems
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Class Reference Materials for EMS Workshop

June 20-21, 2001  in Mobile, Alabama

The following is a list of reference materials regarding Environmental Management Systems (EMS) for use by
participants attending the EMS Workshop on June 20-21 in Mobile, AL. The U.S. Environmental Protection Agency
(EPA), Region 4 and the Alabama Department of Environmental Management are sponsoring the workshop.
Instruction and reference materials are provided by staff from the N.C. Division of Pollution Prevention and
Environmental Assistance. For questions related to the workshop, please contact Tony Shelton, U.S. EPA, (404)
562-9636.

Participants do not need to review all materials prior to the workshop. Materials are provided for informational
purposes only. However, cursory review of some of the information will provide some basic EMS knowledge to
participants unfamiliar with the topic. In addition, participants should find some reference materials of use following
the course or of use when developing their own EMS.

An Introduction to EMS

  • The ISO 14000 Family of Standards: Environmental Management Systems
    August 1999 - 3 pages

  • Short EMS Case Studies

  • EMS Design Tools

What is an EMS? Good Overview Documents

  • Environmental Management Systems: An Implementation Guide for Small and Medium-Sized Organizations
    This guide is intended to support and facilitate the development of environmental management systems (EMS)
    among small and medium-sized organizations. The guide explains how you can develop and implement an
    effective EMS and how it can support your organization's mission and goals. Development of an EMS is a
    voluntary approach to improving your organization's environmental performance. December 1996 - 166 pages
  • Integrated Environmental Management Systems: Implementation Guide

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      This guide has been designed to help companies integrate environmental concerns into business decision
      making using the Design for the Environment Program's Integrated Environmental Management System
      (IEMS). This guide follows the guidelines of ISO 14001, an international standard for EMS, and it is designed
      to help businesses set up and implement a simple, straightforward EMS. This guide does not intend to give
      guidance for ISO 14001 certification. EPA Office of Pollution Prevention and Toxics, Design for the
      Environment Program, October 2000 - 301 pages
   •  Ford Motor Company
      This workbook was developed to aid Ford Motor Company suppliers in implementing ISO 14001.  It includes a
      PowerPoint presentation, procedure documents, work practices and other components of an EMS manual.
      December 1999 - 161 pages

EMS Models

   •  Environmental Management Systems: A Guide for Metal Finishers
      This project involved 11 metal finishing companies in a pilot project with the following objectives: 1) to
      demonstrate Environmental Management Systems (EMS) implementation in the metal finishing industry, and
      2) to better define the resulting costs and benefits. The ISO 14001 (1996) Environmental Management System
      Standard was used  as the basis for defining an environmental management system. December 1998 - 103
      pages

   •  Improving Environmental Performance and Compliance: 10 Elements of Effective Environmental
      Management Systems
      This document represents the first joint statement from Canada, Mexico and the United States on how
      voluntary EMS designed for internal management purposes can also serve the broader public policy goals of
      compliance assurance and improved environmental performance  in regulated and non-regulated areas. The
      guidance document focuses on only two public policy issues: compliance assurance and improved
      environmental performance in regulated and non-regulated areas. June 2000 - 9 pages

   •  Implementation Guide for the Code of Environmental Management Principles for Federal Agencies (CEMP)
      Federal reference tool - EMS template. June 1998

   •  Environmental Management Systems Primer for Federal Facilities
      This guide will be of particular interest to environmental managers responsible for implementing
      environmental management systems at federal facilities. 1998 - 71 pages

Other

   •  EPA Performance Track
      The National Environmental Performance Track is a new program designed to motivate and reward top
      environmental performance by companies and facilities of all types - public and private
Home EMS FAQs  ISO 14001 Information | EMS Design Tools | Sector-Specific Information | EMS Case Studies
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              Please provide your opinion of this site
Environmental Management Systems Home Page. This page was last modified on 06/06/2001.
   Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                  1639 Mail Service Center - Raleigh NC 27699-1639
                 (919) 715-65007(800) 763-0136 - fax (919) 715-6794
     Pollution prevention or EMS question or comment? Send e-mail to:  Beth Graves
           Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

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                                                            Skanska 's Environmental Policy
To all employees at Skanska,
Our vision is that Skanska shall become the world's leading company in construction-related services and in
project and real estate development. This requires, among other things, that all of us take environmental
issues seriously.
What we do today affects the environment of both current and future generations. Caring
about people and the environment must therefore permeate all of our work. This
responsibility rests with all of us. Our environmental awareness will help us prevent and
minimize adverse environmental impact and improve our operations, thereby generating
new business opportunities. We must be open-minded in our dialogue with others. In
order to be successful, we need knowledge and commitment.

We shall always follow these principles in our work at Skanska:

" Think ahead about how your work will affect the environment.
" Ask questions and obtain help if you are unsure. Use common sense.
" Be cautious and avoid materials or methods if you cannot properly assess their
environmental risks.
" Bear in mind that there are circumstances where, due to environmental risks, we should
not participate.
" Choose or propose environmentally better alternatives when this makes sense.
" Conserve natural resources.

Every operative unit must build up an environmental management system and set its own
environmental goals in order for our environmental policy to yield results in our daily
work. Legislation and the environmental demands of our clients  provide a foundation for
our environmental ambition. Beyond this, we shall endeavor to make continuous
improvements. All operations shall have environmental management systems in place no
later than December 31,  1999 and be certified no later than December 31, 2000.

By letting responsibility for the environment and the future permeate our day-to-day
work, we will gain the confidence and respect of others.

Danderyd, April 1998
ClaesBjork
President and CEO
This Environmental Policy document replaces the Policy adopted in 1995.

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   BRIDGESTONE/FIRESTONE    WILSON   PLANT
             HEALTH,  SAFETY,  QUALITY  &
               ENVIRONMENTAL    POLICY
                  HEALTH AND  SAFETY  POLICY

  Bridgestone/Firestone Wilson Plant management is committed to providing a safe,
healthy workplace for our associates. To meet this commitment, our health, safety, and
  loss control programs must be:  CONTINUING, AGGRESSIVE,  & EFFECTIVE.

                  The purpose of these programs will be to:
               Protect employees from occupational illness or injury
              Protect BFS equipment and property from loss or damage

     These programs will be actively conducted within all departments and will
       support the guidelines of the BFS Wilson Health and Safety Program.


                         QUALITY  POLICY

     We will maintain our quality systems, processes and standards to meet the
   changing needs of our customers and to assure the quality of our products.

          We will  strive for continuous improvement through teamwork
                      and the education of our people.
                    ENVIRONMENTAL   POLICY

            We will produce competitive products to meet customer
         requirements while operating in an environmentally responsible
       manner. The Plant Manager and his management team are committed
    to implementing an effective environmental management system designed to
     accomplish our strategic business objectives and fulfill our responsibility
  as a good industrial employer and neighbor in the Wilson community.  We shall:

  •   Conduct business so that environmental challenges  are managed as an integral
    part of current and changing business strategies.
  »  Communicate about environmental issues.
  •  Comply with applicable federal, state, and local environment laws,  and meet other
    environmental commitments we make.
  »  Promote pollution prevention.
  •  Continually improve the environmental management system.
                              John McQuide
                                 5/3/99

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                     IS014001 Key Phrase:

 COMMUNICATE,  COMPLY  AND  CONTINUALLY  IMPROVE!

                           We will:
          COMMUNICATE about  environmental  issues
  COMPLY with  federal, state  and local laws  that are  appropriate
                       to  the environment
CONTINUALLY  IMPROVE  our  environmental management system
                       and prevent pollution
                     Environmental   Engineer:

                        Dennis Hargens

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      Revision # _0__      Effective Date: #  06/98    Document Type: _Level 1

      Document Title   Eastern Region Land and Timber Environmental Policy

      Approved:   (Signature - Morris C. Wright)                Page 1 of 1



                       INTERNATIONAL (logo here) PAPER

                                  CORPORATE POLICY
                              Environment, Health and Safety

        An essential part of our business strategy is to make products in a safe and
        healthful work place, to  manage natural resources wisely, and to continually
        improve our environmental performance.  We are committed to removing the
        conditions and behaviors that cause personal injury or environmental impact.
        Therefore, we will:

            •   Comply with all applicable environmental, health and safety laws and
                regulations, with the company's own environmental, industrial hygiene
                and safety policies and commitments and with the Sustainable Forestry
                Initiative (SFI™) and with the Environmental, Health and Safely
                principles of the American Forest and Paper Association.

            •   Undertake with our employees the creation and maintenance of an
                accident and injury -free workplace.

            •   Emphasize prevention of pollution, elimination of process excursions
                and continual improvement through employee diligence as the best
                practicable means to improve the environmental performance of our
                operations.

        Business site managers  have the responsibility to assure that their business site:

            •   Complies with  applicable environmental, health and safety laws,
                regulations and corporate policy and to certify  to this requirement.

            •   Develops, implements and maintains effective systems, procedures and
                training to achieve and maintain an accident-free, injury-free and
                healthful workplace.

            •   Integrates continual environmental, health and safety improvement,
                pollution prevention and employees diligence into daily operations.

            •   Develops site-specific annual objectives for environmental, industrial
                hygiene, safety and worker's compensation improvements that support
                these goals, policies and statements.

                                        	(Signature')	
                                        John T. Dillon
                                        Chairman & Chief Executive Officer

        Apnl, 1997
        Supporting Documents
        International Paper Environment, Health and Safety Principles
        International Paper Forest Management Principles
EMS2.1wp

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Environmental Policy

Carrier Solutions RTF Area Operations (RAO) commits to demonstrate environmental
leadership in the telecommunications industry and to protect and enhance the
environment through sound management decisions.

Carrier Solutions RAO commits to:

   •   Comply with all relevant environmental legislation and other standards to which
       we subscribe.
   •   Prevent Pollution by minimizing resource consumption, waste generation and
       adverse environmental impacts whenever technologically and economically
       viable.
   •   Set and review objectives and targets to ensure continual improvement of the
       EMS and our environmental performance.
   •   Participate in efforts to share with suppliers, customers, industry and the
       community, appropriate knowledge and technology that benefit the environment.
(from Nortel Networks, RTF, NC Carrier Solutions Operations, Issue Date:  6/30/1999)

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PUROLATOR PRODUCTS
MANAGEMENT SYSTEM MANUAL
SECTION 0 General
0.2 Environmental, Health, and
Safety Policy
(Fayettevllle Only)
Pages: 1
Status: Issued
                  0.2 Environmental, Health, and Safety Policy
   Purolator,  Fayetteville  Plant,  is  committed  to  develop  and  operate  an  Environmental,
   Health, and  Safety  (EHS)  System to  provide:

          *     Compliance with relevant environmental, safety and health legislation and
                regulations
          *     Compliance with Purolator's safety and health program and other requirements
          *     Continual improvement through the achievements of targets and objectives
          *     Prevention of pollution through the reduction of environmental
           emissions  and  waste   disposal

   The  framework  for  establishing,  implementing,  and   maintaining  our  Environmental,
   Health,  and  Safety  System provides  the  following  activities:

          *     Communication of this policy to all employees
          *     Making this policy available to the public
          *     Setting and reviewing EH&S obj ectives and targets

Linked procedures apply  to all Plants unless specifically noted.
Revision:

Last Rev. Date:


5

07/14/98
Effective Data:

Author:


10/29/98

Wes Thomas
    1 cf 1 Pages ... 0.2 Environmental, Health, and Safety Policy-Uncontrolled Document04/07/2000

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Bique Pens Ranking System
Severity - The potential effect of an environmental aspect on the environmer
     * No Impact
     Minor
4.    Moderate
5,    Serious / Environmentally Regulated
Quantity - The amount of the material generated / used
1.    T Minimal quantities generated
4.
5.

Large quantities generated

Worker Safety - The health risk to facility employees

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   T No Health Ris
   Serious health risk - major concern for worker safety
Ranking

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Management
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National Environmental Achievement Track

Environmental Regulations Checklist

The following checklist is a component of the EPA National Environmental Achievement Track Application. It
serves to help facilities identify the major federal, state, tribal, and local environmental requirements that are
applicable to them. This is not necessarily an exhaustive list of environmental regulations and requirements.
Air Pollution Regulations
Hazardous Waste Management Regulations
Hazardous Materials Management
Water Pollution Control Requirements
Drinking Water Regulations
Solid Waste Management
Toxic Substances
Pesticide Regulations
Environmental Clean-up, Restoration, Corrective Action
Air Pollution Regulations
  1. National Emission Standards for Hazardous Air Pollutants (40 CFR 61)
  2. Permits and Registration of Air Pollutant Sources
  3. General Emission Standards, Prohibitions and Restrictions
  4. Control of Incinerators
  5. Process Industry Emission Standards
  6. Control of Fuel Burning Equipment
  7. Control of Volatile Organic Compounds
  8. Sampling, Testing, and Reporting<
  9. Visible Emissions Standards

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  10.  Control of Fugitive Dust
  11.  Toxic Air Pollutants Control
  12.  Vehicle Emissions Inspecting and Testing
  13.  Other Federal, State, Tribal, or Local Air Pollution Regulations not listed above
Hazardous Waste Management Regulations
   1.  Identification and Listing of Hazardous Waste (40 CFR 261)
         a.  Characteristic Waste
         b.  Listed Waste
   2.  Standards Applicable to Generators of Hazardous Waste (40 CFR 262)
         a.  Manifesting
         b.  Pre-transport requirements
         c.  Record keeping/reporting
   3.  Standards Applicable to Transporters of Hazardous Waste (40 CFR 263)
         a.  Transfer facility requirements
         b.  Manifest system and record-keeping
         c.  Hazardous waste discharges
   4.  Standards for Owners and Operators of TSD Facilities (40 CFR 264)
         a.  General facility standards
         b.  Preparedness and prevention
         c.  Contingency plan and emergency procedures
         d.  Manifest system, record keeping, and reporting
         e.  Groundwater protection
         f  Financial requirements
         g.  Use and  management of containers
         h.  Tanks
         i.  Waste piles
         j.  Land Treatment
         k.  Incinerators
   5.  Interim Status Standards for TSD Owners and Operators (40 CFR 265)
   6.  Interim Standards for Owners and Operators of New Hazardous Waste Land Disposal Facilities (40 CFR 267)
   7.  Administered Permit Program (Part B) (40 CFR 270)
   8.  Other Federal,  State, Tribal, or Local Hazardous Waste Management Regulations not listed above
Hazardous Materials Management
   1.  Control of Pollution by Oil and Hazardous Substances (33 CFR 153)
   2.  Designation of Reportable Quantities and Notification of Hazardous Materials Spills (40 CFR 302)
   3.  Hazardous Materials Transportation Regulations (49 CFR 172-173)
   4.  Worker Right-to-Know Regulations (29 CFR 1910.1200)
   5.  Community Right-to-Know Regulations (40 CFR 350-372)
   6.  Other Federal,  State, Tribal, or Local Hazardous Waste Management Regulations not listed above
Water Pollution Control Requirements

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   1.  Oil Spill Prevention Control and Countermeasures (40 CFR 112)
   2.  Designation of Hazardous Substances (40 CFR 116)
   3.  Determination of Reportable Quantities for Hazardous Substances
   4.  NPDES Permit Requirements (40 CFR 122)
   5.  Toxic Pollutant Effluent Standards (40 CFR 129)
   6.  General Pretreatment Regulations for Existing and New Sources
   7.  Organic Chemicals Manufacturing Point  Source Effluent Guidelines and Standards
   8.  Inorganic Chemicals Manufacturing Point Source Effluent Guidelines and Standards
   9.  Plastics and Synthetics Point Source Effluent Guidelines and  Standards (40 CFR 416)
  10.  Water Quality Standards
  11.  Effluent Limitations for Direct Dischargers
  12.  Permit Monitoring/Reporting Requirements
  13.  Classifications and Certifications of Operators and Superintendents of Industrial Wastewater Plants
  14.  Collection, Handling, Processing of Sewage Sludge
  15.  Oil Discharge Containment, Control, and Cleanup
  16.  Standards Applicable to Indirect Dischargers (Pretreatment)
  17.  Other Federal, State, Tribal, or Local Hazardous Waste Management Regulations not listed above
Drinking Water Regulations
   1.  Underground Injection and  Control Regulations, Criteria, and Standards (40 CFR 144, 146)
   2.  National Primary Drinking Water Standards (40 CFR 141)
   3.  Community Water Systems, Monitoring and Reporting Requirements (40 CFR 141)
   4.  Permit Requirements for Appropriation/Use of water from Surface or Subsurface  Sources
   5.  Underground Injection Control Requirements
   6.  Monitoring, Reporting, and Record Keeping Requirements for Community Water Systems
   7.  Other Federal, State, Tribal, or Local Hazardous Waste Management Regulations not listed above
Solid Waste Management
   1.  Criteria for Classifications of Solid Waste Disposal Facilities and Practices (40 CFR 257)
   2.  Installation of Systems of Refuse Disposal
   3.  Solid Waste Storage and Removal Requirements
   4.  Disposal Requirements for Special Wastes
   5.  Other Federal, State, Tribal, or Local Hazardous Waste Management Regulations not listed above
Toxic Substances
   1.  Manufacture and Import of Chemicals, Record Keeping and Reporting
   2.  Import  or Export of Chemicals (40 CFR 707)
   3.  Chemical Substances Inventory Reporting Requirements (40  CFR 710)
   4.  Chemical Information Rules (40 CFR 172)
   5.  Health and Safety Data Reporting (40 CFR 716)
   6.  Pre-Manufacture Notifications (40 CFR 720)
   7.  PCB Distribution Use, Storage, and Disposal (40 CFR 761)
   8.  Regulations on Use of Fully Halogenated Chlorofluoroalkanes (40 CFR 762)

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   9. Storage and Disposal of Waste Material Containing TCDD (40 CFR 775)
  10. Other Federal, State, Tribal, or Local Hazardous Waste Management Regulations not listed above
Pesticide Regulations
   1. FIFRA Pesticide Use Classification (40 CFR 165)
   2. Procedures for Disposal and Storage of Pesticides and Containers (40 CFR 165)
   3. Certification of Pesticide  Applications (40 CFR 171)
   4. Pesticide Licensing Applications (40 CFR 171)
   5. Labeling of Pesticides
   6. Pesticide Sales, Permits, Records, Application, and Disposal Requirements
   7. Disposal of Pesticide Containers
   8. Restricted  Use and Prohibited Pesticides
   9. Other Federal, State, Tribal, or Local Hazardous Waste Management Regulations not listed above
Environmental Clean-up, Restoration, Corrective Action
   1. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) (Superfund)
   2. RXRA Corrective Action
   3. Other Federal, State, Tribal, or Local Hazardous Waste Management Regulations not listed above

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  Workshop  Presentations  Articles and Reports | N.C. Certified Facilities N.C. Pilot Program  Links  Hot Topics

                                     Please provide your opinion of this site
                           Environmental Management Systems Home Page. This page was last modified on 04/04/2001.
                              Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                        1639 Mail Service Center - Raleigh NC 27699-1639
                                        (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                               Pollution prevention or EMS question or comment?  Send e-mail to: Beth Graves
                                   Site question or comment? Send e-mail to: Webmaster(a!p2pavs.org

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 Environmental Management Systems/ISO 14001

                Frequently Asked  Questions

D  What are ISO, ISO 14000, and ISO 14001?

   ISO stands for the International Organization for Standardization, located in
   Geneva, Switzerland. ISO promotes the development and implementation of
   voluntary international standards, both for particular products and for
   environmental management issues. ISO 14000 refers to a series of voluntary
   standards in the environmental field under development by ISO. Included in the
   ISO 14000 series are  the ISO 14001 Environmental Management System (EMS)
   Standard and other standards in fields such as environmental auditing,
   environmental performance evaluation, environmental labeling, and life-cycle
   assessment.
    How are these standards developed?

   All the ISO  standards are developed through a voluntary, consensus-based
   approach. ISO has different member countries across the globe. Each member
   country develops its  position on the standards and these positions are then
   negotiated with other member countries. Draft versions of the standards are sent
   out for formal written comment and each country casts its official vote on the
   drafts at the appropriate stage of the process. Within each country, various types
   of organizations can  and do participate in the process. These organizations
   include industry, government (Federal and State), and other interested parties,
   like various non-government organizations (NGOs). For example, EPA and States
   participated in the development of the ISO 14001 standard and are now
   evaluating  its usefulness through a variety of pilot projects.
    What are some  of the potential benefits  of an  EMS based on  ISO
    14001?
          Improvements in overall environmental performance and compliance
      E   Provides a framework for using pollution prevention practices to meet  EMS
          objectives
      E   Increased efficiency and potential cost savings when managing environmental
          obligations
          Promotes predictability and consistency in managing environmental obligations
         More effective targeting of scarce environmental management resources
          Enhances public posture with outside stakeholders

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Can existing environmental management activities be integrated
into the EMS  under 14001?

Yes. The standard is flexible and does not require organizations to necessarily "retool"
their existing activities. The standard establishes a  management framework by which
an organization's impacts on the environment can be systematically identified and
reduced.  For example, many organizations, including counties and municipalities, have
active and effective pollution prevention activities  underway. These could be
incorporated into the overall EMS under ISO 14001.
Questions from EPA Office of Wastewater Management
Back to To[
Back to Home

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Management
                      Environmental
      v                 — —
   \           j     Management
  Checking    Implementation
  Corrective
   Action
                      Systems
Home EMS FAQs ISO 14001 Information I EMS Design Tools I Sector-Specific Information I EMS Case Studies
 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program  Links  Hot Topics
EMS Workshop  Presentations  -

ISO  14001: The Nuts and  Bolts of Getting  It

Done


Speaker Bios:

    Terry Albrecht is the program director of Waste Reduction Partners, which works in partnership with
    the N.C. Division of Pollution Prevention and Environmental Assistance (DPPEA). For the past nine
    years, Albrecht has provided industries with on-site pollution prevention audits, training and outreach.
    He has co-authored numerous publications and manuals including: Waste Reduction Programs for
    Commercial/Industrial Solid Waste and Water Efficiency Manual for Commercial, Industrial and
    Institutional Facilities. He was a member of the N.C. DENR Working Group on ISO14001 and has
    received ISO 14001 lead auditor training. Terry holds both bachelor's and master's degrees from N.C.
    State University in civil and environmental engineering and is a professional engineer in North Carolina.
    Albrecht has also worked as a manufacturing engineer for Eaton Corporation, as an environmental
    consulting firm engineer, and as a sanitation/water supply engineer in Ecuador, South America - totaling
    12 years in environmental experience.

    John Burke is an environmental engineer with DPPEA. Burke has been involved in more than 100
    on-site industrial waste assessments, providing assistance in areas ranging from toxicity reduction and
    solid waste recycling to production efficiency improvements. He has also worked with several
    companies and municipalities to implement the ISO 14001 Environmental Management System and
    developed a number of seminars related to industrial wastewater issues.

    Karen Czor is a Registrar Accreditation Board (RAB) approved lead auditor and a member of the
    American Society for Quality. Czor has completed the ISO 14000 Lead Auditor Training course. She
    has developed and implemented corporate-wide ISO 9000 and ISO 14000 management systems for
    clients in the construction, hazardous waste and explosives industries. Czor also is an experienced
    consultant in the fields of environmental management, hazardous waste treatment and safety

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engineering. She received a B. S. in physics from Eastern Kentucky University and an M.S. in physics
from the University of Tennessee.

Gary Davis is an environmental engineer with the Ford Norfolk Assembly Plant. Davis has been with
Ford since 1990 and has worked on the production floor as an hourly and production supervisor, and
currently serves as the ISO 14001 coordinator for the plant. Davis has also been involved with ISO 9001
since  1995 and worked collaboratively with three colleagues at other Ford Plants in developing an
Environmental Quality Operating System (QOS) in 1994, as part of an effort to develop an
Environmental Management System to be utilized throughout Ford. Prior to joining Ford, he worked for
three years at the N.C. Department of Marine Fisheries as a marine biologist, based in Elizabeth City.
While still in college, Davis worked as a hazardous waste technician for the UNC-Chapel Hill Health
and Safety office. Gary holds a B.A. in biology from UNC-Chapel Hill.

Bob Devlin is currently manager of the environmental management group with Ford Motor Company's
Environmental Quality Office. The environmental management group is responsible for Ford's
Corporate Citizenship program, ISO 14001 global certification, and supplier environmental
requirements. Devlin has been with Ford's Environmental Quality Office since 1977, and has a diverse
environmental background in environmental stack sampling, odor analysis, compliance assurance
auditing and compliance assurance program development. He is an accredited ISO 14001 lead auditor
and a certified hazardous waste manager (CHMM).

Steve Freeman is the registration program leader for Underwriters Laboratories Inc. Freeman has seven
years  experience in management systems auditing and currently serves as program manager for
Underwriter Laboratories' ISO 14001 program. He is an ISO 14001 lead auditor, ISO 9000 lead auditor,
RAB  lead auditor, certified environmental auditor and has performed over 300 audits. Freeman has 20
years  of industrial experience, including serving as technical director and quality assurance manager at
ITT and serving as technical director and manufacturing manager at Litton.

Joe Fleming currently serves as environmental coordinator and safety officer and oversees the ISO
14001 program at Philips Communications Security & Imaging Inc. Fleming is a quality manager with
certification from the American Society of Quality and has held quality responsibilities for various firms
over the past 30 years. He has been the quality representative for Philips since 1993. Fleming received a
B.S. in metallurgical engineering from Grove  City College.

Rick Gehrke serves as Southeast regional account executive for NSF-ISR's quality and environmental
management system registration program. His background is primarily in diversified management and
environmental science applications, including consulting, auditing, training and project management.
Gehrke is an experienced environmental auditor who has led ISO 14001 registration audits since the
standard was first released in 1996.

Susan Graff is president of Environmental Resource Services, a company she started in Atlanta, Ga., in
1997 with a commitment to providing clients sound environmental strategies that enhance business
performance. Graff has 20 years of experience in environmental management and regulatory
compliance.  Her areas of expertise include corporate policy analysis, training, environmental  auditing
and assessments, stakeholder outreach and system implementation. Graff's most recent projects involve
consulting on strategic environmental management programs, including ISO 14000, for a diverse group
of industries in the United States and South America. Prior to starting her company, she worked for  the
U.S. Environmental Protection Agency (EPA), managing waste management programs at over 5,000
facilities throughout the southeastern United States. Graff led teams to  conduct site assessments, RCRA
corrective action, and community relations at controversial hazardous waste cleanup sites. Her
accomplishments include implementing EPA's regulatory reinvention through use of team-based
approaches for use in environmental project management and also leading design of the Superfund
Accelerated Cleanup Model for integrated assessment. Graff is a member of the U.S. Technical

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Advisory Group to ISO Technical Committee 207, and a registered environmental auditor with the UK
EARA. She is a graduate of the Georgia Institute of Technology, where she conducted interdisciplinary
research on environmental risk and technology assessment. Graff obtained an M.S. in technology and
science policy and received a Public Fellowship Award. Susan also holds a B.S. in biology from
Western Illinois University.

Beth Graves serves as Environmental Management Systems (EMS) project coordinator in the N.C.
Division of Pollution Prevention and Environmental Assistance (DPPEA). Graves oversees the EMS
Pilot Program as well as participates in the Multi-State Working Group (MSWG) and the U.S. Technical
Advisory Group to ISO Technical Committee 207. She provides technical assistance to industry, local
governments and other staff in the Department of Environment and Natural Resources (DENR) on EMS
and coordinates DPPEA's EMS Web site and workshops. Graves began working for DPPEA in 1993
first with the Community and Business Assistance section providing technical assistance to local
governments and businesses regarding integrated solid waste management programs, and providing
research and materials development support, particularly in the areas of composting and source
reduction.

Denis Hargens is the senior environmental engineer for Bridgestone/Firestone-Wilson, N.C., and has
served in this role for eight years. Prior to joining Bridgestone/Firestone, Hargens  has 14 years of plant
and project engineering experience in the roofing industry. Hargens has a B.S. in mechanical
engineering from the South Dakota School of Mines and Technology.

Chris Kappert is currently employed at Konica Manufacturing U.S.A., where he  is the information
systems team leader. In this role, he is pushing the company's management systems for environment and
quality to being paperless. Back in 1998, he was the lead in the two-person team that implemented ISO
14001 at Konica, and in 1996 he completely revised the company's ISO 9002 system. Prior to working
at Konica, Kappert was responsible for the Nuclear Quality Assurance Program aboard the navy aircraft
carrier U.S.S. Nimitz.

Ron Lak has worked with Uniroyal Chemical Company for 27 years, spending the last 17 years in
Gastonia, N.C. While at Uniroyal, Lak has held various positions in project engineering, process
engineering and environmental engineering. Currently, he is the  operations manager in the urethane
department for the Gastonia plant. Lak's duties include assurance that all new or improved processes
introduced into the plant meet all environmental requirements, overseeing legal aspects of
environmental programs and regulations, and serving as a team member on the facility's ISO 14001
steering committee. He has a B.S. in chemical engineering from  Worcester Polytechnic Institute and an
MBA from the University of New Haven.

Jim Laney is assistant manager of ASMO Greenville  of North Carolina Inc. Laney serves as safety,
environment & facilities registered environmental manager (REM). He has 15 years of experience in
manufacturing, with eight years in the automotive supplier industry. Laney has five years of experience
in the environmental & safety field. He is a graduate of East Carolina University.

Jason Morrison  is a senior associate of the Pacific Institute.  He heads the Institute's Economic
Globalization and the Environment Program, where he is currently studying the public policy
implications of private sector environmental initiatives and voluntary international standards, with a
focus on the environmental management standards — ISO 14000. Morrison is the lead author of a recent
Pacific Institute report, entitled "Managing a Better Environment: The Opportunities and Obstacles for
ISO 14001 in Public Policy and Commerce." He is a member of the U.S. Technical Advisory Group to
ISO Technical Committee 207,  as well as a U.S. delegate to Subcommittee 3 (Ecolabeling), and to
Subcommittee 5 (Life Cycle Assessment).  Morrison is a non-governmental organization (NGO)
participant of the Multi-State Working Group on Environmental Management Systems, and a founding
member of the NGO Working Group on ISO 14000. He holds a B.A. in philosophy from the University

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of California, San Diego, and a master's degree from Boston University's Center for Energy and
Environmental Studies. Morrison was a fellow with the Americans and World Affairs Fellowship
Program in Berkeley, Calif. In addition to heading the Institute's Trade, Economic Globalization and the
Environment program, he works on issues relating to water and sustainability.

Norma Murphy joined the N.C. Division of Pollution Prevention and Environmental Assistance in
1993 as an environmental chemist. She now serves as the Industrial Section outreach and training team
leader. Murphy's primary responsibilities include coordinating workshops and training sessions on
pollution prevention and environmental management for industries, commercial establishments and
other government agencies. Her areas of significant experience include food processing, water
conservation, employee training and ISO 14000. Murphy has a B.S. in chemistry from Meredith
College.

Jennifer Pierce is responsible for maintaining Novo Nordisk's ISO 9001 certification, along with other
quality assurance functions related to ensuring "customer quality assurance" including customer
complaints and product specifications. She became involved in implementing ISO14001 atNovo's site
mainly to ensure integration of the two systems.

Scott Plemmons is quality manager for Cutler-Hammer in Asheville. The Asheville facility was
awarded ISO 14001  certification in July 1999, and Plemmons was instrumental in assisting the company
to obtain certification.

Ron Pridgeon joined the N.C. Division of Pollution Prevention and Environmental Assistance in 1991
as an environmental engineer. He now serves  as the Industrial Section technical assistance team leader.
Pridgeon's primary responsibilities include  coordinating technical assistance to North Carolina
industries  in pollution prevention and environmental management.  His areas of significant experience
include furniture manufacturing, coatings applications, boat building and ISO 14000. Pridgeon holds a
B.S. in industrial engineering from N.C. State University.

Jack Rockstad is the Dowty Aerospace North American environmental  director and also serves as the
operations manager at NCI Inc. in Asheville. Rockstad has previous experience with facilities
management and plant engineering; has served as purchasing manager, electronic technician and safety
director; and is a licensed electrician. He has his OSHA 80-hour certification.

Steve Ross is the environmental manager for Purolator Products, a 700,000 sq. ft. manufacturing facility
in Fayetteville, N.C. The facility is QS 9000 and ISO 14001 certified. Ross was one of the core team
members instrumental in the ISO certification process.

Barb Satler is an environmental specialist with the N.C. Division of Pollution Prevention and
Environmental Assistance (DPPEA). She has  10 years experience in the  field of waste reduction.
Satler's focus is on outreach and training, providing technical assistance  and coordinating the
Governor's Award for Excellence in Waste Reduction. She is a member  of the Department of
Environment and Natural  Resources quality guidance team and is a certified Baldridge Examiner.

Suzanne Sessoms is with Excel Partnership in Wilmington, N.C., and has over 15 years of experience in
engineering and business management. Sessoms is a RAB-certified lead  auditor for ISO 1400, with
expertise is developing environmental management systems including compliance strategies, risk
management and pollution prevention. Prior to working with Excel, she worked for Corning Inc. in
Wilmington where she was involved with implementation of Total  Quality Management (TQM) and
ISO 9000. Sessoms received a degree in chemical engineering from the Georgia Institute of Technology.
She is also a licensed professional engineer in North Carolina, South Carolina and Florida.

Rahul Thaker currently reviews state and federal air permits in his work at the North Carolina Division
of Air Quality. Thaker is  a professional environmental engineer and holds both bachelor and masters

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      degrees in civil and environmental engineering. He has completed the lead auditor training course on
      ISO 14001.  Thaker has nine years of environmental engineering experience, encompassing multimedia
      environmental regulatory and technical issues. Prior to his work with state government, he worked for
      consulting engineering companies.

      Mark Warner is a registered environmental manager and is in charge of the environmental engineering
      department  at the Mercedes-Benz plant in Tuscaloosa, Ala., which was certified to the ISO 14001
      standard in September 1999. He has been with Mercedes since January of 1996. Warner started his
      career at the Chemical Manufacturers Association (CMA) in Washington, D.C., as manager of air
      programs, and was heavily involved in the development of the Clean Air Act Amendments of 1990.
      Since CMA, he has held corporate environmental coordinator positions at American Standard Inc. (New
      Jersey/New York City) and Vulcan Chemicals (Birmingham, Ala.) and has had general corporate
      oversight responsibility for approximately 35 domestic manufacturing plants during that time. Mark
      received his B.S. degree from The Catholic University of America (Washington, DC) where his major
      areas of study were chemical engineering and biochemistry.

      Peter Wise is a senior consultant and principal of Kestrel Management Services LLC. He has over 30
      years of experience as an environmental professional  in the private sector and in state and federal
      government. At Kestrel, he assists clients with consulting, training and facilitation in the areas of
      environmental management systems, regulatory affairs, strategic planning and environmental systems
      optimization. Wise serves as vice chair of the Multi-State Working Group on Environmental
      Management Systems (MSWG), where he chairs MSWG's research task team on environmental
      management systems. He chaired the National Research Summit on Environmental Management
      Systems hosted by the Brookings Institution in 1999.  Wise has written several published articles on
      environmental innovation. Prior to joining Kestrel,  he was the associate director of the Illinois EPA,
      where he managed the agency's pollution prevention  program, the EMS pilot program, public affairs,
      community  relations, the Office of Small Business, the total quality management effort and the
      environmental education program. Wise also worked  as group senior vice president for Science
      Applications International Corporation (SAIC). With  the EPA for more than 10 years, he directed the
      water planning program and oversaw the water quality standards program and the effluent guidelines
      program.  Wise also directed the agency's Great Lakes National Program Office and served as acting
      deputy regional administrator for Region V.

      Danny Yount has been with ASMO North Carolina Inc. for 10 years and  serves as an environmental
      engineer. Yount was part of a five-member team that  implemented ISO 14001. Before working at
      ASMO, Yount worked for Thonet in Statesville for five years as an industrial engineer and safety, health
      and environment personnel.
Home  EMS FAQs ISO 14001 Information | EMS Design Tools I Sector-Specific Information | EMS Case Studies
 Workshop Presentations Articles and Reports | N.C. Certified Facilities  N.C. Pilot Program Links  Hot Topics


                                    Please provide your opinion of this site
                          Environmental Management Systems Home Page. This page was last modified on 04/03/2001.
                            Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                      1639 Mail Service Center - Raleigh NC 27699-1639
                                      (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                             Pollution prevention or EMS question or comment?  Send e-mail to: Beth Graves
                                 Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

-------

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Management
 Review
  Checking
  Corrective
  Action
  Pbnning
   f

Implementation
Environmental
 Management
Systems
Home EMS FAQs ISO 14001 Information I EMS Design Tools I Sector-Specific Information I EMS Case Studies

 Workshop Presentations Articles and Reports I N.C. Certified Facilities N.C. Pilot Program Links Hot Topics
EMS Workshop Presentations -
ISO 14001: The Nuts and Bolts of Getting It
Done - Workshop Pictures

Beth Graves, N.C. Division of Pollution Prevention and Environmental Assistance
John Burke, N.C. Division of Pollution Prevention and Environmental Assistance

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Suzanne Sessoms, Excel
Chris Kappert, Konica Manufacturing USA
Steve Freeman, Underwriters Laboratories Inc.
Jason Morrison, Pacific Institute
Danny Yount, ASMO North Carolina Inc.

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Rahul Thaker, Division of Air Quality
Home  EMS FAQs  ISO 14001 Information | EMS Design Tools I  Sector-Specific Information | EMS Case Studies
  Workshop Presentations  Articles and Reports I N.C. Certified Facilities  N.C. Pilot Program  Links   Hot Topics
                                          Please provide your opinion of this site
                              Environmental Management Systems Home Page. This page was last modified on 05/18/2001.
                                 Site hosted by the NC Division of Pollution Prevention and Environmental Assistance.
                                             1639 Mail Service Center - Raleigh NC 27699-1639
                                            (919) 715-6500/(800) 763-0136 - fax (919) 715-6794
                                   Pollution prevention or EMS question or comment? Send e-mail to: Beth Graves
                                       Site question or comment? Send e-mail to: Webmaster(g)p2pavs.org

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                     AGENDA
                  Thursday, May 14,1998
       Embassy Suites Hotel, Gary, North  Carolina
9:00 a.m.-4:30 p.m.
      Opening Remarks
      Henry Lancaster, Deputy Secretary, North Carolina Department of Environment and
      NaturalResources

      Welcome
      Ravila Gupta, North Carolina Department of Environment and Natural Resources
      jay Benforado, United States Environmental Protection Agency Office of Reinvention
      Robert Stephens, California Environmental Protection Agency

      Multi-State Working Group (MSWG):
      Mission and Future Activities
      Robert Stephens, California Environmental Protection Agency and Chair of MSWG

      BREAK

      National  Database  and Data Collection Efforts
      Jim Home, United States Environmental Protection Agency
      John Villani, University of North Carolina - Chapel Hill

      North Carolina Pilot Projects
      BethGraves, Division of Pollution Prevention and Environmental Assistance, Moderator
      Sean Bir, Konica Manufacturing USA
      Peter Self, Motorola
      Matt Caton, Lufkin/CooperTools

      LUNCH 12:30-1:45

      Dawn Sudmeyer, Marine Corps Base, Camp Lejeune
      Doug Gaylord, Honda Power Equipment
      DavidRachels, Exide Electronics

      Pilot Project Panel  Discussion

      BREAK

      MSWG Regulatory  Framework
      Dave Ronald, Arizona Attorney General's Office

      North Carolina Permit Reform Project
      Dan Bius, Environmental Permit Reform Team Leader

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  •     "*~^     ^^^
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CO   rt     ii
                                          AGENDA
                                         Friday, May 15,1998
                              Embassy Suites Hotel, Gary, North Carolina
                       9:00 a.m. - Noon
                             Other State Perspectives - EMS Pilot Projects / EMS Programs
                             Marianne. Fitzgerald, Oregon
                             Stacy Richards, Pennsylvania
                             Lynda Wiese, Wisconsin
                             Peter Wise, Illinois

                             EPA Position on ISO 14001/EMS
                             Mary McKiel, United States Environmental ProtectionAgency
                             Jim Home, United States Environmental Protection Agency

                             Non-Governmental Organizations' Views

                             jerry Spier, Tulane Law School
                             Jason Morrison, Pacific Institute
                             Erilc Meyers, Environmental Law Institute

                             Industry Views
                             Jim Connaughton, Coalition for ISO Implementation
                             John Harris, Chemical Manufacturer's Association

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                                        Chapter 1: Process Mapping
     Green Zia Environmental Excellence Program
The Nothing to Waste Program:  Incorporating Pollution
Prevention
              into Small Businesses
 The  Green Zia  Environmental Excellence Program is  a
 voluntary program of the New Mexico Environmental Alliance
 designed to assist all New Mexico businesses, from the largest
facility to  the smallest corner  business, achieve environmental
 excellence  by implementing pollution prevention  and energy
 efficiency programs.

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                                              Chapter 1: Process Mapping
A cknowledgem ents
Special thanks to....

Dr. Robert Pojasekfor his assistance in developing the Green Zia
Environmental Excellence Program.

The Nothing to Waste Program was developed as a project of Working
Capital, Grove Hall NDC, Green Island/Vernon Hill CDC, Tufts University
New England Environmental Network and Dr. Robert Pojasek with funding
provided by the US Environmental Protection Agency.

Manual printed with funds provided by the US Environmental Protection
Agency in a grant to the New Mexico Energy, Minerals and Natural
Resources Department and the New Mexico Environment Department.
For more information on the Systems Approach tools used in the Green Zia
Environmental Excellence Program, please call Dr. Pojasek at (781) 641-2422

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                                                Chapter 1: Process Mapping
Introduction:   Incorporating  Pollution
Prevention
The "Nothing to Waste Initiative introduces pollution prevention as a core
component of business management. The minimization of waste and the
maximization of efficiency are important to micro-business viability and to
protecting the environment.

The following six tutorials have been developed to demonstrate the key
principles of pollution prevention.  Entrepreneurs are encouraged to
immediately and continuously apply these pollution prevention concepts
toward their businesses,

The process of applying pollution prevention includes examining the
business process, identifying material loss, identifying the cause of the loss,
generating possible solutions, selecting an alternative and implementing an
action plan to prevent material loss and reduce costs.  The tutorials walk
through the process, each building upon the strategy presented in the
previous tutorial.  After you complete all six tutorials, you will be asked to
answer several summary questions to determine whether the tutorials
develop the critical skills intended.

The six pollution prevention tutorials are briefly outlined below:

1.  Process mapping: Process mapping determines the steps materials pass
   through as they are transformed into the final product.  These maps  allow
   for the identification of all inputs to and outputs from a process, making
   wastes, or losses, evident.

2.  Activity-based costing: This method helps you identify key losses and
   total dollar value of these losses. The Pareto principle suggests that 80%
   of the problems in a business come form 20% of the machines, raw
   materials, or operators. (The same is true for any facet of business.  For
   example, 80% of sales come from 20% of customers, etc.) We will

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                                                   Chapter 1: Process Mapping

   demonstrate this principle by assigning costs to each loss in the process, a
   technique known as activity-based costing.

3. Root cause analysis:  The underlying reason for a loss is known as its
   "root cause". A cause and effect diagram is one way of determining the
   root causes for losses. By producing a diagram participants can see why
   and where losses occur in the process. Once the diagram is complete, a
   group "Dear Abby" letter will be written as a definitive statement of the
   problem to ensure that all participants are in agreement and can identify
   the reason for the loss.

4. Brainwriting: Because there are many ways to address a problem, this
   exercise is designed to help participants generate as many alternatives as
   possible to minimize loss. Each participant writes two ideas on a sheet of
   paper, the papers are exchanged, and two more ideas are written.  This
   process continues until all ideas are exhausted. The team then discusses
   the ideas and produces a viable list of alternatives.

5. Bubble-up/bubble-down: Bubble-up/bubble-down is just one of the
   many evaluation methods available for ranking alternatives to determine
   the optimal solution.  The list of alternatives is ranked by comparing the
   first two items,  arranging them by order of preference, and continuing the
   process for the second and third items, etc., until the entire list is ordered.
   Considering each option with such factors as cost, implementability, and
   effectiveness will help identify the best alternative.

6. Action Plan:  Now that the pollution prevention opportunity/opportunities
   have been identified and alternatives have been discussed, it is time to
   develop an action plan. This plan details the steps that need to be taken
   to implement the alternative and reduce or remove the  loss from the
   process.

Each of these tutorials will take approximately 60 to 90 minutes to complete.
We hope you will find the tutorials enjoyable and useful in your future
management practices.

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                                                   Chapter 1: Process Mapping
Tutorial 1
      Process Mapping
Tutorial 2
      Activity Based Costing
Tutorial 3
      Root Cause Analysis
Tutorial 4
      Brainwriting
Tutorial 5
      Bubble-up-bubble-down
Tutorial 6
      Action Plan
1

9

25

35

45

55

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                                                Chapter 1: Process Mapping
Tutorial 1: Process Mapping
To begin incorporating pollution prevention into your business, you must
first  get a full understanding of where wastes are being generated. This
tutorial will  discuss the advantages of using  process maps to logically
evaluate each step of your process.
Warm-up Exercise
                            Maps have been used throughout the  ages
                            for  many purposes from  helping  sailors
                            navigate the seas to providing a safe route
                            for climbers hiking to the tallest peaks. You
                            have probably drawn maps to your home or
                            office so  that  someone  could visit.  It is
                            important that the information on this map
                            is complete  and accurate or,  as you  may
                            have found, your guest will get lost!
Take a minute now and think of a coffee shop or restaurant nearby that
everyone in the  group knows. Draw a map from the building you  are
currently in to this establishment - include traffic lights, landmarks, and any
other important features along the way. Now compare maps with the other
members of your group. Are they the same? If a person not familiar with the
area was to use your map, would they have found their way?

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                                                  Chapter 1: Process Mapping
Introduction
Are you aware of the amount of waste that your business generates? Could
this waste be turned into profit? By considering methods of reducing wastes,
recycling used and unused raw materials, and reusing lost material you could
not only help the environment but also reduce your raw material and waste
disposal costs.

This tutorial discusses process mapping, a method of analyzing a process in
order to catalogue all the materials used and lost in the process. With process
mapping, you  will systematically identify the series of steps materials pass
through as they are transformed into the  final product.  Evaluating  your
process in this manner will  allow you  to recognize the opportunities to
prevent losses and  possibly streamline operations. Each loss identified
during the process mapping is an opportunity to prevent that loss.

During this exercise you will:
Objectives
   Fully understand the functionality of each step of a process.
   Identify the inputs and outputs/losses within the process.
   Communicate findings in a clear and concise manner.
Basic Instructions
This tutorial should be completed by your Green Zia Group.
Please read aloud from here on.
Allow 60minutes to complete.

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                                                  Chapter 1: Process Mapping
Process mapping and Discount Signs
Jim Davis, a Green Zia participant, arrived at his Green Zia Group meeting
full  of enthusiasm.  He had attended a  training session on pollution
prevention the previous evening and was surprised to discover the many
opportunities  for pollution  prevention in his business. He  was excited to
share his findings  with the group and help them discover opportunities in
their businesses.

"Last night I attended a session on pollution prevention and I would like to
repeat an  exercise  we  did  on  process  mapping,"  said  Jim. "Process
mapping," he continued, "is a method of identifying and documenting every
input and output in a process by logically evaluating each process step."

"Let's start by looking  at my  sign business," said  Jim.  Jim has  been
operating Discount signs for five years and has recently been able to expand.
His customers range  from other small businesses in the area to consumers
looking for unique gifts. The  metal signs he produces  come in  a variety of
standard colors and  sizes.  Jim  stressed the importance of asking many
questions during the exercise to be sure not to miss any losses.

"When  I  receive  an  order,  I first cut  a piece of metal  to  fit the
specifications," Jim began.

"Do you have a lot of scrap metal?" asked Cecilia.

"Well," said Jim, "that's a good question. Sometimes I do have a lot of scrap
metal. It depends on  the size of the sign I'm making. Normally  I just throw
the scrap metal away."

"Next I clean the metal to remove any dirt and oil," he continued.

"What exactly do you use to clean the metal?" asked John.

"Just soap and water," he answered.

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                                                  Chapter 1: Process Mapping

"Next I brush on a primer to get the part ready for painting and, once that
dries, I rinse it in the sink. The paint doesn't stick if I leave out these steps."

"Finally, I paint the signs to meet the customer s specifications. Sometimes I
have bottles of half-used dried-up paint that I throw away: this is one of my
losses that I would like to reduce."

"Do you package the  signs for  your customers,"  asked  another group
member.

"I used to package all the signs in bubble wrap and then place them in a box,
but I stopped doing that. Finding the right  size boxes was difficult and
expensive,  and half the  boxes would end up in the garbage  in front of my
store. Now I use my delivery company to package the few signs that I have
to mail  out to customers. I guess you could say I already identified that
opportunity!"

"What about defects?  Do you have a lot of defects? And do you reuse the
metal if you can?"

"Do you have many spills? With the paint  and paint thinner laying around I
would think you have spills from time to time." asked members of the group.

"I never thought about those things," replied Jim. "You're right I do have an
occasional  defect that makes its way into the trash. Normally the defects are
due to cutting the metal too small or making a mistake with the  lettering. If
it's just a lettering mistake I remove the paint with some thinner and salvage
the part, but if I cut the metal to the wrong specifications, I throw it out. I
should really think of that some more. As for the spills, I try to keep a clean
shop to keep spills at a minimum but I do have an occasional spill."

Now that the group talked about the process in detail  and discussed all the
inputs and outputs, the next step was to create the process map.

"Let's present all this information pictorially by creating  a process map,"
said Jim. "Make  a box and define the first step with a one or two word
identifier such as Cut Metal. Put an arrow into the top of the box for  each
input and put an  arrow coming from the bottom of the box for each  loss.
Then draw an arrow from the right side of this box into the next box, defined

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                                                  Chapter 1: Process Mapping

by the  second step. Continue this procedure  until the entire process is
defined."

The group began mapping the process. (See Figure 1)

 "As you can see," said Jim, "my inputs are metal, soap, rags, water, paint,
and paint thinner, and  my  losses are  scrap metal, soapy water, used rags,
paint, and paint thinner. Each of these losses is actually costing me money so
reducing them will translate into additional profits. Plus if I can reduce these
losses I will be helping the environment.  Definitely a win-win situation."

"I can see how you can benefit from pollution prevention," said Benito, "but
I own a small restaurant. I  don't see how pollution prevention can help me
make sandwiches."

Jim replied, "Don't you have any losses?  Stale bread,  napkins, or maybe
cleaning products?"

"Yes," responded Benito.

"Well, where there is a loss, there is an opportunity to prevent that loss. Let's
look at your operation next time."
Discussion Questions/Activities
  1.   What did Jim discover by creating a process map?

  2.   How was Jim preventing pollution in his business? How was he
      benefiting from it?

  3.   What did Jim discover by discussing his process with his  Green Zia
      Group?

  4.   Use the attached form to create a process map of your operation. You
      may need to modify this map by  adding or removing more boxes,
      arrows, etc.   Explain your  operation to the  group by walking them
      through your process map.
10

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                                               Chapter 1: Process Mapping


5.   Bring your process map to your business.  Go through your process
    step-by-step ensuring that you have not left out any steps or materials.
    Update your  process map, if  necessary, and bring it to  the  next
    meeting: you will need to refer to it.

6.   Did you find this tutorial useful? Why or Why not?

7.   Were the tutorial  exercises clear? If not, please specify which  ones
    were unclear and why.
 At the next meeting, Activity Based Costing mil be presented
             to examine the value of material losses.
                                                                 11

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                                                      Chapter 1: Process Mapping
                                  Process Map
12

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                                                                Chapter 1: Process Mapping
                       Figure  1: Discount Signs Process Map
  metal

 J_
                                           soap
                                  water
                                                  rags
                                                                                        brush
                                          primer
 Cut Metal
                                        Clean Part
                                                                                Prime Part
scrap metal
                                                 k
soapy water
                                                  rags
                                                        f
                                                                            primer
                                                                                     used brushes
  water
   1
                                        paint thinner
                                paint
                                                  brushes
 Rinse Part
                                          Paint
                                  ( FINISHED
                                      PART
                                  V          /
   T
  water
                            paint
                                                    defects
                                           used brushes

                                    paint thinner
                                                                                         13

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                                            Chapter 2: Activity Based Costing
Tutorial 2: Activity Based  Costing
Every waste or environmental loss costs you money. By determining the
activities that cause waste, you can focus your pollution prevention efforts to
minimize the cost to your business and protect the environment. This tutorial
will introduce you to a method of evaluating your waste.
Warm-up Exercises
                         Your daughter  approaches you one evening
                         and says that she is planning to buy a car. With
                         the $400 she has  left over each month, after
                         paying all of her bills, she is sure she will be
                         able to afford the $220 monthly car payment.

                         What are the other  costs of operating and
                         maintaining  a  car  that  she  is  forgetting?
Consider not only the  annual  costs,  such as insurance, but  also the
intermittent (once in a while) costs. Can she really afford this car?
14

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                                              Chapter 2: Activity Based Costing
Introduction
Once you have  determined the losses in your process,  you can begin to
discover how these losses are affecting your "bottom line". How much does
it cost you to discard 10% of your raw materials, or 2% of your finished
products?  Which activities have losses that most hurt the profitability of
your company? In this exercise we will take a look at the cost of the losses
in your business and see how much these losses are costing you. The results
may surprise you!

Activity based costing, or ABC, is a method of accounting for a certain type
of cost by assigning  each cost to the activity that generates it. In the warm-
up  exercise you used ABC  to  account  for  all the costs associated with
operating a car, now  you will use ABC to account for all the costs associated
with the losses in your business,  also  called your environmental  costs.
Environmental costs include the costs of raw materials that are discarded,
fees paid for hazardous materials disposal, and regulatory fines associated
with a loss to name  a few. As you  saw in the warm-up  exercise, there are
many hidden costs that should not be overlooked.

Which losses should you  be most concerned about? The Pareto principle, or
80/20 Rule, suggests that  80% of the problems  in a business come from 20%
of machines, raw materials, or operators. (The  same is true for any facet of a
business, for example, 80% of sales  comes from 20% of the customers, etc.)
Once you have assigned  costs to your activities, you can figure out  which
20% of your activities are contributing 80% of your costs. A Pareto diagram
visually depicts total costs for each activity, making the biggest cost-drivers
very apparent. The most prominent pollution  prevention opportunities can
then be targeted for improvement.

During this exercise you will:
Objectives
          Identify all the environmental costs in a process (that is, the costs
          associated with your losses).
          Assign each cost to an activity.
          Create a Pareto diagram depicting the total cost for each activity.
                                                                     15

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                                               Chapter 2: Activity Based Costing
Basic Instructions
          This tutorial should be completed by your Green Zia Group.
          Please read aloud from here on.
          Complete all exercises as they appear.
          Allow 90 minutes to complete.
          Please have the process map you created in the last exercise
          readily available. You will need to refer to it.
New Terms
Activity based costing (ABC) - An accounting method used to assign the
cost of your losses to the activities that generate these losses. By assigning
costs to activities, you will discover the activities should be  targeted for
prevention.

Environmental costs -The costs associated with the losses in your process.

Pareto principle - A principle that suggests that 80% of anything can be
attributed  to 20% of the factors  involved. For example, 80% of  your
environmental costs can be attributed to 20% of your activities.

Intermittent operations - Operations that occur once in a while.
16

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                                               Chapter 2: Activity Based Costing
Activity Based Costing in a Restaurant
Benito runs a small restaurant in downtown Farmington. After attending the
session on process mapping, he is still unsure of how pollution prevention
can work in his business. Benito decided to create a process map of his most
popular lunch item, a chicken  sandwich, to see if he could identify the
losses, (see Figure 1)

"I mapped out the process of making a chicken sandwich," said Benito at his
Green Zia Group meeting, "and I found several losses. Most of my losses
have to do with food being spilled, such as bread and chicken. But I  also
have several losses associated with cleaning the restaurant. I'm not sure how
this ties into my process. But these losses are very important to  me because
they cost me a lot of money."
"That  activity," said Jim, "is called an  "intermittent operation",  or an
operation that occurs once in a while. Intermittent operations can be mapped
separately."

"I see. The preparation area is visible to all the customers. Having food and
ketchup all over this preparation area, as well as  on the floors where the
customers wait, and below the tables where people eat, is very unappetizing.
Preventing spills  will go a long way towards keeping these areas  clean.
Keeping the  floors clean is very difficult, especially when we are  at our
busiest between 11:30 am and 1:30 pm. The other reason I like to maintain a
clean restaurant is because  I  never  know when the Farmington Health
Department will be coming in to do  its annual  inspection.  The inspection
always goes better if the restaurant is tidy."

"What do I do next?" asked Benito.

"The next step," said Jim, "is to determine the losses (and thus the activities
where these losses occur) that drive your costs. You will assign dollar  values
to each loss  by the activity that generates it. Then we  can  evaluate the
activities that are costing you the most. First you need to summarize all your
activities and all your losses. List all your activities as they  appear on your
                                                                     17

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                                               Chapter 2: Activity Based Costing


process map and any intermittent activities that may be important.  Then you
can summarize your losses."

Benito listed his activities:

List of Benito's activities:
Clean working surface
Take order
Cut bread
Make sandwich
Wrap sandwich
Clean restaurant
Exercise
Make a list of all the activities in your operation. Be sure to include the
activities from your process map as well as any intermittent operations (such
as cleaning or maintaining equipment.)

Benito then began to look at his losses. Again he referred to his process map.
Benito's losses  include soapy water, paper, bread wrappers,  improperly cut
bread,  crumbs,  odd  pieces, etc.,  food wrappers, chicken,  cheese, etc.,
mistakes, containers, condiment spills, and sandwich wrappers. Other losses
not on Benito's process map include cleaning agents, dirty rags, etc.
Exercise
List all of the losses in your operation. Look on your process map and add
any others that you think of.

"Great,"  said Jim. "Now start to think about all the types of costs that are
associated with these losses. When you think about the mistakes you have
when you make a sandwich, don't just include the cost of the raw material
that gets thrown away. There are other costs too. For example, the cost of the
time spent making the sandwich and the cost of the unhappy customer that
waits too long."

Benito summarized  his  cost  categories.  "Well,  there  are  many  costs
associated with the wasted raw materials; bread, chicken, cheese, vegetables,
condiments etc. I have to store these products this also costs me money. The
18

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                                               Chapter 2: Activity Based Costing

other costs that are associated with the mistakes are the cost of my time
spent making a sandwich that then gets thrown away, as you just mentioned.
The further down the line a mistake is made, the more valuable the sandwich
is, since additional foods are being added and additional time is being spent
on its preparation. This concept is known as the "value added" to a product.
I also have  the cost  of a potential  lost  customer:  they may  go  away
dissatisfied if I make them wait too long or give them  the wrong order.
Finally, there are the costs of the paper that I use to take orders and pieces of
wrap that get thrown away."

"What about the cleaning you do?" asked Cecilia. "You said earlier that this
is a big concern of yours."

"Yes, you are right. There are costs associated with the cleaning.  The more
cleaning  I  need to do, the more cleaning agents I must use. Excessive
cleaning  also  leads to an excessive laundry bill  from all the aprons and
towels that must be cleaned. This takes up a lot of my time. By preventing
spills, I could reduce these costs."

"Then there are costs associated with inspections and other health issues. If
the regulators come in and the restaurant is not clean, the inspection will not
go well. I will  need to spend a great deal of time with the regulators and I
could end up with a few fines  and a  lot of paper work. In fact, this just
happened a couple of weeks ago. An inspector came in at 1:30 right when
the place looks the worst. I spent the entire afternoon with him and ended up
with a fine because I didn't have the storage room in  order. I know if the
place looked better, he wouldn't have issued the fine because I didn't have
any major violations."

"If a customer  gets food poisoning, such as salmonella, because the food is
not properly stored or handled I could potentially be shut down. I'm careful
not to allow this to happen. My other big concern is  if mice get into the
building  they  could get  into  the  bread I keep in storage.  The Health
Department always checks for signs of mice, and the lost bread costs me a
lot," Benito continued.

"Make a summary list of all of your cost categories that are associated with
the losses in your operation," said Jim. "Next to each cost category, write the
activity that the cost can be attributed to. Think about the steps, or activities,
                                                                     19

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                                               Chapter 2: Activity Based Costing


in your process when you waste your time because of the losses that occur
during this activity."

Benito listed all his costs categories.

List of the cost categories and. activities associated with these costs:
Raw materials (Take order, cut bread, make sandwich, wrap sandwich)
Lost customers (Clean working area, make sandwich)
Time (Cut bread, make sandwich)
Regulatory Fines (Clean working area, clean restaurant)
Exercise
Create a  list of the cost categories associated  with the losses in your
operation.  Next  to  each cost,  write the activities  that  the  cost  can be
attributed to.

"Now that you've listed your activities, your losses, and your cost categories,
with the activities that cause these costs, you should set up a table with this
information we'll fill it in later," said Jim. List all the different costs in the
first column, such as the cost of raw materials etc., and across the top of the
table list all the different activities, such as taking orders," he continued, (see
Table 1)
Exercise
Use the attached table  for your  costs and activities. Put  all your  cost
categories in the first column, and all of your activities in the first row.

"Your activities and your costs are  summarized," said Jim. "Now your need
to assign a dollar value to each cost by the activity. For example, in the
second row, second column, you will enter the cost of the raw materials lost
when you take an order." (see Table 1)

"At this point, though, because you don't have all the information for all of
your  costs, divide $100 among all of your cost categories  based on  their
relative weight. Think about  all  your  costs (due to the losses in  your
operation) from last month," said Jim.

"So I  should take $100  and divide it up based on how much I think raw
materials, lost customers, time, and regulatory fines cost me last month,"
said Benito.
20

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                                              Chapter 2: Activity Based Costing
"That's right," said Jim. "And these values should be based on the costs of
your losses. That is, you wouldn't include the costs  of all of the time spent
by you and your employees, just the cost of the time required to cleanup or
the time wasted when a mistake is made. This will  give you a pretty good
estimate."

"Well, I would have to say when considering these costs from last month,
the regulatory fine I received is my biggest expense. Probably close to half.
I'll  call it $47.50," Benito began. Benito  continued to estimate his  costs. "I
also noticed that some of my regular customers haven't been around as much
lately.  This is my next biggest costs.  I'll call  it $25." Benito  finished
assigning his total costs.

"Place these values in the row marked TOTAL COST," instructed Jim. "And
then continue  to assign costs by dividing up the  TOTAL COST value for
each cost  into costs per activity. For example,  if the total cost of raw
materials lost is $15, how much of this cost is due to lost bread during the
"Cut Bread" activity? Fill all these values into the table. Add up all the costs
by activity  (i.e. each column) and calculate the percent." (see Table 2)

Benito considered each cost. He broke down the  $47.50 for the  regulatory
fines into the two activities that had to do with cleaning the restaurant. After
all, if the restaurant was clean, he would not have received this fine. Next he
divided up  the $25 for the cost of lost customers. A small part of this cost, he
figured, may have been due to mistakes.  Thus, he assigned $2.50 to the
make sandwich activity. The  rest of this amount ($22.50) he divided among
the two cleaning activities. Benito continued until all the costs were divided.
Exercise
Fill in the column marked  TOTAL COST in your table.  Take $100 and
estimate the relative amounts of this total that should be attributed to each
cost category.  Once  you have  finished entering TOTAL  COST  values,
divide up the totals to the individual activities in each cost category. Fill
these values in as well. Total each column.
Note:  If you wish, see how well you estimated these costs by updating this
table based on your actual expenses.

"Reading  a graph is always easier than trying to interpret a table, so we are
going to use the information from the table and create a Pareto diagram. It is
                                                                    21

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                                              Chapter 2: Activity Based Costing


easy to do. Along the horizontal line, list all your activities. The vertical line
will represent the relative cost represented by each activity." (see Figure 2
Exercise
Using  the attached graph  to  create  a Pareto diagram.  Write all  your
activities, as they appear in  your table, in the boxes marked activity 1, etc.
Now, for each activity, draw a bar up to the total cost for that activity (again
as they appear in your table.)

"As you can see from the graph a majority of the costs associated with the
losses from Benito's restaurant are from the cleaning operations, or just two
of the activities. The Pareto principle suggests that 80% of the problems in a
business come from  20% of machines, raw materials, or operators.  This
example demonstrates this  principle. From this information, Benito now
knows that he  should focus on his cleaning operations. If he does this, he can
increase his profitability by reducing his environmental costs."
Discussions Questions/Activities
   1.     What is the Pareto Principle? Think of an example of how this
         principle holds true in your life (business or personal).

   2.     What advantages are there to graphing the results of your analysis?

   3.     What activity  drives the environmental costs  in your  operation?
         Share this information with the group using your Pareto diagram.

   4.     As an optional exercise, spend some time between now and the
         next  meeting and determine your actual costs. Some of these costs
         may  be hidden or hard to determine. For example, how do you put
         a dollar value  on your time? To put a value on your time, or the
         time  of your employees, you need to consider what is called the
         "fully burdened rate". When you calculate the fully burdened rate,
         consider not only the hourly rate you pay, but also the  cost of all
         benefits. For example, if you pay someone $7 an hour to work the
         counter  and you also provide some health benefits and sick time,
         they  are probably  costing  you as  much  as  $10  an hour.  Now
         consider the cost of your time. If you pay yourself $20 an  hour,
         with  all your benefits this number is probably more like  $30 an
22

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                                     Chapter 2: Activity Based Costing


hour. This brings up a couple of points. First, if someone is needed
to perform tasks like cleaning the floor, you should assign the least
specialized person  on your staff - the person you are paying the
least.  Second, consider these fully  burdened costs when you
determine the total cost of a person's time since  this is what the
person's time is actually costing you.
  The next tutorial mil present Root Cause Analysis - a
            method to identify the factors which
                 are causing material loss.
                                                          23

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                                                              Chapter 2: Activity Based Costing
                    Figure  1:  Chicken sandwich - Process Map
       Soap
                      Water
            Soapy water
                                                  Paper
                                                Paper
                                                                              Bread
Clean Working Surface
1


Take Order
2


Cut Bread
3
                                                                                                     To #4
                                                                         Bread      Improperlyc
                   "cut bread,
wrappers   Crumbs, Odd pieces, etc.
           Make Sandwich
                4
                1
                                                  Wrap

          Mistakes     Not so empty
Food wrappers,           containers,
  Chicken,           Condiment spills
 Cheese, etc.
                                           Wrap Sandwich
                                                5

                                                  Wrap
24

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                  Chapter 2: Activity Based Costing
Table 1
Cost
Raw
Materials
Lost
Customers
Time
Regulatory
TOTAL
By
Activity
Percent
TOTAL
COST









Take Order









Clean
Working
Area









Cut Bread









Make
Sandwich









Wrap
sandwich









Clean
Restaurant









                                             25

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                                                         Chapter 2: Activity Based Costing
                                       Table 2
—
Raw
Materials
Lost
Customers
Time
Regulatory
Fines
TOTAL
By
Activity
Percent
TOTAL
COST
15

25

12.50
47.50
100


Take
order
2.50

0

0
0
2.5

2.5%
Clean
Working
area
0

10

0
20
30

30%
Cut bread
2.50

0

2.50
0
5

5%
Make
Sandwich
5

2.50

2.50
0
10

10%
Wrap
sandwich
2.50

0

0
0
2.50

2.5%
Clean
Restaurant
2.50

12.50

7.50
27.50
50

50%
26

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                                                      Chapter 2: Activity Based Costing
                             Activity Based Costing
   Cost
TOTAL
 COST
TOTAL
By
Activity

Percent
                                                                                27

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                                                          Chapter 2: Activity Based Costing
                 Figure 2: Chicken sandwich - Pareto diagram
               $6(1
               $50_
               $40_
            3  $so_|
               $20_
               $10_
                 $0
                         50%
                        Clean
                      Restaurant
                                                                      2.5%      2.5%
 Clean    Make sandwich  Cut Bread    Take Order Wrap sandwich
Working
 area
          Activity
28

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                                                    Chapter 2: Activity Based Costing
              Activity Based Costing: Paredo Diagram
80
60
40
20
     Activity!             Activity2            ActivityS             Activity4            ActivityS
                                                                               29

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                                               Chapter 3: Root Cause Analysis
Tutorial 3: Root Cause Analysis
Now that you have recognized the activities in your process
that are costly or expensive to your business, you can begin to
focus your efforts on pollution prevention. This tutorial
presents a method of detecting the underlying reason for an
environmental loss so that the loss can be prevented.
Warm-uo Exercise
 t:
Think of all of the times that you have been late for
work and list the different reasons for your delay.
Maybe your alarm clock did not go off, or perhaps
your child was sick and you needed to arrange for a
sitter. Did  you spend too much  time reading  the
newspaper or did you need to run to the store to pick
up milk.

Arrange  all these reasons in  the categories  listed
below, or create an additional category. Some of the
items on your list may be entered more than once.
Now consider the last time you were late for work. Why were you late?
Circle the reason.
MACHINES
broken alarm clock
                 PEOPLE
                      sick child
METHODS
reading the newspaper
                 MATERIALS
                 out of milk
30

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                                                     Chapter 3: Root Cause Analysis
Introduction
In the last tutorial you determined the key losses responsible for the greatest
amount of environmental costs. In order to try to prevent a loss, you must
first understand why it is occurring. The underlying reason for a loss is also
known as its "root cause".  The root cause will answer the  question: What
ultimately caused the loss?  Determining the root cause of an environmental
loss is very similar to determining the root cause of being late for work

A cause and effect diagram is one method of determining the root cause for
a loss. This tool provides a visual description of all possible  causes for a
specific loss. Once all the possible causes are depicted on the  diagram, the
most plausible cause or causes are identified. It is imperative that all persons
involved in determining the root cause  are in agreement. Having each team
member construct a "Dear Abby" letter  summarizing the cause or causes for
a loss will ensure that all participants see the problem in the same way.

During this exercise you will:
Objectives
      Construct a cause and effect diagram with all potential causes for a
      loss.
      Discuss the most probable cause or causes.
      Write individual Dear Abby letters describing the reason for the loss.
      Write a group Dear Abby letter taking the best ideas from each letter.
Basic Instructions
      This tutorial should be completed by your Green Zia Group.
      Please read aloud from here on.
      Allow 60 minutes to complete.
                                                                    31

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                                                     Chapter 3: Root Cause Analysis
Root cause analysis and Belen Jewelry
Cecilia  Williams owns and operates a jewelry business, Belen  Jewelry,
specializing in beaded earnings and  necklaces.  With four to  six part-time
employees, she produces up to one-hundred items each day that  she then
sells to department stores.

After participating in process mapping and activity based costing exercises,
Cecilia  determined  that  her  largest  loss, the  high-quality  beads  she
purchases, accounts for approximately 80% of all her environmental costs.
Cecilia was anxious to discuss this loss with her group  and hoped that by
talking through her problem she could discover the root cause of this loss.

"I knew I was throwing away some  of the raw materials that I purchase,"
Cecilia began, "but I could not believe how much this one waste is costing
me. The result of my process mapping and activity based costing exercises
indicated that the majority of my costs  associated with  wastes come from
beads that are lost during all stages  of the process. I really would like  to
spend some time getting to the bottom of this problem." (see Figure 1)

Cecilia had  done some research on methods of determining a root cause,
including the use of cause and effect diagrams.  She went on to explain the
use of cause and effect diagrams.

"Let's spend some time discussing root cause analysis. To determine the root
cause of a loss, you must ask "Why is the loss occurring?" I read about one
way of gathering information concerning the generation of a  loss called a
cause and effect diagram, or fish bone  diagram, since  it resembles a fish
bone. Major categories of possible causes for the loss are first defined and
entered on the diagram as an off-shoot from a main horizontal line.  Next, all
possible causes of the waste are  assigned to a category and entered on the
diagram. Once all the  causes are defined,  an agreement is made as to the
most plausible reason for the loss."

"I have divided the causes into four major  categories  - Methods, Machines,
Materials, and People  -  and what we need to do is write  down all the
32

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                                                     Chapter 3: Root Cause Analysis

possible reasons why I could lose beads in my process and assign them to a
category," she continued. "I started the diagram and wrote down some of the
things that immediately came to mind."

"The first thing I thought of is my supplier. Normally the shipments are very
good, but occasionally I get  a shipment of beads that aren't very consistent.
Some of the beads are different  sizes and sometimes the shapes and the hues
are slightly  different and I can't use them.  I also can lose beads when the
chains break, but this doesn't happen  very  often. The other  things I wrote
down are that beads can get  damaged  when  they are in  storage  either
because the  heat causes them to get deformed or because they are not stored
properly: we don't really have any storage policies in place. Also the  shop is
a little small and sometimes it gets cluttered, so beads are easily spilled.
Finally, I have a pretty high rate of turnover in my employees especially due
to the cyclical nature  of the business and I don't think I have been  able to
convey how important it is to prevent losses."

"Those are the main issues I  thought of, can anyone think of anything else?"
asked Cecilia.

"Yes," Jim replied, "You didn't mention anything about training. I know in
my business when I put  a formal training program in place,  I saw  a large
improvement in the way raw materials were being used."

"That's a good point. Currently I don't do any training," said Cecilia.

Other ideas  were  also mentioned. One person brought up the importance of
inventory control, after all, you  would not have losses associated with parts
being damaged in storage if there were no  parts to be stored!  Someone
talked about the surroundings such as the importance of proper lighting in
the workplace. Still  another  issue  raised  was process control,  or the
movement of material throughout the process. All these ideas were entered
onto the diagram,  (see Figure 2)

"Now that all the possible causes of beads being lost during the process of
making beaded jewelry were categorized, it is time to determine the most
probable cause. Let's go  back to the diagram and circle the  most probable
causes. One of these should be the root cause.  After much discussion, the
team reached their conclusion. The lack of employee knowledge and training
has lead to the  excessive  losses of beads. Cecilia suggested that each
                                                                    33

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                                                   Chapter 3: Root Cause Analysis


member of the group  write a short "Dear Abby" letter describing their
interpretation of the problem to ensure that each person sees the problem the
same way. After each letter was read to the group, a joint letter was written
with the best ideas from each. Once the letter is in place, the group becomes
Abby and seeks to solve the problem, (see Figure 3)
Discussion Questions/Activities
   1.     What is meant by the "root cause" of an environmental loss and
         why is it important to identify it?

   2.     Why is it important that all members of a group see a problem the
         same way?

   3.     Recall the activity that you identified as driving the environmental
         costs in your business. Write down all the possible reasons for this
         loss on the attached fish bone diagram.

   4.     Discuss  your diagram with the group.  Add any additional causes
         based on this discussion.

   5.     Circle the most probable cause and  write a  Dear Abby letter
         describing the problem. Read your Dear Abby letter aloud.

   6.     If other people work with you ask them to write down how losses
         occur in your business.  Examine  whether there  are  additional
         factors causing the loss that you did not think of.

   7.     Please give feedback on this exercise:
          •  Was it useful?
          •  Was the group response to Dear Abby productive?
          •  Will you repeat this exercise to examine business losses in the
             future?

   8.     Were the tutorial exercises clear? If not, please specify which ones
         were unclear and why.
           The next tutorial mil present brainwriting - a method
                           to generate ideas.
34

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                                                                     Chapter 3: Root Cause Analysis
                  Figure  1: Beaded jewelry - Process Map
       Beads
        1
                                        Chain
       1
                                                                     Water
                                                Cleaning
                                                Agents
     Bead Storage
                                      Size Chain
                                                                         Clean Chain
                                                                                            To #4
 T         T
Packaging      Beads
      Scrap
      Chain
                                                                      Dirty
                                                                     Water
                                                                                  Rags
    Inspect & Count
        Beads
String Beads on Chain
                                        Attach
Clasp   	^J
                                                           To #7
        T
        Beads
                                       Beads
                                          Broken
                                          Clasps
               Plastic  Cardboard   Tape
                      Packaging
                         Shipping
           Plastic  Cardboard   Tgpe   Damaged
                                   Jewelry
                                                                                          35

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                                                                              Chapter 3: Root Cause Analysis
                           Figure 2: Cause and Effect Diagram
       Methods
    too hot


storage	
                        lack of control
                              inventory
                                                              Machines
     proper storage policies
         not in place
           process control
      supplier
                                                  magnifying glasses
                                  proper lighting
                                           _  workplace
                                               conditions
                                           \
                                            shop cluttered
          color    wronof
                   size
                       Materials
                                                         no formal
                                                          trainin;
                                                         training
                                                                                            needles
                                                              People
                                                                                                         lost
                                                                                                        beads
                                                                                               poor

                                                                                              	attitude
36

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                                                     Chapter 3: Root Cause Analysis

                      Figure 3: Dear Abby Letter


Dear Abby,


I'm losing my beads!! I make and sell high quality beaded jewelry.  The cost
of the beads keeps rising and my profits keep going down. I'm afraid more
beads are landing on the floor and being thrown away than are going into the
jewelry. I'm  losing a lot of money especially when the  shop is busiest.
Finding well  trained employees is very difficult. My  employees work very
hard but they do not realize the importance of being cautious when working
these high-priced items.  I  guess  I'm not  communicating  this  to  them
effectively. Maybe I need to conduct training sessions to really make them
understand. I  hope you can give me some advice.

Sincerely,


Beadless in Belen
                                                                    37

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                                                        Chapter 3: Root Cause Analysis
                 Root cause analysis: Fishbone Diagram
38

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                                                   Chapter 4: Brainwriting
Tutorial 4: Brainwriting
To  address an  opportunity effectively, it  is important to  recognize all
alternatives. Very rarely is there one "right" way of preventing pollution.
Instead, there  are many different potential solutions.  This tutorial presents a
technique of listing many different alternatives for an opportunity.
Warm-up Exercise
                 You know the old adage "two heads are better than one".
                 This is especially true when trying to come up with new
                 ideas. When you generate ideas in a group you will notice
                 that each member of the group brings their unique set of
                 experiences and strengths to the table.
                 Try the following exercise with your group. Look at the
picture below (turn it on it's side and upside-down). What does it remind you
of? Write  down all the images that come to mind-even images that seem
crazy should be included. Now go around the room, each person sharing one
image with the group. One person should volunteer to keep a list of all the
images. Repeat this step until every member of the group is out of images.
How many images did  the group come  up with? How does this compare
with the number of images you generated alone?
                                                                 39

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                                                     Chapter 4: Brainwriting
Introduction
In the last tutorial you  evaluated all  the  probable  causes of a loss  and
determined the underlying reason, or root  cause. Once the root cause has
been identified, you may be tempted to jump to a premature solution. When
you address a loss without considering all the alternatives of prevention you
may be overlooking the most appropriate option(s).

Looking for alternatives for pollution prevention by addressing its root cause
is the next step towards addressing an opportunity. There are  several tools
available to help groups develop alternatives. You already explored one tool
during the warm-up  exercise.  In this exercise you will  explore another
method-brainwriting.  Brainwriting  requires  maximum   interaction  and
creativity  between group members. All possible alternatives, regardless of
how far-fetched they appear, are considered by  the  group.  Alternatives
raised  by the group may seem contradictory,  or  they may build on  one
another making them better. A comprehensive list of alternatives can then be
compiled.

During this exercise you will:
Objectives
        Conduct a brainwriting session.
        Develop a list of all possible alternatives for an opportunity.
Basic Instructions
        This tutorial should be completed by your Green Zia Group.
        Please read aloud from here on.
        Allow 90 minutes to complete.
40

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                                                     Chapter 4: Brainwriting
Brainwriting and Sam's Garage
Sam Rogers, the owner of Sam's Garage, provides automobile maintenance
at his shop. One of the regular, most profitable  services he provides is oil
changes. Looking for ways to further increase the profitability  of  this
operation, Sam mapped out this process, indicating all losses, (see Figure 1)
Sam  discovered  that 80% of  the  environmental costs associated  with
changing oil were due to oil spillage. Not only is oil expensive, but because
it is  considered a hazardous  waste, Sam must handle these spills  very
carefully.

The largest spills take place when the oil is being added. After evaluating all
of the possible causes for oil spillage during the "Add Oil"  stage of the
process,  Sam determined  the root cause  for  this loss.  The  quart-size
containers that are currently used are difficult to pour into the small fill cap.

Sam shared this information at  his Green Zia Group meeting.

"As  you can  see," Sam said after  explaining the process to the group,
"during the "Add Oil" stage of this process, a lot of oil is being lost. This
loss translates into less  profit  for the Garage. I  created a cause and effect
diagram with  the mechanics  and  we  decided that the oil  containers are
awkward and hard to pour from. We thought of a few things we could do to
reduce spills, and I already think I know the best solution, but I was hoping
the group could help me think of some additional alternatives."

"I have an idea," said Cecilia.  "I was reading  about a method of listing
alternatives called brainwriting. The goal is to write down as many ideas as
possible regardless  of how crazy they seem. In fact,  to  make  it more
interesting we can give a prize to the person that  comes up with the craziest
idea.  Since there are five of us  here today, I will use  six sheets  of paper.
Each  sheet is divided into two  columns and five rows, making a total of ten
boxes on each sheet. Each box is numbered. I'm going to place these sheets
in the center of our circle. Each person should take a sheet and write  two
alternatives on it and then place the sheet back in the  center. Then take
another sheet of paper and write two more alternatives on it. Every time you
                                                                    41

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                                                     Chapter 4: Brainwriting

pick up a sheet of paper read what others have written  and try to make
improvements to  the  alternatives  listed.  You  can even say you think
someone's idea is completely out in left field, if you try to make it better.
Keep repeating this process until everyone runs out of ideas."

The group performed this exercise. A lot of laughing and talking took place
during the free flow of ideas. This is a key sign of a successful brainwriting
session, (see Figure 2)

"Now we can list all the alternatives that were discovered," said Sam.

The alternatives on each sheet of paper were read and discussed. Many of
the ideas were the same and some had small variations. The group debated
these small variations  and  eliminated the  impossible  alternatives.  One
comprehensive list was developed-each idea was only written once, although
all variations of the same idea were included.

"We talked  about  a couple  of these alternatives  at the Garage," said Sam,
"but this definitely helped me come up with some additional things. I really
like the idea of ordering the oil in bulk and running a fill line overhead. That
will help keep the shop clean too. Employee training is  also a good thought.
I was hoping that by including the mechanics in this exercise I could also be
providing some training."

"That gave me a thought for another alternative," said Cecilia. "Maybe you
could provide some sort of incentive for employees who achieve pollution
prevention."

"I'll add that to the list of things to consider," said Sam. "Any by the way,
who thinks I could get Ford to change  the way they design their engines!?!
That gets my vote for the craziest idea." (see Figure 3)
42

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                                                    Chapter 4: Brainwriting
Discussion Questions/Activities
   1.    Why is it important for Sam to consider alternative methods for
        preventing an oil spill  (even though he thinks he knows the best
        alternative)?

   2.    What are the advantages of an exercise like brainwriting? How does
        it help members of a group work together?

   3.    Make "brainwriting  sheets" for each member of the group plus one
        extra, using the attached example as a model.

   4.    Review the root  cause for your loss discovered in the last exercise
        and state it aloud.

   5.    Conduct brainwriting sessions for each business represented. Spend
        at least 5 minutes on each session.

   6.    When all the brainwriting sessions are completed compile a list of
        alternatives for your business.

   7.    Did you find this tutorial useful? Why or why not?

   8.    Were the tutorial exercises clear? If not, please specify which ones
        were unclear and why.
    The next tutorial will present 'bubble-up-bubble-down' a
    method for selecting the best option to prevent loss.
                                                                   43

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                                                                      Chapter 4: Brainwriting
                         Figure 1: Oil change-Process Map
        Open Hood
           Filter
          _L
                       Position Drip Pan


                                  2
                                                                               Drain Oil
                                                                                               To #4

                                                       Dirt and
                                                         Oil
                                                                                       Rags
                                                               Oil

                                                              1
       Replace Filter
                        Open Fill i
       Add Oil
                                                                                               To #7
    I       I      I
          Rags
  Fllter
Packaging
 I      I       I
Rags
                                                                                         Oil
                                                                                Oil Bottle
                                                                         Water
                                                                   Soap
                                                         I	L
      Replace Fill i
                         Close Hood
    Clean Equipment
                                                                         I      I       I
                                                                         Oil
                                                              Dirty    Rags
                                                             Water
44

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                                                     Chapter 4: Brainwriting
                   Figure 2: Sample of brainwriting
   1.    Use smaller oil containers that
        are easier to maneuver.
2.     Buy oil containers that have a
      spout.
4.     Place a drip pan under the
      engine to reclaim the oil that is
      lost.
5.     Use larger oil containers so there
      is less residual wastes.
      Put a spout on the container
      before you pour the oil.
7.     No longer provide oil changes at
      the Garage.
8.     #6 You would lose a lot of
      customers how about attracting
      more business so you can afford
      better equipment?
8.
                                       10.
                                                                     45

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                                                      Chapter 4: Brainwriting


                      Figure 3: List of alternatives
        Contact companies that package oil and request a different lip  or
        spout on the quarts of oil.
        Fit a reusable spout onto the quarts of oil.
        Use smaller containers of oil that can be used more carefully.
        Buy larger containers to avoid residual waste.
        Pump oil from  100 gallon containers.
        Fill oil using an overhead line.
        Stop providing the oil change service in garage.
        Use a drip pan to reclaim spilled oil.
        Place a funnel on the fill cap.
        Write the automobile manufactures requesting that the location  of
        the fill cap be moved to a more approachable area in the engine.
        Place suction hoses around the fill cap to reclaim spilled oil.
        Meter oil dispensing only what is needed.
        Train workers  on pollution prevention and  ways to  reduce and
        reclaim spills.
        Provide incentives for employees who reduce losses.
        Measure thickness of oil ensuring oil is not changed unless it needs
        to be.
        Attract  more  customers  for  oil  changes  and invest  in better
        equipment.
46

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                                                         Chapter 4: Brainwriting
                       Figure 4: Brainwriting Sheet
                                         2.
                                         4.
                                         6.
7.
8.
                                         10.
                                                                          47

-------
                                          Chapter 5: Bubble-up-bubble-down
Tutorial 5: Bubble-up-bubble-down
You have  now  generated  a  list  of  alternatives for  preventing an
environmental loss in  your business.  But how  do you choose the best
alternative? This tutorial presents one method of prioritizing alternatives to
ensure that the most appropriate alternative is selected.
Warm-up Exercise
                     Most of us use lists from time to time to make sure
                     that we don't forget to do the things that we need to
                     get done. Without a shopping  list, for example, we
                     may return from the store without milk, the reason
                     why we went in the first place. Certain limitations,
                     like time or money, may cause us to drop things off
                     our list. We often need to prioritize and make sure
                     that the most important things get done.
Make a list of the things that you need to get done tomorrow (try to list at
least ten things). List these items in the order that they come to mind. Now
prioritize this list by putting the most important items on the top of the list
and the least important items on the bottom. You should now have a "rank
ordered" list. If you only have time to complete one of the items on your list,
which would it be? You should have answered the item on the top of the list
the most important item.
48

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                                              Chapter 5: Bubble-up-bubble-down
Introduction
A comprehensive list of pollution prevention alternatives was developed in
the last  tutorial using  a technique  called brainwriting.  The alternatives
generated during this tutorial  can range from operational changes, such as
employee training and  inventory control,  to technology changes, such as
automating a  process. The  next step is to choose one alternative that is
capable of being worked with successfully. Additionally, it is important to
select the optimal solution for your business. To accomplish this,  you must
consider the feasibility  of each  alternative. Such factors  as effectiveness,
implementability, cost, and potential ramifications of each alternative should
be discussed. Personal preferences and biased information should not enter
into the decision-making process.

There are several tools  available to aid a  group in selecting an alternative
and avoid bias. These tools allow a group to rank and prioritize alternatives
using a systematic approach. When all the alternatives are listed, suggestions
are made by the group to improve even the worst alternatives. At this point,
many of the  alternatives may be eliminated:  every  realistic alternative
remains on the list. These remaining alternatives can then be sorted based on
the factors presented above and any other factors that may effect a particular
business. The method of selection presented in the exercise is the bubble-up-
bubble-down.  This tool uses a forced pair comparison to rank alternatives.
Using this method you will be able to find  the most effective solution to the
selected loss.

During this exercise you will:
Objectives
        Evaluate all alternatives.
        Use the bubble-up-bubble-down method to reach a decision on the
        best alternative.
Basic Instructions
        This tutorial should be completed by your Green Zia Group.
        Please read aloud from here on.
        Allow 60 minutes to complete.
                                                                     49

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                                             Chapter 5: Bubble-up-bubble-down
Bubble-up-bubble-down and Creative Cabinets
Lany Weaver has been operating Creative Cabinets for ten years. To remain
competitive in this business, she has been forced to cut prices on her line of
colored cabinets. In order to  realize greater profit margin, Lany has been
evaluating her process attempting to reduce losses  and improve process
efficiency. Streamlining and cost containment will counteract the squeeze on
profit margin. Lany presented her case at her Green Zia Group meeting.

"The competitive environment  for colored cabinets has been  increasing,"
Lany began. "I was forced to drop my prices and watch my profit margin
decrease. I hope I can put these pollution prevention tools to work in my
operation and improve the efficiency of my operation without jeopardizing
the quality of the cabinets."

Lany described the process of making these  cabinets  to her group.  She
receives precut cabinet doors from a vendor. The  cabinets are then  cut,
sanded, and  routed  to  meet  customer's  specifications.  Components are
loaded onto a conveyor where they move through open primer and painting
booths and enclosed driers. Finally, the cabinets are  assembled, packaged,
and shipped, (see Figure 1)

"After  evaluating my  losses, I was able to demonstrate that 80% of all the
environmental costs were due to one part of my operation-painting. I use a
series of wet spray booths to apply the paint. Operators apply the paint using
a spray gun. Over spray, or the paint that does not land on the cabinet, ends
up in a washwater  system; the resultant paint sludge gets  shipped offsite for
disposal."

"There are many costs associated with this activity. First,  there is the cost of
the paint that  is wasted. This paint waste is considered hazardous waste
under RCRA federal law so disposal fees are very high. Plus, I have to spend
a great deal of time completing paper work. I also have high  cleaning costs
and  associated down time. My  washwater system often  gets clogged with
excess paint, interrupting the process. I have to keep the spray guns clean to
50

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                                              Chapter 5: Bubble-up-bubble-down

keep them from getting clogged.  There are several other costs too-I've just
listed the major ones," said Lany.
"Have you determined the root cause for this loss?" asked Jim

"Yes," replied Cecilia, "I held a meeting with all the employees working in
the paint process and  we  constructed  a  cause and  effect diagram. We
determined that the method of paint application was the root cause for the
paint loss. We also held a brainwriting session  and developed a  list  of
alternatives for achieving pollution prevention  in this process. We  already
eliminated the ideas that were not feasible. Now all that is left is choosing
the best  alternative. I really want to  be cautious when I chose a solution
since picking the wrong alternative could cost me a lot of valuable time and
money, and could also damage employee morale." (see Figure 2)

Lany presented the alternatives to the group and explained the pros and cons
of each.  Some of the alternatives such as converting to a dry filter  system,
required a sizable capital expenditure.  Other alternatives, such as contracting
out the painting would put several of her employees out of work and may
also end up costing her more.

Jim provided a suggestion on  how to proceed.  "You need to use a tool for
rank ordering these  alternatives," said Jim. "Try using the bubble-up-bubble-
down method.  Take  the list of alternatives and compare the first two
alternatives. Decide which of the two is the best and move this alternative to
the top of the list. Go to the next, or third alternative and compare it to the
second. If it is better than the second,  move it up and compare it to the first,
if not, leave it in  the  third position. Continue this  process until all  the
alternatives are rank ordered.  Make sure you listen to everyone's opinions
and objections."

"I suggest you include all of the members of the paint group just as you have
up to this point. That way you will be able to reach a decision that all the key
players agree upon. In order to get an alternative to  work you  must have
their buy-in. You may need to compromise in order to reach a solution that
will be successful."

Lany held another meeting with all the employees  of the paint process. She
explained the bubble-up-bubble-down method of rank ordering alternatives.
Forced comparisons were made between the alternatives. A great  deal  of
discussion and even some arguments were heard. The painters, some with up
                                                                     51

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                                             Chapter 5: Bubble-up-bubble-down

to ten years experience, were insulted at the suggestion  that they may need
to be trained on the best method of applying paint. The manager, Sal, was
upset at  the  suggestion of moving to aqueous based paint. Sal had tried
switching paint once before and it was a disaster. He let his objections be
heard and did not let the other members of group forget that if there was a
problem, he would be the one that would take the blame  for it. Sal did agree
that  perhaps they  were behind  on the technology and using  a dry filter
system would be a lot more efficient.

The  decision was reached. The  group determined that  the best alternative
was  to convert to using a dry filter  system. They also decided that they
would  conduct another brainwriting  and bubble-up-bubble-down  session
after the new system  was installed in order to continually  improve the
painting process.
Discussions Questions/Activities
   1.     What are some of the potential problems associated with choosing
         the wrong alternatives?

   2.     Why was it important for Lany to include all the members of the
         paint group  in  the bubble-up-bubble-down exercise?  Why is  it
         necessary to compromise?

   3.     How did Lany's Green Zia Group help her work through selecting
         the best alternative?

   4.     Refer to the list of alternatives generated during the brainwriting
         session.

   5.     Take turns listing the alternatives on the board (or on a piece of
         paper).

   6.     Perform  a bubble-up-bubble-down  exercise  for  each  list  of
         alternatives. As you proceed with this ranking method, explain in
         detail the positive and negative attributes of each alternative.
52

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                                          Chapter 5: Bubble-up-bubble-down


7.     Did the  bubble-up-bubble-down method work for you? How did
      your business group help?

8.     Were the exercises clear? If not, please specify which ones were
      unclear and why.
               The next step is to develop an action plan.
                                                                53

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                                               Chapter 5: Bubble-up-bubble-down
                             Process Map
          V        V
V        V
V        V
          V        V
V        V
54

-------
                                                               Chapter 5: Bubble-up-bubble-down
                           Figure 1: Cabinet making-Process map
pa
m
Pr
]
>-
Pre-cut
cabinet parts
1
Storage
1


Wood
Preparation
(cutting, sanding, and
routing)
2


T T s 1 1
Used wooden ^ Sawdust
ckaging pallets
aterials
mer Water Thinner Paint Water Thinner
'TV V T V
Priming
4


Painting
5



Conveyor loading
3
Natural
gas
Drying kiln
6
     /   \    \     I   \
            T     T     T       ^         ^      T      T     T       ^
        VOC's  Water/ Paint    Spent    Paint     VOc's  Water/  Paint    Spent
barrels          Sludge suits   thinner   barrels           pgint   suits   thinner

                                                   sludge
Glue
1
Staples
Assembly
7
1
imaged
roduct
Cardbt
\

sard Glue Staples
' ? T l
Packaging
8
Foam
r

1
Staples

Shipping
9
1
Wooden
pallets
                                                                                             To #4
                                                                                             To #7
                                                                                            55

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                                               Chapter 5: Bubble-up-bubble-down


                       Figure 2: List of alternatives
   1.     Switch to an aqueous-based paint.
   2.     Use more efficient spray guns.
   3.     No longer provide painted cabinets.
   4.     Contract a professional painting facility to paint the cabinets.
   5.     Convert to a dry filter system.
   6.     Train employees on the best methods of applying paint.
   7.     Dewater the paint sludge to decrease the  volume of sludge being
         disposed.
   8.     Enclose the painting booth preventing the paint from entering into
         the work area.
   9.     Dip cabinets into a tub of paint for cleaner application.
   10.    Recover           the           overspray            and           reuse.
56

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                                                    Chapter 6: Action Plan
Tutorial 6: Action Plan
Being able to  successfully manage a project is important when trying to
accomplish a task, especially when you are under a deadline. You need to set
up a schedule,  ensure that you have the necessary resources, and assign the
right person to  each part of the job. In this tutorial you will create an "action
plan" for the implementation of an alternative to prevent pollution.
Warm-up Exercise
                           Your group has been assigned the task  of
                           making chocolate chip cookies.  The cookies
                           need to be ready in one hour and the cooking
                           time is twelve  minutes.  Pick  a  person  to
                           manage this project. The manager must then
                           assign   the   ten  tasks  listed  below  to
                           individuals in the group.
You will need to know how much time is required for each task, what tasks
need to be accomplished before others, what resources (i.e. bowls, flour etc.)
are required, and what the most efficient way of organizing these tasks (and
remember the clock is ticking). Create a schedule.

Making chocolate-chip cookies:

Mix dry ingredients
Mix wet ingredients
Add chips
Put the batter on the pan and put pan into the oven
Combing wet and dry ingredients
Turn on the oven
Taste cookies
Wash tools and utensils
Grease pan
Take cookies out of the oven
                                                                  57

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                                                     Chapter 6: Action Plan
An Action Plan for Prints by Marcy
Marcy's screen printing business has been in operation for 25  years. Her
largest  client,  the  Nature  Conservancy, has  questioned  her on the
environmental impact of her business. When their contract  came up for
renewal, the  Nature  Conservancy asked Marcy  to  demonstrate her
commitment to preserving the environment. Marcy had been  attending the
Pollution Prevention sessions with her Green Zia Group. She identified the
loss  in  her process responsible for the greatest  amount  of environmental
costs, and  determined  the best  alternative  for dealing with  this  loss.
Although Marcy has not yet defined an action plan for implementing this
change,  she is confident that the Nature Conservancy would look favorably
on this effort.

The  process map for Marcy's business Prints by Marcy., Inc. is shown in
Figure  1.  Marcy determined that  by incorporating a  more  sophisticated
cleaning process she could  reduce the chemical loss associated with screen
reclamation. She was not sure how to proceed  with  the implementation.
Marcy discussed her concern at her Green Zia Group meeting.

"I have  a new reason to implement a pollution  prevention change in my
business. My biggest client wants  me to  demonstrate my commitment to
preserving the environment. I'm going to send them all the output from our
previous meetings on pollution prevention from my  process map to the
bubble-up-bubble-down exercise. But I still need to develop a concrete plan
to implement the process change," Marcy explained. "I'm having a problem
getting started."

"Why don't you briefly describe the process and how you intend to modify
it," said  Jim.

"I use screen printing techniques to print images on fabrics to make clothing,
bags, and tapestry. It's really a simple process. First, mesh is placed over a
frame, making a screen. Then a stencil is used to block parts of the screen,
producing the image. The screen is placed on the fabric and a squeegee, or
rubber blade, is drawn over the screen forcing ink into  its porous portions.
58

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                                                      Chapter 6: Action Plan

Since the screens are expensive, I reuse them. The screen reclamation
technique that I currently employ is a three step process. The ink is removed
first by wiping an ink remover over the screen and then rinsing it with water.
Next, the emulsion, or stencil, is removed. The emulsion remover is sprayed
on, rubbed in with a brush, and rinsed off with water Finally, the haze,
which is the ghost image that remains on the screen, is eliminated. The haze
remover is brushed on the  surface and then the screen is rinsed  one last
time." said Marcy.

"I contacted the Screen Printing Association International  (SPAI) for some
cleaning alternatives and after discussing these and  many  other approaches
with members of the staff, we decided we were  going to introduce a high-
pressure screen washer. An emulsion remover will be applied to the screen.
Ink and stencil will then be removed by a high pressure water blaster. Ink
remover will no longer be needed. A haze remover will then be applied, only
if needed. We have read about other companies' successes using this system
and believe we can drastically reduce our chemical  use and reduce the risk
of chemical exposure to employees. Our reclamation costs will decrease due
to the reduction in the amount  of chemicals used and safety measures that
need to  be taken. Labor costs associated with this task will also be less, and
this will free up the staff  to  complete other tasks,  thus, increasing our
production rate. I also expect my cleaning costs will go way down since I
will be using at least one-third less rags."

"Before you begin to implement your alternative you  should  complete this
questionnaire," said Jim.  "It  will ensure that you  are being  thorough in your
planning and have considered all the important issues that may arise such as
the resources that are needed and the  problems that  could  may occur." (see
Figure 2)

Marcy took a few minutes to answer all the questions and read her responses
to the group, (see Figure 3) When she finished she emphasized the important
considerations.  "My  schedule is pretty flexible and  I have already ensured
that I will have  all  the  resources that  I  need. But I do  have two major
concerns about implementing  this new  washer.  First,  I must maintain
consistent high quality cleaning. If the screens are not completely clean, I
could end up  with an  entire  batch of defective products.  My senior
employee, Doug, is responsible  for checking the quality of the screens so he
will  be monitoring  this closely.  Second, it's  important  that  I  have the
cooperation of all my employees. Currently, I employ three additional full-
                                                                    59

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                                                      Chapter 6: Action Plan

time people, Pat, Jean, and Paul, plus my husband, John, and sisters, Donna
and Carol, help out when we get busy.  There may be some problems in
beginning-change always  brings resistance.  I  will be ready to answer all
questions and concerns.  I think the training session and the group meetings
will help ensure open communication."

"Can you  explain how you  intend  on tracking the  success of this new
technology?" asked Bob.

"Well, I'll be keeping a record of the amount of chemicals and water that are
used each day.  I can compare these numbers to the resource usage required
using the current cleaning system. I will also monitor the service life of each
screen to make sure that the water blaster does not cause excessive damage
to the screens. If I  find a problem,  I can  adjust the water pressure,
temperature, or the chemicals used.   Additionally, I intend  to compare
production rates and per screen reclamation costs.  I expect my production
rate to go  up and my costs to decrease, after the capital expense of the new
system is paid off, of course."

"It sounds like you have thought it all out. Now put all this information in an
Action Plan Form. Most of the information you need should come from your
answers to the questionnaire. The specific task, or step, to be accomplished
is written  in the first column under "Action."  In the following column list
the  person who is responsible  for completing this task.  A performance
standard should then be provided. This standard is a way of establishing how
well a task needs to be performed. Under "monitoring technique" enter  a
measurable goal or target used to track the plan's  implementation. A firm
deadline  should then  be  set,  and finally,  indicate the resources that are
needed to  perform each  task.  This  form  will help  you organize  your
thoughts, keep track of all the actions that need to be completed, and ensure
that the proper quality is being maintained" said Jim. (see Figure 4)

"I can definitely  see how this form  will help  me keep track  of the
implementation of the high-pressure washer," said  Marcy. "I'm  sure once
this washer is  in  full operation  I'll notice  a  significant  reduction in the
amount of chemicals I use. My demand on other resources, such as laundry
services, will also decrease. The Nature Conservancy will certainly be happy
about that, and it makes me feel good about my Company. Plus, I'm sure  it
will save me a lot of money!"
60

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                                                      Chapter 6: Action Plan


"That's great," said Jim. "Since pollution prevention is a continual process,
do you have any thoughts on future pollution prevention projects?"

"You're right," Marcy responded. "I'm sure I can decrease my process losses
even further. The alternative that came in second during the bubble-up-
bubble-down exercise is prompt cleaning of screens. If the screens are
washed before the ink dries, much less water and chemicals are needed to
clean them. Once the first alternative is in place, I intend to start
implementing a "Timely Screen Washing" Program."
Discussions Questions/Activities
   1.    Why is it important to develop an action plan?

   2.    What are  some of the key issues that are addressed in the action
        plan?

   3.    Recall your selected alternative from the previous exercise.

   4.    Answer all questions on the Activity Planning Questionnaire

   5.    Fill in the attached Action Plan Form

   6.    What do  you see as the biggest problems in implementing this
        alternative? When this alternative is fully implemented, what are
        you expecting to accomplish?

   7.    How  has  developing  an action  plan improved your ability  to
        prevent loss?

   8.    Did you find developing an action plan useful? Why or why not?

   9.    Were the  exercises clear? If not, please  specify which ones were
        unclear and why.

Congratulations!!!  You have  completed the Pollution Prevention Training.
Now it is time to put these tools to work and remember pollution prevention
is an ongoing process. If you continue to implement pollution prevention in
your business, you will increase the efficiency of your process while helping
the environment.
                                                                    61

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                                                                                       Chapter 6: Action Plan
                                 Figure 1: Screen Printing-Process map
                        mesh
                                     emulsion
                               Prepare screen
                          mesh       SP'I|S: emulsion
                                                                     .  .      rubber squeegy
                                                                             Press
                                                                                                       Finished
                                                                                                       product
                                                                                            —W To #3)
                                                                                            screen
                          damaged rubber
               spills: ink     squeegies
  ink remover       rags    water
                Ink removal
spent solution: water,
 ink remover, & ink
                             rags
                                                         brushes
                                         emulsion remover
                                                                 water
                                                           V     V
                                                      Emulsion
                                                       removal
                                naze      brushes
                               remover
                   1 brushes
spills: emulsion remover & water
                                        spent so ution: water,
               spills: ink remover & water emu|sion remover & emulsion
                                                                                          Haze removal
                                brushes
                spills: haze remover & water
 spent solution: water,
haze remover, & residue
         62

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                                                  Chapter 6: Action Plan

             Figure 2: Action Planning Questionnaire

1.    What is the overall objective and ideal situation1
2.    What steps are needed to get there from here?
3.    What actions need to be done?
4.    Who will be responsible for each action?
5.    What is the best sequence of action?
6.    How long will each step take and when should it be done?
7.    How can we be sure that earlier steps will be done in time for later
     steps that depend on them?
8.    What training is required to ensure  that all staff have sufficient
     know-how to execute each step in the plan?
9.    What standards do you want to set?
10.  What volume or quality is desirable?
11.  What resources are needed and how will you get them?
12.  How will you measure results?
13.  How will you follow up each step and who will do it?
14.  What checkpoints and milestones should be established?
15.  What are the make/break vital steps and how can you ensure they
     succeed?
16.  What could go wrong and how will you get around it?
17.  Who will this plan affect and how will it affect them?
18.  How  can the plan be adjusted without jeopardizing its results for
     the best response and impact?
19.  How will you communicate the plant to generate support?
                                                                63

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                                                      Chapter 6: Action Plan

          Figure 3: Responses to Action Planning Questionnaire

   1.       To  install  a high-pressure  screen  washer,  reducing per unit
           production costs and chemical use.
   2.       Install the high-pressure screen washer and train employees on
           its use.
   3.       1)  Call  suppliers of  this  technology  for  equipment  and
           installation costs;
           2) Identify vendor that will be used and draw up contract;
           3) Meet with employees to discuss the new cleaning process-
           understand  concerns  and  any hesitation-address outstanding
           issues;
           4) Perform installation;
           5) Perform employee training;
           6) Test new cleaning system and work out any problems;
           7)  Contact vendor of  current cleaning  products and  make
           necessary changes  in orders;
           8) Monitor water use and chemical use;
           9) Schedule pickup of unused ink remover.
   4.       Step # 1 Carol
                 2 Marcy
                 3 Marcy & Doug
                 4 Vendor
                 5 Vendor & Doug
                 6 Doug
                 7 Carol
                 8 Doug
                 9 Carol
   5.       Steps outlined in question #3 are in proper order.
64

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          6.         Time line
                                                                            Chapter 6: Action Plan
Jan 1
                       Feb1
                                            March 1
                                                                    April 1
May1
             15
                                   15
                                                          15
                                                                                 15
     step 1
                 step 2
                    stepS
                                  step 4
                                             stepS
                                                         step 6
                                                                 step?
                                                                               stepS
                                                                                 step 9
                                                                                               65

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                                                      Chapter 6: Action Plan

   7.       Time estimates allow for delays—start-up date can be pushed
           back if needed .
   8.       Training will be provided to all staff members. Issues discussed
           will  include:  Best  operating  practices,  water  conservation,
           maintenance, and communication of problems.
   9.       Would like to eliminate  ink remover from facility and reduce
           other chemical use by 10% in year  1 while maintaining quality
           cleaning.
   10.      Need to clean 25-35 screens per day.
   11.      Vendor list provided by SPAI. Adequate floor space is currently
           available.  Funds required not  expected to exceed  $5000-will
           come out of operating budget.
   12.      Results will be measured based on the reduction of chemicals
           used and the quality of the cleaning from the new system.
   13.      The person responsible for each task will report findings to me
           upon completion.
   14.      Checkpoints  and milestones:  by March  1 the  high-pressure
           screen washer will be installed; by April 1 the washer will be in
           full-operation.
   15.      Vital steps:
          1)  Getting  employee cooperation.  Training  sessions  should
          provide a means of voicing all objections and concerns  about the
          new cleaning technique.
         2) Ensuring quality cleaning. The use of the high-pressure screen
         washer will be phased in over a one month period.  All  problems
         should be worked out during this period.
   16.      Product could  fail.  We  will  keep inventory  for the current
           cleaning method in  stock until we are sure the new method is a
           success.
   17.      Plan will affect all  workers  responsible for screen reclamation
           and  equipment  maintenance  and  office  manager  whose
           responsibilities  include   ordering  stock. Doug will  need  to
           continually monitor the success of the washer and the reduction
           in chemical use.
   18.      For the first year  after implementation, staff meetings will
           include a  discussion  of  the  washer.  Employees  will  be
           encouraged to make suggestions towards improving the process
           and Doug will report on  the reduction in chemical use and the
           per unit cost of cleaning.
   19.      See #15 and #18.
66

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                                  Chapter 6: Action Plan
Figure 4: Action Plan Form
Overall Target: Install high-pressure washer
Action
l.Call
suppliers
2. Contract
with vendor
3. Meet
with
employees
4. Perform
installation
5. Employee
training
6. Test and
debug
7. Change
orders
8. Monitor
resources
used
9. Pick up
ink
remover
Responsible
person
Carol
Marcy
Marcy & Doug
Vendor
Vendor &
Doug
Doug
Carol
Doug
Carol
Performance
standard
List of 5 10
providers
Signed
contract
Highly
interactive
meeting
Complete
installation
Employees
able to use and
maintain
washer
High quality
washing with
least amount
of chemicals
Inventory as
needed
Demonstrate
changes in
resource use
All ink
remover
disposed of or
returned
Monitoring
technique
Discuss
results
None
Question
employees
before and
after
On-time and
on-budget
Doug
evaluates
work
Check all
washed
screens for
cleanliness
Document
inventory
Check
chemical &
water use
Follow-up
with memo to
Marcy
Completion
deadline
Jan 15
Febl
Febl
March 1
March 7
April 1
April 1
Ongoing
April 18
Resources
needed
List of
vendors
Action #1
complete
Firm date
for meeting
Floor space
Training
material
from vendor
Action #4
complete
None
Action #4
complete
Action #4
complete
                                                  67

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                                                                     Chapter 6: Action Plan
Overall Target
Action
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Responsible
person










Performance
Standard










Monitoring
Technique










Completion
Deadline










Resources
Needed










68

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                                        Chapter 6: Action Plan
Here are a few suggestions to make pollution prevention
continue to work for you:

• Return to the Nothing to Waste activities and concepts as
  you make business decisions.

• Schedule regular pollution prevention reviews of your
  business.

Remember: Pollution Prevention saves resources, saves
money, and prevents accidents!
                                                    69

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Nothing  to  Waste  Manual
     The U.S. Environmental Protection Agency (EPA) funded the development of
     this "Nothing to Waste" manual for its Environmental Justice Program. This
   manual is derived from a training model developed by a not-for-profit group,
   Working Capital. Their approach was designed to help micro-businesses learn
   how to write business plans and request loans from banks.

   In the Nothing to Waste manual, each of the Systems Approach tools is described
   in a separate chapter and is designed to offer three levels of involvement with the
   information. First, a warm-up exercise offers the participants a simple activity to
   start their thinking in the context of the tool. Next, an exercise is provided to
   develop their familiarity with the tool. Last, each participant is asked to use the tool
   for a situation or issue that is relevant to his or her own business. This three-step
   approach offers the participants an experience of each tool before using it for their
   own business.

   Several states have adopted Nothing to Waste (e.g., New Mexico) to bring very
   small businesses together in off-hours so they can map one another's business
   processes and apply the tools to identify P2 opportunities and derive and select
   P2 alternatives. The group facilitator also helps provide the group members with
   P2 information and resources that may be needed to implement the selected P2
   alternatives.
     Back HOME
Back to P2 Tools Page

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 Please Note:
 This is the first page of this Sample P2 Plan.
This generic Pollution Prevention Program Procedure may be used as a basis for preparing company-
specific procedure(s).  This example, provided electronically by the Oak Ridge National Laboratory
(ORNL), was based on a procedure being used by another facility on the Oak Ridge Reservation
(ORR).

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                                                                Number:

                                                                Rev. Date:
                     Company Name                        Supersedes:
                                                                Page:           1  of 20
                                               Health and Safety
                                                   Procedure
Subject: Company Name Plant Pollution Prevention Program
Approvals:
     Prepared By                                                              Date
     Procedure Validator                                                       Date
     Functional Procedures Configuration Control Board Chairperson               Date
     Functional Policy Coordinator                                              Date
     Plant Procedures Coordinator                                               Date
This procedure has been reviewed by an
Authorized Derivative Classifier and has been
determined to be UNCLASSIFIED. This review
does not constitute clearance for public release.
           Name & Date
                                                                             Effective Date

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Subject:  Company Name Plant Pollution Prevention Program


                                   CONTENTS

I.    PURPOSE 	

II.   REQUIREMENT REFERENCES	

III.   SCOPE/LIMITATIONS 	

IV.   DEFINITIONS	

V.   GENERAL INFORMATION 	

VI.   REQUIREMENTS  	

VII.  RESPONSIBILITIES	
     A.  Company Name Manager 	
     B.  Organizational Managers 	
     C.  P2 Program Office Personnel 	
     D.  Pollution Prevention Council Members  	
     E.  Waste Generators  	
VIII. REQUIRED RECORDS

IX.   ADMINISTRATION
X.   APPENDIXES	
     Project Activity Report Form

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Subject:  Company Name Plant Pollution Prevention Program                                |


I.    PURPOSE
To establish requirements and responsibilities for the Company Name Pollution Prevention Program. The Program
on four major elements which are as follows: (1) the evaluation of processes for pollution prevention opportunities ;
projects, (2) pollution prevention awareness activities, (3) tracking of activities, and (4) the exchange of information
technology. These elements are addressed with respect to roles and responsibilities of all organizations within this p

II.   REQUIREMENT REFERENCES

     A.  Flowdown Documents

         1.  U.S. Environmental Protection Agency (EPA):  PL 98-616, 98 Stat. 3221, Hazardous and Solid Wash
            Amendments (November 8, 1984)

         2.  EPA PL 101 -508: The Pollution Prevention Act of 1990 (November 5, 1990)

         3.  EPA Executive Order 12873:  Federal Acquisition, Recycling, and Waste Prevention (October 22,
             1993)

         4.  U.S. Department of Energy (DOE) Order 5400.1:  General Environmental Protection Program
            (November 9, 1988)

         5.  DOE Order 5400.5: Radiation Protection of the Public and the Environment

         6.  DOE, Waste Minimization and Pollution Prevention Policy (September 1992)

         7.  Tennessee Department of Environment and Conservation (TDEC):  TCA 68-212-301  et. seq., Tennes.
            Hazardous Waste Reduction Act of 1990 (1990)

         8.  Document Number:  Company Name Pollution Prevention Program Plan (Date)

     B.  Other Documents Needed

         Project Activity Report Form (Appendix)

     C.  Information References

         1.  DOE and  TDEC: State Oversight Agreement between the State of Tennessee and the
            Department of Energy (May 13, 1991)

         2.  DOE Defense Programs: Guidance for the Preparation of the Waste Minimization and
            Pollution Prevention Awareness Plan (December 1993)

         3.  DOE, Document No. DOE/S-0118:  Pollution Prevention Program Plan 1996

         4.  DOE:  DOE Model Pollution Prevention Opportunity Assessment Guidance (February 1996)

         5.  DOE:  DOE Model Process Waste Assessment Plan (January 15,  1991)

         6.  DOE Environmental Management, DOE Order 5400.1:  Site WMin/PP Awareness Plans DOE-Wide
            Implementation Guidance - Update (March 1994)

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Subject:  Company Name Plant Pollution Prevention Program                                |


         7.   DOE:  Environmental Restoration and Waste Management 5-Year Plan, (1993)

         8.   DOE, Memorandum from Hazel R. O'Leary, Secretary of Energy, to Distribution (all elements of the
             "Implementation of Executive Order 12856, Federal Compliance with Right-to-Know Laws and Polk
             Prevention Requirements" (November 15, 1994)

         9.   DOE Order 5400.3: Hazardous and Radioactive Mixed Waste Program (February 22, 1989)

         10.  DOE Order 5700.6C:  Quality Assurance (August 21, 1991)

         11.  DOE Order 5820.2A:  Radioactive Waste Management (September 26, 1988)

         12.  DOE Order 6430.1 A:  General Design Criteria (April 6, 1989)

         13.  DOE Secretary of Energy Notice SEN-37-92 from James D. Watkins, Admiral, U.S. Navy (Retired),:
             Secretary of Energy: Waste Minimization Crosscut Plan Implementation (May 13, 1992)

         14.  DOE:  Waste Minimization/Pollution Prevention Crosscut Plan (1994)

         15.  EPA, Document No. EPA/625/7-88/003:  Waste Minimization Opportunity Assessment Manual
             (July 1988)

         16.  EPA Executive Order 12088:  Federal Compliance With Pollution Control Standards (October 13,
             1978)

         17.  EPA Executive Order 12856:  Federal Compliance With Right-to-Know Laws and Pollution
             Prevention Requirements (August 3, 1993)

         18.  EPA, Federal Acquisition and Community Right to Know, Executive Order 12969, (August 8,
             1995)

         19.  EPA, Federal Register Vol.  58, No. 102: Guidance to Hazardous Waste Generators on the
             Elements of a Waste Minimization Program (May 28, 1993)

         20.  EPA PL 94-83: National Environmental Policy Act (August 9, 1975)

         21.  EPA PL 99-499:  The Emergency Planning and Community Right-to-Know Act of 1986
             (October 17, 1986)

         22.  EPA PL 101-549, 104 Stat. 2399-2712: The Clean Air Act Amendments of 1990 (November 15, 1990

         23.  EPA PL 102-580: Clean Water Act of 1992 (October 31, 1992)

         24.  EPA PL 102-886: Federal Facility Compliance Act of 1992 (September 22, 1992)

III.  SCOPE/LIMITATIONS

Applies to all organizations at the Company Name and to all sources of pollution, including air emissions; untreate(
effluents; and all wastes, including hazardous, radioactive, radioactive mixed, toxic, sanitary, industrial, asbestos, m<
infectious waste generated from operations of the Company Name.

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Subject:  Company Name Plant Pollution Prevention Program
IV.  DEFINITIONS

     A.  Acronyms

         1.  DOE:           United States Department of Energy

         2.  DOE-XYZ:  Department of Energy - Office Name Operations

         3.  DP:          Defense Programs

         4.  EM:          Environmental Restoration and Waste Management

         5.  EO:          Executive Order

         6.  EPA:            United States Environmental Protection Agency

         7.  EPCRA:      Emergency Planning and Community Right-to-Know Act

         8.  P2:             Pollution Prevention

         9.  PPOA:          Pollution Prevention Opportunity Assessment

         10. PWA:           Process Waste Assessment

         11. RCRA:          Resource Conservation and Recovery Act

         12. TDEC:          Tennessee Department of Environment and Conservation

         13. TSCA:          Toxic Substances Control Act

     B.  Representative:  A representative from each Company Name Organization that serves as the central
         technical and administrative contact within that organization for the implementation of the Pollution Prev<
         Program.

     C.  Pollution Prevention (P2):  Activities that minimize or eliminate the volume, toxicity, or both of waste
         streams, emissions, or discharges generated; recycling processes that use, reuse, or reclaim a material firon
         stream in any media. The primary method for pollution prevention should be through source reduction. F
         opportunities should be explored secondarily to source reduction.  Pollution Prevention does not include t
         these are defined as implementation of best available technology or management practices.

     D.  P2 Activity Report Form: Forms used to populate the P2 Activity Data Base from which regulatory repofl
         prepared to provide the latest status to our customers, help with budgeting requests, identify barriers, and ]
         general knowledge of activities occurring on site. The P2 Program Office uses the information exclusivel;
         document activities, progress, etc., of the  company program.

     E.  Pollution Prevention (P2) Council: The P2 Council is composed of Pollution Prevention Representatives
         from each Company Name Organization, central organizations located at Company Name, and the
         Environmental Restoration Organization at Company Name; the Company Name P2 Coordinator and
         Program Staff; DOE; and technical subject matter experts as needed.  The Company Name P2 Coordinati
         chairs this council.

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Subject: Company Name Plant Pollution Prevention Program                                   |


      F.  Pollution Prevention Opportunity Assessment (PPOA):  The evaluation of process and operations for
         potential opportunities to apply pollution prevention techniques to reducing waste generation and disposal
         were previously known as Process Waste Assessments (PWA).

      G. Pollution Prevention Program Office: Composed of the Company Name Pollution Prevention
         Coordinator and other dedicated staff members within the Company Name Organization to administer tl
         P2 Program.

      H. Project Activity Data Base: A data base developed to help with the tracking of pollution prevention activi
         The information given to the Pollution Prevention Program Office on the P2 Activity Report Form is ente:
         maintained within the P2 data base.  This mechanism allows for the easy retrieval of information to suppo
         needs such as reporting functions, informational requests, and budget and programmatic planning activitie

      I.  Recycling: The use or reuse of waste as an effective substitute for a commercial product or as an ingrediei
         feedstock in an industrial process. It can occur on- or off-site and includes the reclamation of useful const
         fractions within a waste material, the removal of contaminants from waste to allow it to be used, or the us<
         as a fuel supplement or fuel substitute.

      J.  Source Reduction: The reduction or elimination of water, emissions, or discharges at the source, usually \
         process.  Any practice which (1) reduces the amount of any hazardous substance,  pollutant, or contaminan
         any  waste  stream, emission, or discharge or otherwise released into the environment (including fugitive er
         prior to recycling, treatment, or disposal; and (2) reduces the hazards to public health and the environment
         with the release of such substances, pollutants, or contaminants.  The term includes equipment or technolc
         modifications; process or procedure modifications; reformulation or redesign of products; substitution of i
         materials; and improvements in housekeeping, maintenance, training, or inventory control.

      K. Waste Generators:  All Company Name employees generate waste and are waste generators.

      L.  Waste Minimization: Any source reduction or recycling activity that results in either (1) reduction of total
         volume of waste; (2) reduction of toxicity of waste: or (3) both,  as long as that reduction is consistent witt
         general goal of minimizing present and future threats to  human health and the environment.

      M. Waste Reduction: Any change in a process, operation, or activity that results in the economically efficient
         reduction in waste material per unit or production without reducing the value output of the process, operat
         activity, taking into account the health and environmental consequences of such change.

      N. Waste Treatment: Any method, technique, or process that changes the physical, chemical, or biological cl
         of any waste in a way that neutralizes the waste or renders such waste nonhazardous, less hazardous, safer
         amenable for recovery, amenable for storage, or reduced in volume.

V.    GENERAL INFORMATION

      The Pollution Prevention Act of 1990 established a national  policy hierarchy for pollution prevention activitie;
      reduction as the preferred method over waste treatment, control, and disposal. Waste that cannot be prevented
      is to be treated in an environmentally safe manner to reduce  volume, toxicity, or mobility prior to storage and i
      For the purposes of this procedure, pollution prevention activities will include source reduction and recycling i
      including hazardous, radioactive, mixed, and sanitary. Waste treatment and disposal are addressed as best mai
      practices.

      Pollution prevention is a multimedia and multidisciplinary approach that advocates source reduction in which
      substitutions and engineering solutions are sought to reduce  the mass and toxicity of waste and pollutants. It s

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Subject: Company Name Plant Pollution Prevention Program                                   |


      concept of as low as reasonably achievable in that it promotes the use of innovative approaches in the front em
      process to achieve maximum pollution abatement.

      In addition to the Pollution Prevention Act of 1990, pollution prevention philosophy has been incorporated in
      environmental statutes including the Clean Air Act, Clean Water Act, Emergency Planning and Community R
      Know Act (EPCRA) Title III, Resource Conservation and Recovery Act (RCRA) and Toxic Substances Contr
      (TSCA).  The P2 provisions included in these statutes are not discussed specifically in this procedure.

      The overall objectives of the Company Name Program are to:

      A. Foster a company-wide philosophy to conserve resources, reduce the costs of production operations, and c
         minimum of waste and pollution in achieving company strategic objectives through developing and imple
         techniques, technologies, and programs that minimize waste and pollution generation.

      B. Promote the use of nonhazardous materials in Company Name operations to minimize the potential risks
         human health and the environment.

      C. Reduce or eliminate the generation of waste materials through input substitution; product reformulation; p
         modification; improved housekeeping; on-site, closed-loop recycling; and off-site recycling to achieve mi
         adverse effects on the air, water, and land when technically and economically feasible and cost effective.

      D. Comply with federal and state regulations and DOE requirements for pollution prevention.

VI.   REQUIREMENTS

      A. Airborne, liquid,  and solid wastes and effluents will be reduced to the greatest extent practical and results
         accordance with the provisions of DOE orders; the applicable regulations of local, state, and federal agenc
         company directives.

      B. Air emission and  water effluent pollutants will be integrated into all source reduction/recycling efforts.

      C. Planning, budgeting, and implementation of pollution prevention activities shall be an integrated function.

      D. Pollution prevention budgeting and funding requests shall be established annually to provide for a compre
         pollution prevention program.

      E. An aggressive pollution prevention program will be established with primary emphasis on reduction of all
         pollutants at the source. Following source reduction options, recycling alternatives will be investigated ar
         instituted.

      F. A waste stream prioritization matrix will be established to determine which streams should be targeted for

      G. Waste streams and other pollutants will be prioritized. Following prioritization, characterization of waste
         and airborne and  aqueous effluent will be conducted to:

          1.  establish mechanisms to determine pollutant/waste generation rates, and

         2.  provide a baseline by which reductions can be ascertained and quantified.

      H. Pollutant and waste records shall be established and maintained to:

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Subject: Company Name Plant Pollution Prevention Program                                   |


          1.  track waste and pollutant generation, storage, disposal, and discharge operations; and,

         2.  report pollution prevention efforts and accomplishments in accordance with DOE orders and state, loc
             federal regulations and permits.

      I.  Proactive and aggressive pollution prevention awareness programs for all employees will be established ai
         maintained to provide pollution prevention information to employees and to support a cultural change tow
         pollution prevention philosophy.

      J.  Employee training programs in pollution prevention will be developed to support the company's overall in

      K. Methodologies for monitoring  and quantifying pollution prevention successes will be developed.

      L. Incentive and awards programs for individual and team efforts associated with positive pollution preventic
         will be established and maintained.

      M. Characterization information from waste and pollutants should be used to conduct the following assessme
         and pollutant-generating process  and activities to determine the most effective pollution-abatement metho

          1.  Develop process area flow diagrams, materials balance, and process descriptions as applicable.

         2.  Develop options to minimize waste and pollutants.

         3.  Evaluate and prioritize reduction options.

         4.  Implement practicable low-cost or no-cost options.

         5.  Assess project expenditure options for cost savings/avoidance.

         6.  Budget for economically or environmentally practicable expenditure options.

      N. Recycling programs will be utilized  and, where necessary, developed to promote environmental benefits a
         comply with the requirements of Executive Order (EO) 12873.

      O. A proactive approach, including the  development of internal mechanisms to increase the purchase of recy<
         materials in accordance with EO  12873, will be established  and maintained.

      P. Procurement practices will be developed which favor the purchase of more environmentally preferred proi
         less toxic, smaller quantity, recyclable, etc.).

      Q. Future regulatory trends and initiatives in pollution prevention will be identified and communicated withii
         company.

      R. Pollution prevention achievements and lessons learned will be communicated.

      S. Pollution prevention information will be exchanged within the company and DOE facilities and with indu

      T. Pollution prevention research needs will be communicated to federal research facilities, academia,  and ind

      U. Compliance with all orders, agreements, compliance schedules, or compliance agreements issued by feder
         regulatory agencies shall be maintained and  documented.

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Subject: Company Name Plant Pollution Prevention Program                                  |


VII. RESPONSIBILITIES

      A  Company Name Manager

         1.  Supports the P2 Program by approving a company P2 Policy and Plan for the administration of an act
             Pollution Prevention Program.

         2.  Recognizes employee(s) achievements related to P2 activities (e.g., issue letters of appreciation).

      B.  Organizational Managers

         1.  Be accountable for reducing waste where practical within their respective organization. This should b
             accomplished by first considering source reduction opportunities followed by recycling.

         2.  Appoint Pollution Prevention Representatives, who are knowledgeable in organization processes and
             generation, to represent their organizations on the Pollution Prevention Council.

         3.  Develop and maintain organization-specific P2 Plans that outline goals and activities.

         4.  Ensure that funding is requested to meet P2 Program objectives, plans, and data requests.

         5.  Monitor and keep records of organizational pollution prevention activities (Appendix).

         6.  Conduct a semiannual assessment of the P2 Program elements within the organization.

         7.  Participate in the use/reuse of material surplus through various material exchange mechanisms.

         8.  Submit P2 Projects/Activities for nominations toward applicable  award recognition programs (e.g., A
             Excellence, Presidents Award for Continuous Improvement, DOE-XYZ Waste Minimization Award,

         9.  Appoint PPOA team members as needed to support preparation of assessments.

      C.  P2 Program Office Personnel

         1.  Involve all  employees in the pollution prevention effort by promoting integration and coordination of
             generators and waste management  personnel on pollution prevention matters.

         2.  Communicate with the P2 Council to exchange information, provide updates on pollution prevention
             developments, discuss problems, receive suggestions, and review the program. Hold meetings of the

         3.  Maintain open channels of communication laterally and vertically among the Company Name
             organizations to enhance awareness and convey pollution prevention objectives, goals, ideas, methods
             learned, and successes.

         4.  Prepare, review, and revise P2 Policy and Plans for approval and signature of company management.

         5.  Establish tracking and communication systems that are designed to provide waste stream characteriza
             baseline waste stream generation data and to enable quantitative evaluation of pollution prevention ef

         6.  Develop and maintain a system of reporting pollution prevention activities and results of minimizatio]
             both internally and in accordance with regulatory and DOE requirements.

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Subject: Company Name Plant Pollution Prevention Program                                   |


         7.  Track, report, and keep records of the company P2 activities and accomplishments.

         8.  Support the identification and implementation of pollution prevention methods and technologies to re
             generated waste volume and toxicity.

         9.  Test and evaluate new pollution prevention opportunities and associated technologies as applicable.

         10. Target any policies, procedures, or practices that may be barriers to pollution prevention.

         11. Review other procedures and practices for incorporation of P2 philosophy [e.g., incorporating P2 opp
             into the early planning stages of proposed projects (National Environmental Policy Act)].

         12. Evaluate on an annual basis progress made in implementation of pollution prevention opportunities id
             previous PPOAs, and determine if additional PPOA activities are required.

         13. Develop and revise, as necessary, specific goals and schedules for pollution prevention activities.

         14. Conduct management briefings to keep management abreast on P2 activities, barriers, and successes.

         15. Develop performance measures for which to assess the P2 Program elements. Administer a self-asses
             organization and the entire program on a semiannual basis.

         16. Determine a mechanism to prioritize waste streams, emissions, and discharges for additional
             studies/recommendations for targeting reduction.

         17. Identify funding and personnel requirements and establish schedules for the implementation of selects
             pollution prevention options and program activities.

         18. Track associated resource utilization to allow evaluation of use and needs.

         19. Create incentives for pollution prevention by establishing a program of awards for pollution prevent!c
             suggestions and accomplishments and establishing achievable, measurable pollution prevention goals
             each organization manager's annual measures of performance.

         20. Plan and organize incentives and awards programs for individual and team efforts associated with P2

         21. Develop and implement employee pollution prevention awareness and occupational training program;

         22. Sponsor an annual  awareness event to focus on environmental issues and general awareness of polluti
             prevention opportunities (usually conducted in conjunction with Earth Day, April 22).

         23. Support the procurement and use of products containing recovered materials.

         24. Collect and exchange pollution prevention information through technology transfer, outreach, and edi
             networks.

         25. Develop and maintain mechanisms for fully disseminating current technical information to company \

         26. Share pollution prevention information with other DOE sites in Location and across the DOE comple
             Participate in information exchange (e.g., attending when appropriate, EPA Seminars, DOE Contractc

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Subject: Company Name Plant Pollution Prevention Program                                  |


             Reduction Workshops, EM and DP Conferences on P2, P2 Coordinators meetings, Company Name ]
             Task Team, etc.).

         27. Communicate P2 achievements and difficulties (lessons learned) within the company.

      D. Pollution Prevention Council Members

         1.  Represent and support their organization managers and serve as the pollution prevention technology t
             point within their organization. This includes providing information about the wastes generated withi
             organization for reporting purposes; ensuring that new projects or changes to existing facilities have c
             pollution prevention in design and construction; and submitting ideas or problems for pollution prevei
             efforts originating within their organization.

         2.  Attend P2 Council Meetings. The members provide a comprehensive approach to meeting various pc
             prevention and waste minimization requirements, and the meeting serves as a forum for increased
             communication and consistent implementation of pollution prevention activities. The meeting also se
             information exchange mechanism to promote general awareness of pollution prevention information,
             providing a system to document pollution prevention progress, and to identify resources necessary to
             pollution prevention opportunities.

         3.  Implement the Company Name P2 Program Plan and Organization P2 Plan, if applicable. Review th
             objectives of the Company Name program in accordance with the facility's mission and needs.

         4.  Develop pollution prevention goals and implement programs and activities necessary to reduce both t
             and toxicity of waste and environmental pollutants within the organization.

         5.  Ensure that progress in pollution prevention implementation is documented and communicated for aci
             within the organization.

         6.  Advise Company Name Management on methods to initiate and carry out pollution prevention initia
             as well as promotion  of employee awareness and incentive programs.

         7.  Assist in long- and near-term pollution prevention planning activities, including evaluating technical i
             recommending resource requirements.

         8.  Ensure that project activity report forms are completed and submitted to the P2 Program Office for all
             proposed or ongoing  activities as soon as the project/planning is initiated.

         9.  Periodically communicate program objectives to organization personnel.

         10. Obtain waste generator support and input for the plant program.

         11. Facilitate integration  and coordinated interaction between waste generators on new and current polluti
             prevention matters.

         12. Evaluate and  revise pollution prevention goals and objectives in accordance with regulatory, DOE, an
             Company Name requirements.

         13. Prioritize waste streams or production areas for assessment.

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Subject: Company Name Plant Pollution Prevention Program                                  |


          14. Support the selection of teams to conduct or update pollution prevention opportunity assessments (PP
             required.

          15. Support the evaluation of the technical and economical feasibility of options to reduce waste generatii

          16. Support the recommendations and ranking of options for specific implementation by management.

          17. Support monitoring the performance of pollution prevention options that have been implemented and
             the performance according to established criteria.

          18. Support the monitoring and reporting of progress of the program through evaluations such as audits ai
             reviews.

          19. Solicit personnel nominations for achievement and incentives awards for P2 Activities.

         20. Coordinate program participation within organization.

         21. Support,  sponsor, and suggest ongoing and proposed employee awareness and training.

         22. Facilitate technology transfer and pollution prevention awareness.

         23. Submit budget and project information to support reporting functions of the P2 Program as necessary.

      E.  Waste Generators

          1.  Support tracking and reporting activities related to their material usage, waste generation, and pollutic
             prevention progress made.

         2.  Communicate P2 initiatives/issues to the P2 Representative for their organization and complete a proj
             activity report form (Appendix) for activities with the help of the P2 Representative.

         3.  Support PPOA activities related to their wastes and investigate and implement pollution prevention te

         4.  Support the development and implementation of new pollution prevention techniques as necessary.

         5.  Request technical assistance as needed from the P2 Program.

         6.  Participate in plant-wide source reduction and recycling programs.

         7.  Participate in P2 related training and awareness activities.

VIII. REQUIRED RECORDS

      A. The Pollution Prevention Activity Report Forms which identify P2 projects proposed or ongoing at the C(
         Name are to be transferred from the P2 Representatives of each respective organization to the P2 Program
         The P2 Program Office maintains a copy of the forms as well as transfers the information to the P2 Activi
         Base.

      B.  Other reporting requirements that are fulfilled to satisfy regulatory requirements are maintained in the P2 ;
         Office. The following is a list of the reports that are required to date:

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                       Rev. Date:                Supersedes:              Page: 13 of 20

Subject:  Company Name Plant Pollution Prevention Program


         1.   Company Name Annual Waste Reduction Report (SEN-37),

         2.   Tennessee Annual Generator Report (Waste Minimization Information Summary), and

         3.   Hazardous Waste Reduction Progress Report.
IX.  ADMINISTRATION

     A.  The Company Name Pollution Prevention Coordinator is responsible for the implementation, interpretati
         maintenance of this procedure.

     B.  A hard copy of this procedure shall remain in the Company Name Procedures Group office in Building (]
         Bldg. Number), in the HS&E Organization Procedures Representative's office in Building (Insert
         Bldg. Number), and in the Company Name Organization Procedures Representative's office in
         Building (Insert Bldg. Number).  The master copy of this procedure is done in PC WordPerfect 5.1,
         and the electronic (disk) storage is to be kept in the Electronic Publishing office in Building (Insert Bldj
         Number).

X.   APPENDIXES

     Project Activity Report Form

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Subject: Company Name Plant Pollution Prevention Program
                                       Appendix

                          PROJECT ACTIVITY REPORT FORM
                              Pollution Prevention Activity Report
                           Note: All Information Must Be Unclassified!
                                                                       Activity Number_
Organization:
Project Title:
Project Contact/Phone/Address:
Date:

Process Description
Project Current Status:
o Development o Construction
o Engineering/Design o Pilot Study
o Procurement o Start-up
P2 Adv.

Process Location:
o Implementation Complete
o On Hold
o Canceled
WASTE TYPE
o Solid o Liquid o Gas o Sludge o Emulsion
WASTE CATEGORY: (CHECK ALL APPLICABLE)
o (01) Oils and Other Oily Wastes o 11
o (02) Solvents and Other Solvent Wastes o 12
o (03) Commercial Chemical Products o 13
o (04 RCRA-Ignitable Wastes o 14
o (05 RCRA-Corrosive Wastes o 15
o (06 RCRA-Reactive Wastes o 16
o (07 Mercury Wastes o 17
o (08) Lead Wastes o (18
o (09) Cadmium and Chromium Wastes o (19
o (10) Other RCRA F-Listed Wastes
RELEASE TYPE (If Applicable)
o Air Emission o Water o Soil
Sanitary Waste, Solid
Sanitary Waste, Sewer
Medical Wastes
Industrial Waste, Liquid
Special Solid Waste
RAD Contaminated
PCB Contaminated (< 50 ppm)
PCB Contaminated (>50 ppm)
Other: (List all RCRA EPA Codes)
POLLUTION PREVENTION/WASTE MINIMIZATION TECHNIQUES (CHECK ALL APP1
SOURCE REDUCTION
o Inventory Control o Spill and Leak Prevention
o Good Operating Practices o Product or Process Changes
o Equipment/Technology Changes o Input Material Changes
ESTIMATED ANNUAL QUANTITY AND PI
Quantity Reduced:
o Pounds o Cubic Feet o Kg o Gallons
ESTIMATED ANNUAL TOXICITY REDUC'
Original Concentration (ppm) Reduced C
BUDGET INFORMATION:
Total Estimated Cost:
Work Order Number:
Estimated Cost Savings: (Use attac
:RCENT REDUCTIC
Quantity Repres
Category Chang
[TON:
Concentration (pp
Total Expended
Funding Status:
led worksheet to comp
JCABLE)
o RECOVERY OR RECYCLE
o TREATMENT
o POLLUTION CONTROL
o AFFIRMATIVE PROCUREMENT
o OTHER
N:
ents a % Reduction in Existing Stream
es: o RCRA to Non-RCRA o RAD to Non-RAD
m) Contaminant :
To Date:
o Completely Funded
o Funding Requested o
o Submitted for ROI/H
lete cost savings)
o Capital o Expense
o Unfunded
Funding Canceled
IV AL - Date Submitted

                                    Appendix (Cont.)
                           PROJECT ACTIVITY REPORT FORM

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Subject:  Company Name  Plant Pollution Prevention Program
  PROJECT DESCRIPTION AND JUSTIFICATION: (Attach additional information if needed.)
  PROJECT IMPLEMENTATION PLAN:

  Date Initiated       -  Date Complete                            Date Initiated       -  Date Complete
                            Developmental                                        -        Funding Requested
                            Pilot Testing                                          -        Design/Engineering
                            Procurement                                          -        Start-Up
                            Construction/Implementation                             -        Fully Operational

  PROJECT MILESTONES/ACCOMPLISHMENTS:  (Date Each Entry)
  PROJECT IMPEDIMENTS: (Check all applicable)

  o Training or Technical Assistance                                o Technical Feasibility
  o Economic Payback                                           o Resource Limitations
  o Implementation Experience                                     o Accidental Generation
  o Other	

  Explain Impediments and Possible Solutions:
  List all Request for Disposal Numbers associated with this waste stream in the past that would be affected by this project. Include UCN-2109
  Numbers, WSIN Numbers, and SID Numbers. (Attach additional information if necessary.)
  List Air Permit Number or Outfall Number associated with this release that will be affected by this project.
  P2 Representative Signature/Date	Project Contact Signature/Date

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Subject: Company Name Plant Pollution Prevention Program
                                       Appendix (Cont.)

                             PROJECT ACTIVITY REPORT FORM


                                 Cost Savings Worksheets
 Total One-Time cost (nonrecurring)


 Operating & maintenance costs (recurring):

 1.      Raw material purchasing costs


 2.      Process operation costs


 3.      PPE and related health/safety supply costs


 4.      Waste management costs


 5.      Recycling costs
Totals
) =IB_
Before One-Time Cost
Costs After Cost Cost Savings













B A C+E F
- A) - Depreciation x 100
                                                (C + E)

Depreciation = [Total One time Costs (e.g., Capital + Expensed) + Useful Life] and can be ignored for
projects with a useful life of more than 10 years.

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    Ohio Pollution Prevention  and Waste
 Minimization Planning Guidance  Manual
                         State of Ohio Environmental Protection Agency
                             Office of Pollution Prevention
                            (614) 644-3469, FAX (614) 728-1245
TABLE OF CONTENTS

Chapter 1. Introduction

Chapter 2. Benefits and Obstacles of Pollution Prevention

Chapter 3. Definition of Terms

Chapter 4. Overview of Federal Law, Regulation and Policy

Chapter 5. Overview of State of Ohio Law, Regulation and Policy

Chapter 6. Overview of Developing a Pollution Prevention Program

Chapter 7. Establish the Pollution Prevention Program

Chapter 8. Organize the Pollution Prevention Program

Chapter 9. Do a Preliminary Assessment

Chapter 10. Write the Pollution Prevention Program Plan

Chapter 11. Do a Detailed Assessment

Chapter 12. Define Pollution Prevention Options

Chapter 13. Cost Considerations

Chapter 14. Do Feasibility Analysis

Chapter 15. Write the Assessment Report

Chapter 16. Implement the Pollution Prevention Plan

Chapter 17. Measure Progress: Program and Project Evaluation

Chapter 18. Maintain the Pollution Prevention Program

Chapter 19. Other Waste Management Options

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APPENDICES
Appendix A References
Appendix B Sources of Pollution Prevention Information
Appendix C Ohio Hazardous Waste Facility Installation and Operation Permit Waste Minimization
Report Condition
Appendix D Class I Injection Well Facility Ohio Revised Code Requirements for Waste Minimization
and Treatment Plans
Appendix E Examples of Pollution Prevention Activities
Appendix F Pollution Prevention Information Available from Ohio EPA
Appendix G Ohio EPA Information Sources
Appendix H Trade Secrets and Confidentiality Requests

ACRONYMS
Back to the Ohio EPA Home Page
Back to the Ohio EPA, Office of Pollution Prevention Home Page

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     Ohio  Pollution Prevention and Waste

  Minimization  Planning  Guidance Manual

I Acronyms Table of Contents I Next Chapter }

                                    Chapter 1
                                   Introduction

"To keep ahead of the many environmental and economic challenges that face us in the 1990s, Ohio must
focus on pollution prevention. Global competition and the public's demand for environmental protection
require that business be as efficient and produce as little waste as possible."
                                          ^1    Donald R. Schregardus, Director, Ohio EPA

Why is pollution prevention planning essential for the State of Ohio? Ohio companies and governments
generate large amounts of waste, as illustrated in brief summary below, "Waste Generation in Ohio."
These wastes discharged to our air, water or land represent a significant loss of raw materials and a
potential threat to human health and the environment. To be responsible guardians of environmental
quality, waste generators must review their production processes and operations as well as consider both
the economic and the environmental benefits of implementing a pollution prevention program. The
public, consumers and employees expect simultaneous attention to both economics and the environment.
Pollution prevention is an excellent way to satisfy this demand.
 Waste Generation in Ohio

 2.9 million tons of hazardous waste generated in 1991
 125,500 tons of toxic chemicals released or transferred in 1991
 13.9 million tons of residential, industrial and commercial solid waste per year
Adopting a pollution prevention program as a way of doing business can provide a number of significant
benefits to a company. By decreasing the amount of waste generated or released, a company can reduce
waste disposal costs, improve worker safety, and reduce long-term liability. In addition, pollution
prevention methods may increase the efficiency of the production line and decrease costs associated with
the purchase of raw materials, inventory control, etc. Any resulting changes in efficiency or expenditures
may help the company to retain or improve its competitiveness in the marketplace.

Companies have traditionally evaluated their industrial processes in terms of optimizing their production,
but times have changed. Due to increasing environmental concerns associated with industrial waste,
companies must now incorporate waste management and prevention strategies into their production lines
with the goal of reducing waste generation. By increasing efficiency of operation, companies can see that
more of their raw materials go into products rather than ending up  as waste.

Donald R. Schregardus, Director of the Ohio EPA, emphasizes that, "To keep ahead of the many

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environmental and economic challenges that face us in the 1990's, Ohio must focus on pollution
prevention. Global competition and the public's demand for environmental protection require that
business be as efficient and produce as little waste as possible." Ohio is also working to reach the
national goal for environmental protection - to reduce or eliminate waste at its source - as established by
the Pollution Prevention Act of 1990 (see Chapter 4).

Introduction to  the Guidance Manual

This guidance manual is a general overview of how Ohio businesses and government facilities can
develop and implement a pollution prevention program. The manual uses the pollution prevention
program steps (with limited modifications) outlined in U.S. EPA's 1992 publication, Facility Pollution
Prevention Guide  (EPA/600/R-92/088). (Table C-3 in Appendix C compares the elements of U.S. EPAs
and the State of Ohio's guidance for developing a program). These steps include planning and
organization, assessment, feasibility analysis, implementation, and measuring progress. The manual also
uses substantial portions of the text from the Illinois Hazardous Waste Research and Information Center's
1993 publication, Pollution Prevention: A  Guide to Program Implementation.
 On September 1, 1993, Governor George V. Voinovich requested the top 100 Toxic Release Inventory
 (TRI) reporters in Ohio to work with Ohio EPA on developing comprehensive pollution prevention
 plans to reduce the various types of waste they generate. As Ohio EPA Director Donald R. Schregardus
 emphasized, "This is not just a paperwork exercise. The real goal is not the plan, it's the reduction."
This document was prepared under a federal fiscal year 1993 RCRA grant from U.S. EPA to Ohio EPA,
Division of Hazardous Waste Management, and the Office of Pollution Prevention, for Great Lakes
Basin activities. The original intent of this guidance manual was to provide waste minimization planning
guidelines (1) for class I injection well facilities and (2) for hazardous waste treatment, storage, and
disposal facilities. Class I injection well facilities have a statutory requirement to prepare and adopt a
waste minimization and treatment plan, including several general requirements for plan content.
Hazardous waste facilities are required by Ohio permits to submit a report describing their waste
minimization program.  Specific requirements for these types of facilities are slightly different; however,
Ohio EPA does not want to create different pollution prevention and waste minimization planning
guidance manuals for each regulated category of business nor for each environmental medium. This
general guidance manual provides a common approach for pollution prevention planning in Ohio for all
waste generators and for all media. This manual can be used by any organization, including businesses
and state and local government organizations. For brevity the words "company" and "business" are used
throughout the manual, but any organization's title can be substituted for these terms.

Because this manual is a generalized overview of how to develop and implement a pollution prevention
program, you will want to modify the program as needed to fit your facility.

Specific requirements for  class I injection well facilities and hazardous waste treatment,  storage, and
disposal facilities are included as appendices.

For more detailed information about pollution prevention programs, refer to U.S. EPA's Facility
Pollution Prevention Guide and to the reference section in the appendices of this guidance manual. U.S.
EPA's Facility Pollution Prevention Guide contains worksheets that may be helpful  in implementing and
documenting a pollution prevention program. Another general reference  document is U.S. EPA's  1993

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Reference Guide to Pollution Prevention Resources (EPA/742/B-93/001). This annual guide contains
information about publicly sponsored pollution prevention resources and training opportunities. The
document consolidates a wide range of pollution prevention information. Contact the Ohio EPA's Office
of Pollution Prevention for copies of these documents and a list of additional references.
                                Purpose of the Guidance Manual

 This guidance manual is intended to increase the amount and improve the quality of activity in
 pollution prevention planning in Ohio. It will help companies to compare their pollution prevention
 programs to the State of Ohio's goals. The State of Ohio, including Ohio EPA, does not intend to
 enforce the letter of this manual to determine what should be included in a pollution prevention plan or
 program. Ohio EPA does not intend to issue related checklists for inspection and enforcement.
 However, we do expect that all pollution prevention programs and plans will have significant
 substantive content, include the general components covered in this manual where appropriate, and
 clearly meet the spirit of this guidance and any applicable law. We do expect that programs and plans
 include efforts and substance comparable to the general headings of Table C-3 in Appendix C of this
 document, e.g., "Establish the pollution prevention program." We do not expect to require subsections,
 e.g., "Executive level decision; Policy statement;" following the exact content of Table C-3.
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                            ACRONYMS

CAAA
    Clean Air Act Amendments of 1990
CAMP
    Cleveland Advanced Manufacturing Program
CFC
    Chlorofluorocarbon
HAP
    Hazardous air pollutant (regulated by the CAAA)
HSWA
    Hazardous and Solid Waste Amendments of 1984
HWRIC
    Illinois Hazardous Waste and Research Information Center
IAMS
    Institute of Advance Manufacturing Sciences
MSDS
    Material safety data sheet
NICE3
    National Industrial Competitiveness Through Efficiency: Energy, Environment, and Economics
NPDES
    National Pollutant Discharge Elimination System
OAC
    Ohio Administrative Code
OAQDA
    Ohio Air Quality Development Authority
Ohio DOD
    Ohio Department of Development
Ohio EPA
    Ohio Environmental Protection Agency
Ohio DNR
    Ohio Department of Natural Resources
OPP

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     Office of Pollution Prevention, Ohio EPA
ORC
     Ohio Revised Code
OWDA
     Ohio Water Development Authority
PIES
     Pollution Prevention Information Exchange System
PMN
     Premanufacture Notice
POTW
     Publicly owned treatment works
PPDW
     Pollution Prevention Development Workgroup
PPIC
     Pollution Prevention Information Clearinghouse
RCRA
     Resource Conservation and Recovery Act
SARA
     Superfund Amendments and Reauthorization Act
SBAP
     Small Business Assistance Program, Ohio EPA
SOP
     Standard operating procedure
TQM
     Total Quality Management
TRI
     Toxic Chemical Release Inventory
TSCA
     Toxic Substance Control Act
U.S. DOE
     United States Department of Energy
U.S. EPA
     United States Environmental Protection Agency
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                                    Chapter 2
              Benefits and  Obstacles of Pollution Prevention

"Ifyou make the commitment to do pollution prevention and that commitment is at every level of the
company, you can create a healthier, much cleaner environment."

                                                         George Makrauer, Amko Plastics


Pollution prevention is often referred to as business planning with environmental benefits. The most
common benefits and incentives for establishing a pollution prevention program are presented here.
Some of the obstacles that may hinder implementation or program development are also discussed.

Incentives

Reduced Operating Costs (Economics) Pollution prevention activities usually save a company money
in the long term. Many pollution prevention projects have good returns on investment and short payback
periods. Money is usually saved in disposal costs, new material costs and improved operating efficiency.
Many firms report that the majority of savings comes from the latter.

Improved Worker Safety Reduction of the use of toxins in the workplace is a major aspect of pollution
prevention. (However, toxic users who manufacture a toxic substance would not be expected to plan for
the reduction in manufacturing of the specific toxic substance as a product.) By reducing or eliminating
toxic substance use, the safety of the work environment can be improved and personal protective
equipment requirements decreased. Also, reducing the likelihood of leaks, spills and releases can
decrease worker, visitor, and contractor exposure. These steps will result in cost savings through
preventing the loss of materials and possibly through decreased insurance rates by reducing medical
claims and disability leave. Better labor relations can also result from improved worker safety.

Reduced Compliance Costs Undertaking pollution prevention projects can reduce your regulatory
exposure and, in some cases, may eliminate the need for permits, manifesting, monitoring and reporting.
Keeping up with regulatory requirements and submitting the required reports is an expensive and time
consuming process which, if eliminated, saves money.

Increased Productivity Pollution prevention can improve plant productivity through more efficient use
of raw materials due to improved processes and operations. Many industrial plants that produce large
quantities of wastes may be using old technologies to make their products, or their processes may be
poorly controlled and inefficiently operated. Sometimes small improvements can result in increased
product yield and better quality.

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Increased Environmental Protection Many waste disposal and treatment methods have been shown to
be less protective of the environment than previously estimated. These methods may just move
environmental contaminants from one medium to another. They may cause future problems that are not
yet apparent. Pollution prevention reduces the generation of wastes at the source, or results 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 has become an important concern in recent years. Past disposal practices, even though they may
have been legal, have often caused environmental damage that has proved to be expense for industrial
facilities as well as damaging to their public image. Pollution prevention can help to reduce long term
liability by reducing the amount and the hazard of waste generated.

Continuous Improvement Successful implementation of a pollution prevention program can be an
integral part of a company's continuous improvement or Total Quality Management program. Reducing
wastes and improving efficiency are what both pollution prevention and continuous improvement are all
about.

Improved Company Image Society is becoming increasingly aware of the environmental hazards
associated with all types of waste. U.S. EPA publishes details of companies' waste and pollution
prevention efforts through the Toxic Release Inventory. U.S. EPA also publicly recognizes those
companies that make voluntary commitments to pollution prevention. To enhance their public image,
companies are implementing and publicizing pollution prevention activities.

Obstacles

Capital Requirements Implementation of many pollution prevention measures often requires capital
investment. Such projects may need to be justified on an economic basis.

Specifications Specifications can be both an incentive and an impediment. For instance, government
contracts may specify certain materials be used in the manufacture of a product or that virgin materials
be used rather than recycled materials.  This can lead to the use of materials that are damaging to the
environment or the unnecessary use of virgin materials where recycled materials 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. Companies should contact the appropriate regulatory agency early in the process of making
changes to the facility to ensure that all permitting requirements are considered.

Product Quality Issues Companies have great concern for the quality of the products they manufacture.
Some pollution prevention projects may change product quality,  even when properly implemented, and
thus may be regarded with skepticism.

Customers' Acceptance The customer ultimately defines product quality requirements. Anything that
affects the quality, or even the perception of its quality, may affect acceptance by the customer.

Immediate Production Concerns Implementation of pollution prevention projects may often require
time, money, and personnel, all of which are usually in short supply.

Company Image Concerns Occasionally companies are hesitant to admit that the "old way" may not

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have been the best way. Once easy-to-implement pollution prevention practices such as improved
operations, for example, are underway, companies may realize that they could have been doing it all
along but do not want the fact made public because it may make them look bad. However, many
companies do not have this attitude.

Available Time/Technical Expertise Some organizations may lack sufficient time or technical expertise
to develop and implement pollution prevention practices.

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," applies.

Although there may be many obstacles to implementing pollution prevention, the benefits can be so great
as to warrant working through the obstacles. By properly educating and including all employees, as well
as customers and suppliers, about the advantages and stages of a pollution prevention program,
successful projects and programs can be achieved.

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                                    Chapter 3
                               Definition of Terms

"Many terms have been used to describe pollution prevention and related activities."

Many terms have been used to describe pollution prevention and related activities. This guidance manual
uses the following terms. References for sources of definitions are given in parentheses.

"Pollution prevention" means the use of source reduction techniques in order to reduce risk to public
health, safety, welfare and the environment and, as a second preference, the use of environmentally
sound recycling to achieve these same goals. Pollution prevention avoids cross-media transfers of wastes
and/or pollutants and is multi-media in scope. It addresses all types of waste and environmental releases
to the air, water and land. (Note: This is Ohio EPA's working definition of pollution prevention. See
Chapter 4 of this manual for U.S. EPA's definition.)

"Source reduction" means any effort to reduce, at the source, the quantity of waste generated, toxic
chemical use, or any release into the environment. Source reduction measures include, but are not limited
to, process modifications, feedstock purity, good operating  and management practices, increases in the
efficiency of machinery, and recycling within a waste generating  or other production process. (Ohio
EPA, Office of Pollution Prevention, Fact Sheet #1, March, 1993)

"Recycle" means to use, reuse or reclaim a material (Ohio  Administrative Code (OAC) 3745-50-10).
Recycling does not include incineration, burning waste as fuel, or other treatment.

"Reuse" means reutilization of a material in an environmentally sound manner that will not result in a
hazard to human health or the environment (OAC 3745-50-10). A material is reused if it is either:
   1. employed as an ingredient, including use as an intermediate in an industrial process to make a
     product, or
  2. used in a particular function or application as an effective substitute for a commercial product
     (OAC 3745-51-01).

"Reclaim" A material is "reclaimed" if it is processed to recover a usable product or if it is regenerated.
(OAC 3745-51-01)

"Waste minimization" means any effort to reduce or recycle the quantity of waste generated, and when
feasible, to reduce or eliminate toxicity. "Waste minimization" does not include treatment, unless the
treatment is part of the recycling process. (Ohio Revised Code (ORC) 6111.045(F)) (Note: Waste
minimization for hazardous waste is defined at OAC 3745-50-10)

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"Treatment" means any method, technique or process designed to change the physical, chemical or
biological characteristics or composition of industrial waste or other waste; to neutralize the waste; to
recover energy or material resources from the waste; to render the waste nonhazardous or less hazardous,
safer to transport, store, or dispose of, or amenable for recovery, storage, further treatment, or disposal;
or to reduce the volume of the waste. (ORC 6111.045(F))

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                                    Chapter 4
             Overview of Federal Law, Regulation and Policy
"A strong emphasis on pollution prevention is the most important thing we can do for the future of
environmental protection in this country. We have to move our environmental effort 'upstream' to look
for opportunities for the use of pollution prevention."
                                                   Carol Browner, U.S. EPA Administrator
U.S. EPA is committed to a preventive strategy to reduce or eliminate the generation of environmentally
harmful pollutants which may be released to the air, land, and water. The following sections detail some
of U.S. EPAs efforts in pollution prevention, hazardous waste minimization, and voluntary pollution
prevention programs.

Pollution Prevention

The Pollution Prevention Act of 1990 established a national goal for environmental protection: to reduce
or eliminate waste at its source. The Pollution Prevention Act established the following national waste
hierarchy policy:
   • pollution should be prevented or reduced at the source whenever feasible;
   • pollution that cannot be prevented should be recycled in an environmentally safe manner whenever
     feasible;
   • pollution that cannot be prevented or recycled should be treated in an environmentally safe manner
     whenever feasible; and
   • disposal or other release into the environment should be employed only as a last resort and should
     be conducted in an environmentally safe manner.

U.S. EPA defines "pollution prevention" to mean "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 as any practice which: reduces the amount of any
hazardous substance, pollutant, or contaminant entering any waste stream or otherwise released into the
environment (including fugitive emissions) before recycling, treatment, or disposal; and reduces hazards
to public health and the environment associated with the release of such substances, pollutants, or

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contaminants. Some practices commonly described as "in-process recycling" may qualify as pollution
prevention. Environmentally sound recycling can reduce the need for treatment or disposal, and conserve
energy and resources. Pollution prevention addresses solid and hazardous waste and all air and water
pollutants, whether regulated or not.

The Pollution Prevention Act also states that each owner or operator of a facility required to file an
annual toxic chemical release form under section 313 of the Superfund Amendments and Reauthorization
Act (SARA) shall include with each filing a toxic chemical source reduction and recycling report for the
preceding calendar year. This requirement became effective in 1992. The reporting requirements include
the following:
   1.  the quantity of the chemical entering any waste stream or otherwise released to the environment;
   2.  the amount of the chemical which is recycled in a calendar year, including the percentage change
      from the previous year;
   3.  source reduction practices used with respect to that chemical during the year (this includes a
      variety of technologies and techniques such as improvement in management, training, inventory
      control, materials handling, or other general operational phases of industrial facilities);
   4.  projections of expected releases for the next two reporting years;
   5.  a ratio of production in the reporting year to production in the previous year; and,
   6.  techniques which were used to identify source reduction opportunities (such as employee
      recommendation, external and internal audits, participative team management, and material
      balance audits).

Although there are other requirements, these six provide an overview of the scope of information being
requested by the Act. Point 6 above lists a number of items that are important components of a pollution
prevention plan, and although not required, it is obvious that planning by  Ohio businesses and
government facilities is desired and will be necessary to fully comply with the regulations.

Hazardous Waste Minimization

With the passage of the Hazardous and Solid Waste Amendments (HSWA)  of 1984,  amending the 1976
Resource Conservation and Recovery Act (RCRA), Congress established a new policy concerning
hazardous waste management. Specifically, Congress declared that the reduction or elimination of
hazardous waste generation at the source should take priority over the management of hazardous wastes
after they are generated. HSWA contains several specific requirements that promote implementation of
waste minimization. Generators of hazardous waste who transport waste off-site are required to certify
on each hazardous waste manifest that they have a program in place to reduce the volume and toxicity of
such waste  to the degree determined by the generator to be economically practicable. Owners and
operators of permitted hazardous waste treatment, storage and disposal facilities are also required to
provide the same certification annually. Hazardous  waste generators and owners/operators of treatment,
storage and disposal facilities who manage their own waste on-site, must also identify in a biennial report
to U.S. EPA (annual to Ohio EPA): (1) the efforts undertaken during the year to reduce the volume and
toxicity of waste generated; and (2) the changes in volume and toxicity actually achieved in comparison
to previous years.

With the intent of meeting HSWAs goal, U.S. EPA has published a notice, "Interim Final Guidance:

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Guidance to Hazardous Waste Generators on the Elements of a Waste Minimization Program" (Federal
Register, volume 58, May 28, 1993). The full text of this notice is included in Appendix C of this
guidance manual. The notice is intended to provide guidance to hazardous waste generators and
treatment, storage and disposal facilities about what constitutes a waste minimization program in place
for certification under HS WA. The elements of a waste minimization program are also important
components of a pollution prevention plan. The elements include top management support,
characterization of waste generation and waste management costs, periodic waste minimization
assessments, developing a cost allocation system, encouraging technology transfer, and program
implementation and evaluation. Table C-2 in Appendix C compares U.S. EPA's program to the program
outlined in this guidance manual.

On May 18, 1993, U.S. EPA also announced a new Hazardous Waste Reduction and Combustion
Strategy. Waste reduction is a key component of the strategy. A state/federal task force has been
convened to fully evaluate the role of hazardous waste combustion in the management of hazardous
waste.

Ohio EPA is authorized to administer the federal hazardous waste program in Ohio. Appendix C of this
document contains information about Ohio Hazardous Waste Facility Installation and Operation Permits
and their condition that requires a Waste Minimization Report. The Waste Minimization Report is a
written document that the permittee must use to demonstrate  compliance with the certification
requirement to have a waste minimization program in place.

Voluntary Pollution Prevention Programs

U.S. EPA has developed several programs to encourage the use of pollution prevention techniques,
among other methods, to reduce toxic releases. U.S. EPA's 33/50 Program is a voluntary program to
reduce national pollution releases and off-site transfers of 17  toxic chemicals by 33 percent by the end of
1992 and by 50 percent by the end of 1995. The Green Lights Program sponsored by U.S. EPA
encourages companies to decrease their energy use by using more energy efficient lighting, which in turn
reduces the amount of emissions and waste generated through the generation of power. The State of Ohio
is a Green Lights Partner and promotes the Green Lights Program to companies in Ohio. Appendix B
discusses both of these programs in more detail.

U.S. EPA has proposed the creation of a program that would encourage and publicly recognize
environmental leadership. As described in the January 15, 1993 Federal Register, this  program would
also promote pollution prevention in manufacturing.

As part of the New  Chemicals Program under the Toxic Substances Control Act, companies are required
to  submit Premanufacture Notices (PMNs) before beginning production of new chemicals. The "Optional
Pollution Prevention Information" page of the PMN form provides submitters with the opportunity to
consider and provide  descriptions of pollution prevention and risk reduction options considered by the
company in regard to specific new chemical substances. Providing this optional pollution prevention
information to U.S. EPA may benefit PMN submitters by reducing regulatory controls and/or testing
requirements, if the pollution prevention information sufficiently mitigates U.S. EPA's concerns for the
toxicity, human exposure, or environmental releases of the PMN substance.

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                                    Chapter 5
          Overview of State of Ohio Law, Regulation and Policy

"Pollution prevention is apriority for this Administration. A strong pollution prevention program
minimizes waste and maximizes profits. It's good for business and for the environment - a real win-win."

                                                            Governor George V. Voinovich


The State of Ohio's environmental programs are increasingly emphasizing pollution prevention. Ohio is
modifying and expanding efforts that will help to redirect attention toward prevention for toxics and
other emissions and wastes. These activities are found in the Ohio Environmental Protection Agency, the
Ohio Department of Development, and the Ohio Department of Natural Resources. Appendix B,
"Sources of pollution prevention information," provides additional information about these activities.

Two Ohio laws are aimed at reducing waste generation in the state. House Bill 147 directs owners and
operators of Class I injection well facilities to prepare waste minimization and treatment plans for wastes
generated at these facilities. The plans will identify the specific technically and economically feasible
measures that will be taken to prevent or reduce releases into the environment. Appendix D of this
guidance manual discusses the waste minimization planning requirements for Class I injection well
facilities in detail.

The implementation of House Bill 592 has helped to stimulate activity in solid waste reduction and
recycling throughout Ohio's solid waste management districts. The major goals of H.B. 592 are to reduce
solid waste generation and increase recycling. By  1994, all districts will implement a solid waste
management plan which includes strategies for achieving 25 percent waste reduction and/or recycling as
a goal. The reduction goal is a planning objective, not an inflexible standard. These plans must be
approved by Ohio EPA. Some districts have developed innovative programs including establishing
commitments by business to reduce and recycle.

Hazardous waste minimization requirements are detailed in the preceding chapter on overview of federal
laws, regulations and policies. Appendix C of this document contains information about Ohio Hazardous
Waste Facility Installation and Operation Permits  and their condition that requires a Waste Minimization
Report. The Waste Minimization Report is a written document that the permittee must use to demonstrate
compliance with the certification requirement to have a waste minimization program in place as required
byRCRA.

Ohio EPA has general permitting authority for storm water general permits. The objective of the storm
water program is to reduce or eliminate illegal, whether intentional or unintentional, dumping of

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materials into storm water discharges. The general permit for industrial activity requires preparation and
implementation of a storm water pollution prevention plan. Permits also require implementation of best
management practices to control the quality of storm water runoff.

The Ohio Environmental Protection Agency (Ohio EPA) strongly supports the move toward more
pollution prevention and is involved in a number of specific pollution prevention activities. The Office of
Pollution Prevention (OPP) coordinates pollution prevention activities for all of Ohio EPA. The OPP has
four main objectives:
   1.  Facilitate the incorporation of pollution prevention into standard Agency operations and into
      standard State government operations.
   2.  Review and develop legislative initiatives for pollution prevention.
   3.  Increase awareness of pollution prevention opportunities through education, outreach and technical
      assistance for business, government and the public.
   4.  Analyze, develop and publicize information and data related to pollution prevention for use by
      business, government and the public.

The OPP provides on-site, by mail, or over the phone technical assistance; provides literature search
information; prepares program and industry specific fact sheets; and makes public presentations
regarding pollution prevention.

The OPP is currently coordinating the development of a strategy to integrate pollution prevention into
activities at Ohio EPA. This strategy will identify regulatory and non-regulatory options for integrating
pollution prevention concepts into existing media programs and propose new pollution prevention
activities for consideration by Ohio EPA.

As part of the Agency Pollution Prevention Strategy, Ohio EPA is now incorporating pollution
prevention requirements in many environmental enforcement cases. The Agency is pursuing this
condition to encourage additional environmental improvements, not just penalties, as a result of
enforcement. Some offers of settlement may include reduced monetary penalties in exchange for
commitments to develop pollution prevention plans, or for commitments to install source reduction
processes.

In 1991, Governor George V. Voinovich announced the formation of the Pollution Prevention
Development Workgroup (PPDW), directed by Ohio EPA. The purpose of the Workgroup is to develop
and coordinate pollution prevention initiatives throughout state government, business and consumer
activities. The goals of the workgroup include the development of a comprehensive Pollution Prevention
Strategy for Ohio and increasing communication on pollution prevention efforts between state agencies,
business and the public.

Currently, the PPDW is initiating pollution prevention planning for State Agencies by implementing a
pilot program which includes the Ohio Department of Administrative Services, the Ohio Department of
Natural Resources, the Ohio Environmental Protection Agency, and one facility within the Ohio
Department of Rehabilitation and Correction. Results are expected to reveal areas in State government
where pollution can be prevented through a variety of means. This effort is expected to be extended to
other  state agencies based upon the results of this initial effort.

On September 1, 1993, Governor Voinovich requested the top 100 emitters of toxic pollutants in Ohio to

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work with the Ohio EPA to develop comprehensive pollution prevention plans to reduce the various
types of wastes they generate. The State of Ohio's press release, "Pollution Prevention Planning - The
Environmental Strategy for the Future," states that wastes in the plans will include chemicals in the Toxic
Release Inventory, hazardous and solid wastes, air emissions, and wastewater discharges. The plans will
identify the types of waste generated, evaluate ways to limit the source of the wastes, set forth a written
course of action to carry out each facility's commitment to pollution prevention, and establish progress
reporting to measure the success of each program.
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{ Acronyms  Table of Contents }

                                     Appendix C
   Ohio Hazardous Waste Facility Installation and Operation Permit Waste
                           Minimization Report Condition
This appendix describes the Waste Minimization Report Condition in Ohio Hazardous Waste Facility Installation
and Operation Permits and describes references that can be used to complete a Waste Minimization Report. The
appendix also compares the elements of a pollution prevention/waste minimization program in this guidance
manual, U.S. EPA's interim final guidance to hazardous waste generators, and U.S. EPA's Facility Pollution
Prevention Guide.

Owners and operators of permitted hazardous waste treatment, storage and disposal facilities are required to certify
annually that they have a waste minimization program in place, and are required to include this certification in their
operating record. The Ohio Administrative Code (OAC 3745-54-73 (B)(9)) states that the operating record must
include:

      "A certification  by the  permittee,  no  less often than
      annually,  that  the permittee  has  a program in place  to
      reduce  the volume and toxicity of  hazardous waste that he
      generates  to  the  degree  determined by  the permittee  to be
      economically  practicable;  and the  proposed method of
      treatment,  storage, or  disposal is that  practicable
      method  currently  available to the  permittee which
      minimizes  the present and future  threat  to human health
      and the environment."

Ohio Hazardous Waste Facility Installation and Operation Permits contain a condition that requires a Waste
Minimization Report. The waste minimization report condition is given in Table C-1. The Waste Minimization
Report is a written document that the permittee must use to demonstrate compliance with the certification
requirement to have a waste minimization program in place.

Ohio EPA is authorized to  administer the RCRA program in Ohio, including issuing hazardous waste treatment,
storage and disposal facility permits. Ohio EPA's authorized RCRA program operates in lieu of U.S. EPA's
program. Ohio EPA's authority includes conditional authority for waste minimization condition in permits. For
informational purposes only, facilities should note  that U.S. EPA's Region V office has developed RCRA waste
minimization permit language, evaluation criteria,  and checklists (December,  1992). Region V has also developed
two guidance documents related to their permit language. Region V's Recommended Minimum Standards,
Hazardous Waste Reduction Plan/Waste Reduction Implementation Report Evaluation Criteria, is to be used by
Permittees to develop plans and reports, and by permit writers to evaluate the plans and reports. Region V's Region 5
Hazardous Waste Reduction Plan/Waste Reduction Implementation Report Guidance is designed to aid the facility
in the development of these documents.

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                         Table C-1. Waste Minimization Report Condition
Waste Minimization Report
      OAC  Rule 3745-54-73

 (a)   The  Permittee  shall submit a Waste Minimization Report describing  the
      waste minimization program required by O.A.C. 3745-54-75  (H),   (I),  and
       (J);  O.A.C.  3745-54-73  (B)  (9);  and, O.A.C.  3745-52-20  (B)  at  least once
      every two years.   The provisions of O.A.C.  3745-54-75  (H),  (I), and (J) ;
      and  O.A.C. 3745-54-73  (B)  (9) must be satisfied annually.

 (b)   In completing  this report, the  Permittee  shall refer to the following
      information:   instructions prepared by the  Ohio EPA for completing the
      Waste Minimization Annual  Report required by O.A.C.  3745-54-75  (H),  (I),
      and  (J); the Federal Register notice of May 28, 1993, vol.  58, p.  31114,
      "Interim Final Guidance:  Guidance to Hazardous Waste Generators on the
      Elements of  a  Waste Minimization Program";  U.S. EPA's  "Facility
      Pollution Prevention Guide"  (EPA/600/R-92/088) May,  1992;  Ohio EPA's
      "Ohio Pollution Prevention and  Waste Minimization  Planning Guidance
      Manual"; and any subsequent updates.  The Waste Minimization Report
      prepared by  the permittee  should incorporate the phases outlined in the
      "Facility Pollution Prevention  Guide" including planning  and
      organization,  assessment,  feasibility analysis, implementation,
      measuring progress, and maintaining the program.   Similar content  and
      additional discussion are  found in Ohio EPA's "Ohio Pollution  Prevention
      and  Waste Minimization  Planning Guidance  Manual."

 (c)   The  Permittee  shall submit the  Waste Minimization  Report  to the Director
      within one-hundred and  eighty days  (180)  of journalization of  this
      permit,  and  shall submit updates to this  report biennially thereafter.
Waste Minimization References

The waste minimization permit condition lists four references that permittees shall refer to when completing their
waste minimization reports. These references are briefly described here.

a) Instructions prepared by the Ohio EPA for completing the Waste Minimization Annual Report required
by OAC 3745-54-75 (H), (I), and (J).

The instructions include definitions for waste minimization, recycling, and source reduction, examples of waste
minimization activities, and a general list of waste minimization activities (see activity codes list).

b) Federal Register notice of May 28,1993, vol. 58, p. 31114, "Interim Final Guidance: Guidance to
Hazardous Waste Generators on the Elements of a Waste Minimization Program."

The notice is intended to provide guidance to hazardous waste generators and treatment, storage and disposal
facilities about what constitutes a waste minimization program in place for certification under HSWA. An effective
waste minimization program should include each of the general elements listed below, although some of these
elements may be implemented in different ways depending on the preferences of individual companies. The notice
provides specific explanations and examples for each of the elements. The full text of this notice is included as a
part of Appendix C.

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       1)   Top management  support
       2)   Characterization of waste generation  and waste  management
            costs
       3)   Periodic  waste  minimization  assessments
       4)   A  cost allocation  system
       5)   Encourage technology  transfer
       6)   Program  implementation and evaluation

c) U.S. EPA's Facility Pollution Prevention Guide (EPA/600/R-92/088) May, 1992

U.S. EPA's Facility Pollution Prevention Guide 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. The manual is also a source of concepts and ideas for developing and implementing a pollution
prevention program. The manual lists several steps in a program, including planning and organization, assessment,
feasibility analysis, implementation, measuring progress, and maintaining the program. The Ohio Pollution
Prevention and Waste Minimization Planning Guidance Manual uses the pollution prevention program steps (with
limited modifications) outlined in U.S. EPA's Facility Pollution Prevention Guide.

d) Ohio Pollution Prevention and Waste Minimization Planning Guidance Manual

The Ohio Pollution Prevention and Waste Minimization Planning Guidance Manual (this document) should also be
used as a reference when writing a Waste Minimization Report. Two tables are included in this manual that compare
elements of different manuals and guidelines to U.S. EPA's Facility Pollution Prevention Guide (refer to Table C-2,
Comparison of elements of a pollution prevention program in U.S. EPA's Facility Pollution Prevention Guide to
elements of a waste minimization program in U.S. EPA's interim final guidance to hazardous waste generators; and
to Table C-3, Comparison of elements of a pollution prevention program in U.S. EPA's Facility Pollution
Prevention Guide to elements of a pollution prevention/waste minimization program in the Ohio Pollution
Prevention and Waste Minimization Planning Guidance Manual). These comparison tables illustrate that although
the names of elements and order of elements may be different, the manuals and guidelines essentially describe the
same kind of pollution prevention and waste minimization programs.

General Considerations

The Waste Minimization Report must be specific and should include the phases outlined in U.S.  EPA's Facility
Pollution Prevention Guide. However, operations and processes at different facilities may be quite diverse. Because
waste minimization activities  are dependent on the operations and processes, waste minimization reports will vary
and may be tailored to individual facilities.

Considerations for commercial treatment, storage and disposal facilities and research and development facilities

Commercial treatment, storage and disposal facilities and research and development facilities have different
constraints on both the type and amount of material inputs to their facilities that limit their options for pollution
prevention. Commercial treatment,  storage and disposal facilities are in business to take a variety of wastes from
generators. Research and development facilities work with a variety of materials and the types of materials that will
be used (and subsequent waste generated) in a specific project are not always identified before a project starts. Some
pollution prevention projects may require changes in the facility's hazardous waste permits. The permitting process
can be lengthy and may delay implementation of the pollution prevention projects.

While there are numerous pollution prevention opportunities at such facilities, their pollution prevention plans and
programs should reflect the above constraints and the nature of materials input. Because of these constraints,
pollution prevention plans and programs for these facilities may be less extensive than plans and programs for other
business or government facilities. Pollution prevention assessments can still be conducted, giving special
consideration to assessing support departments that are common to many facilities (see Chapter 12, Table 2). For

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basic concepts on pollution prevention options, research and development facilities can refer to Ohio EPA's Fact
Sheet 16, Research and Educational Laboratory Waste, and to U.S. EPA's 1990 document Guides to Pollution
Prevention: Research and Educational Institutions, EPA/625/7-90/010.

Hazardous waste treatment, storage and disposal facilities have many common activities, some required by
hazardous waste regulations, that provide the opportunity for implementing and integrating pollution prevention into
the operation of the facility. Several activities are listed here with suggestions for pollution prevention options. Any
changes implemented as a result of pollution prevention options must be in compliance with the facility's permit and
with applicable environmental regulations.

All facilities must evaluate wastes to determine their characteristics. Procedures for sampling and laboratory
analysis can be designed to incorporate pollution prevention.

All facilities must train employees about the operation of the facility and hazardous waste management. Pollution
prevention and waste minimization should be an integral part of the training.  Employees should be encourage to
provide suggestions for pollution prevention projects.

Contingency plans can be written to incorporate pollution prevention options. Plans on responding to emergencies
and spills should consider responses that will address the situation and at the  same time minimize the use of
resources and minimize waste generation. Proactive measures against leaks and spill  should be incorporated in plans
for these facilities.

All facilities have general inspection requirements  and  emergency preparedness and prevention requirements.
Facilities could use these inspections and requirements  as opportunities to continually look for pollution prevention
aspects of daily operations.

All facilities receive waste and manage waste in containers, tanks, or pipelines. Standardized practices for
preventing pollution can be incorporated in loading/unloading procedures,  storage procedures,  and daily operations
of waste management units.

Treatment, storage and disposal activities should be assessed as unit processes by following the steps outlined in
Chapter 9 of this manual. Treatment, storage and disposal activities are the "production" processes of a hazardous
waste facility and can be evaluated in a similar manner. For example, a different flocculent could be used in a
wastewater treatment operation that may result in less solids being generated for later management or disposal.

The following example illustrates some of the challenges facing a commercial solvent reclaimer. The spent solvent
waste generators may determine, to a large extent,  the amount of waste generated by  the solvent reclaimer when
processing a given waste stream.  The annual  volume of hazardous waste generated by the reclaimer  is dependent on
the percentage of reclaimable material in the  hazardous waste and the total hazardous waste received for the year.
The reclaimer's annual receipts are dependent on the generators' reduction of generated spent solvent waste and the
reclaimer's competitive market position for that business year.

The reclaimer can work to improve operating efficiencies and improve reclamation processes at the reclamation
facility as part of a pollution prevention program. For example, the reclaimer could survey the  entire process, look
for areas and equipment that might have fugitive emissions, and institute equipment and operating practices to
reduce or eliminate emissions. The reclaimer could use statistical process control techniques to determine the
optimum operating conditions for distillation equipment. The reclaimer might also want to work with the generators
to educate them on ways to consolidate waste streams and reduce waste generation in an effort to maximize
recovery of spent solvent. Although working with customers to reduce waste at the source might be very desirable
from the reclaimer's and customers' points of view  and  is strongly encouraged by the State of Ohio, this activity is
not required for hazardous waste treatment, storage and disposal facilities.

The following example illustrates some of the challenges facing a specialty chemicals research and development
facility. The "products" of the research and development facility are knowledge (formulations for new chemical

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products) and waste. Experimental products developed during the research process cannot be sold; they must be
managed as waste. Research and development of new chemicals is a constantly changing field and highly
individualized. Constantly changing experiments make it difficult to define production units. It is also difficult to
meaningfully determine a waste per unit product index when the product undergoes frequent changes.
Research and development facilities might define "research" as a process, and concentrate on how to make pollution
prevention, particularly source reduction, part of and integrated into the design of research processes. Engineers and
chemists can work with statisticians to design experiments to reduce waste. Procedures for procuring raw materials
can be established. Information about past experiments can be made easily accessible by computer so that research
chemists do not repeat old work. Computer modelling can help to predict experimental outcomes and product
performance.
                                                Table C-2
  Comparison of Elements of a Pollution Prevention Program in U.S. EPA's Facility Pollution Prevention Guide to
 Elements of a Waste Minimization Program in U.S. EPA's Interim Final Guidance to Hazardous Waste Generators
   Facility Pollution Prevention Guide
     Pollution Prevention Program
 Establish the pollution prevention program
    • Executive level decision
    • Policy statement
    • Consensus building
 Organize the program
    • Name task force
      State goals
 Do preliminary assessment
    • Collect data
    • Review sites
    • Establish priorities
Characterization of waste generation and waste
management costs
 Write program plan
    • Consider external groups
    • Define objectives
    • Identify potential obstacles
    • Develop schedule
 Do detailed assessment
    • Name assessment teams
    • Review data and sites
    • Organize and document information
 Define pollution prevention options
    •  Propose options
    •  Screen options
         Hazardous Waste Generators
         Waste Minimization Program
Top management support
    •  Policy statement
    •  Commit to implementing recommendations
Top management support
    •  Designate a waste minimization coordinator
    •  Set specific goals
 The generator or treatment, storage, or disposal
facility should document its program (in writing)..."
(see note 3)
Periodic waste minimization assessments
   •  Identify opportunities for waste minimization
Periodic waste minimization assessments

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 Do feasibility analysis
    • Technical
    • Environmental
    • Economic
 Write assessment report
                                      The generator or treatment, storage or disposal
                                     facility should document its program (in writing)..."
                                     (see note 3)
 Implement the plan
    • Select projects
    • Obtain funding
    • Install the selected projects
 Measure progress
    • Acquire data
    • Analyze results
 Maintain the pollution prevention program
                                     Encourage technology transfer
                                     Periodic waste minimization assessments
                                        • Analyze waste minimization opportunities
                                          based on the true costs of the waste
                                     Cost allocation system
                                     Top management support
                                        • Commit to implementing recommendations
                                     Program implementation and evaluation
                                     Program implementation and evaluation
                                     Top management support
                                        • Publicize success stories
                                        • Reward employees
                                        • Train employees
                                     Program implementation and evaluation
Notes
   1.
   The pollution prevention program elements follow the outline of U.S. EPA's Facility Pollution Prevention
   Guide (EPA/600/R-92/088).
2.  The waste minimization program elements follow the outline of U.S. EPA's Interim Final Guidance to
   Hazardous Waste Generators on the Elements of a Waste Minimization Program (Federal Register, May 28,
   1993, vol. 58, p. 31114).
3.  This statement is part of the May 28, 1993 Federal Register explanation of the waste minimization program.
                                                Table C-3
  Comparison of Elements of a Pollution Prevention Program in U.S. EPA's Facility Pollution Prevention Guide to
   Elements of a Pollution Prevention/Waste Minimization Program in the Ohio Pollution Prevention and Waste
                                  Minimization Planning Guidance Manual
   Facility Pollution Prevention Guide
     Pollution Prevention Program
                                                     State of Ohio Pollution
                                            Prevention/Waste Minimization Program
 Establish the pollution prevention program
    • Executive level decision
    • Policy statement
    • Consensus building
                                     Establish the pollution prevention program
                                        • Executive level decision
                                        • Policy statement
                                        • Consensus building

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Organize the program
   • Name task force
   • State goals
Organize the pollution prevention program
   • Name the pollution prevention task force
   • State goals
   • Increase employee awareness and involvement
   • Train employees
   • Reward pollution prevention successes
Do preliminary assessment
   • Collect data
   • Review sites
   • Establish priorities
Do a preliminary assessment
   •  Understanding processes and wastes
   •  Gathering background information
   •  Define production units
   •  Characterize general process
   •  Understand unit processes
   •  Outputs
   •  Perform materials balance
   •  Establish priorities
Write program plan
   • Consider external groups
   • Define objectives
   • Identify potential obstacles
Write the pollution prevention program plan
   • Define objectives
   • Identify potential obstacles
   • Develop schedule
   • Augment the plan
Do detailed assessment
   • Name assessment teams
   • Review data and sites
   • Organize and document information
Do a detailed assessment
   •  Begin assessments
Define pollution prevention options
   • Propose options
   • Screen options
Define pollution prevention and waste minimization options
   • Propose options
   • Screen options
                                        Cost considerations
                                           • Determine full cost of waste
                                           • Develop economics
                                           • Establish a cost allocation system
Do feasibility analysis
   • Technical
   • Environmental
   • Economic
Do feasibility analysis
   • Technical evaluation
   • Economic evaluation
   • Environmental evaluation
Write assessment report
Write the assessment report
Implement the plan
   • Select projects
   • Obtain funding
   • Install the selected projects
Implement the pollution prevention plan
   • Select projects
   • Obtain Funding
   • Install the selected projects

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Measure progress
• Acquire data
• Analyze results
Maintain the pollution prevention program
Measure progress: Program and project evaluation
• Program evaluation
• Program modification
Maintain the pollution prevention program
Notes:
   1. The pollution prevention program elements follow the outline of U.S. EPA's Facility Pollution Prevention
     Guide (EPA/600/R-92/088).
   2. The pollution prevention/waste minimization program elements follow the outline of the Ohio Pollution
     Prevention and Waste Minimization Planning Guidance Manual.
Federal Register/Vol. 58, No. 102 / Friday, May 28, 1993

Part VII Environmental Protection Agency

Guidance to Hazardous Waste Generators on the Elements of a Waste Minimization Program; Notice

This reference is not included here in this Web version. You may check the U.S. EPA Web site for it.

{ Acronyms Table of Contents }
Back to the Ohio EPA Home Page
Back to the Ohio EPA, Office of Pollution Prevention Home Page

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     Ohio  Pollution  Prevention and Waste

  Minimization  Planning  Guidance Manual

{ Acronyms Table of Contents }


                                   Appendix B
               Sources of Pollution  Prevention Information


                  Ohio Environmental Protection Agency (Ohio EPA)

Office of Pollution Prevention (OPP)

The Ohio EPA Office of Pollution Prevention is responsible for coordinating pollution prevention
activities for all divisions at Ohio EPA. The office is comprised of the Technical Assistance Unit and the
Program Management and Evaluation Unit. Both units are responsible for developing criteria for
measuring pollution prevention progress, supporting activities relating to the preparation and passage of
pollution prevention legislation in Ohio, and supporting the development of a pollution prevention
strategy for Ohio. OPP has a total of 10 permanent staff positions. Additional part time staff form a
Pollution Prevention Intern Program.

The goal of OPP is to  develop and implement pollution prevention initiatives that effectively reduce
pollutants and conserve natural resources in Ohio by emphasizing source reduction and environmentally
sound recycling. OPP seeks to accomplish this goal through five objectives:
   • Facilitate the incorporation of pollution prevention into standard Agency operations and into
     standard State government operations;
   • Review and develop legislative initiatives for pollution prevention;
   • Increase awareness of pollution prevention through education, outreach, and technical assistance
     for business, government, and the public; and
   • Analyze, develop, and publicize information and data related to pollution prevention for use by
     government and the public.

The OPP provides on-site or over the phone technical assistance; provides literature search information;
prepares program and industry specific fact sheets; and makes public presentations regarding pollution
prevention. OPP maintains a library containing more than 1400 pollution prevention documents such as
case studies, fact sheets, manuals, guides, videotapes and more. OPP has access to several databases and
information from other agencies. In addition, interested parties can request copies of approximately 75
publications via an information request form.

For more information contact:
Office of Pollution Prevention
Ohio EPA

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1800 WaterMark Drive
P.O. Box 1049
Columbus, OH 43216-1049
Phone: 614/644-3469

Small Business Assistance Program

The Clean Air Act Amendments (CAAA) of 1990 require each state to develop a Small Business
Stationary Source Technical and Environmental Compliance Assistance Program to help small
businesses comply with the Act. This program will consist of two elements, a Small Business Assistance
Program (SBAP) and a Small Business Ombudsman. Ohio EPAs Division of Air Pollution Control will
administer the SBAP which will provide information to small businesses on compliance, pollution
prevention, accidental release prevention and detection, alternative technologies, and other areas. The
Ombudsman will represent small businesses with air pollution control concerns before appropriate
government offices and aid in the dissemination of information, operate a toll-free hotline, and refer
small businesses to specialists, as well as other functions. The Ohio Air Quality Development Authority
is proposed as the state's Small Business Ombudsman for CAAA related activities

For more information contact:
Small Business Assistance Program
Division of Air Pollution Control
Ohio EPA
1600 WaterMark Drive
Columbus, OH 43215
Phone: 614/644-2270

                         Ohio Department of Development (DOD)

Edison Technology Centers

Ohio's Edison Technology Centers are independent not-for-profit organizations funded in part by the
Ohio Department of Development and in part by industry. By offering pollution prevention technical
assistance to waste generators, these Centers can offer a wealth of good information geared toward
cost-effective benefits to businesses which help improve manufacturing bottom lines and protect the
environment.

Cleveland Advanced Manufacturing Program (CAMP)

CAMP, northeastern Ohio's Edison Technology Center, plays an active role in helping manufacturers
adopt new technologies, integrate new management techniques, and streamline operations to increase
productivity. A new goal is to encourage businesses to think in terms of pollution prevention and total
quality management. CAMP now offers several environmental services, including pollution prevention
assistance. CAMP provides waste reduction assessments and counselling. Technology application
engineers develop options, estimate cost savings and project the impact of suggested changes.

For more information contact:
Cleveland Advanced Manufacturing Program
4600 Prospect Avenue

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Cleveland, OH 44103
Phone: 216/432-5300
Outside Cleveland: 800/927-0436
Fax: 216/362-2900

Institute of Advanced Manufacturing Sciences (IAMS)

IAMS1 Center for Applied Environmental Technologies (CAET) offers technical assistance in pollution
prevention (Ohio Pollution Prevention Technical Assistance, OPPTA), assists companies in applying
"clean" technologies, and serves as a an information clearinghouse for pollution prevention methods and
technologies. CAET offers industry on-site pollution prevention assessments to quantify wastes, suggest
process changes, and identify potential savings. Following an assessment, CAET is available to work
with companies to develop and initiate pollution prevention programs. Literature searches and telephone
assistance are available as well as training programs and networking opportunities. CAET is also
working to help industry reduce solid waste and to develop markets for recycled products.

For more information contact:
Institute of Advanced Manufacturing Sciences, Inc.
1111 Edison Drive
Cincinnati, OH 45216-2265
In Cincinnati call: 513/948-2000
Outside of Cincinnati:  800/345-4482
Fax: 513/948-2109

                       Ohio Department of Natural Resources (ODNR)

ODNR's Division of Litter Prevention and Recycling is very active in public awareness activities
concerning recycling through the "Keep Ohio Beautiful" program and through several grant programs to
enhance recycling activities in the State. ODNR works with the Association of Ohio Recyclers and the
National Recycling Coalition to promote recycling on  both state and national levels.

For more information contact:
Division of Litter Prevention and Recycling
Ohio Department of Natural Resources
Fountain Square
Columbus, OH 43224-1387
614/265-6333

                     Ohio Air Quality Development Authority (OAQDA)

OAQDA was created in 1970 by the Ohio General Assembly to work in partnership with Ohio's
businesses and citizens to promote clean air and economic prosperity.  OAQDA helps businesses - large
and small - obtain competitive, low cost financing to purchase and install air pollution control equipment
to meet clean air standards. OAQDAs responsibilities include:
   •  Issuing air quality revenue bonds, notes, and refunding bonds;
   •  Making loans for air quality projects for industry, public utilities, commerce, distribution, or
      research;

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   •  Making loans and grants to government agencies to acquire and construct air quality facilities;
   •  Acquiring, constructing, and operating air quality facilities; and
   •  Conducting research and development on air quality issues

For more information contact:
OAQDA
50 West Broad Street, Suite 1901
Columbus, OH 43215
Phone: 614/224-3383

                        Ohio Water Development Authority (OWDA)

OWDA was created by the Ohio General Assembly in 1968 to provide financing to Ohio communities
for the planning and construction of drinking water, waste water, and solid waste facilities. OWDA also
issues private activity bonds for solid waste facilities, facilities which furnish potable water, and facilities
for the disposal of hazardous waste. Additionally, OWDA administers a Research and Development
Grant Program which provides grants to communities seeking innovate solutions to environmental
problems dealing with solid waste, water, waste water, and energy resource development.

For more information contact:
OWDA
50 W. Broad Street, Suite  1425
Columbus, OH 43215
Phone: 614/466-5822

                United  States Environmental Protection Agency (U.S. EPA)

33/50  Program

The 33/50 Program was initiated in January of 1991 by U.S. EPA to reduce national pollution releases
and off-site transfers of 17 toxic chemicals reported under the Toxics Release Inventory (TRI).
Reduction goals are 33 percent by the end of 1992 and 50 percent by the end of 1995. Companies are
encouraged to examine their industrial processes and establish cost effective pollution prevention
practices for these chemicals. Participation in the 33/50 Program is completely voluntary. The TRI will
be used to track these reductions using 1988 data as a baseline.

The 17 chemical groups are:
   •  benzene
   •  cadmium & cadmium compounds
   •  carbon tetrachloride
   •  chloroform
   •  chromium &  chromium compounds
   •  cyanide & cyanide compounds
   •  lead & lead compounds
   •  mercury & mercury compounds

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   •  methylene chloride
   •  methyl ethyl ketone
   •  methyl isobutyl ketone
   •  nickel & nickel compounds
   •  tetrachloroethylene
   •  toluene
   •  1,1,1-trichloroethane
   •  trichloroethylene
   •  xylenes

For more information contact:
The TSCA Hotline: 202/554-1404. All information received by EPA through the 33/50 program is
available to the public through the Emergency Planning and Community Right to Know Act (EPCRA)
Reporting Center
P.O. Box 23779
Washington, D.C. 20026-3779
Phone: 202/488/1501.

Green Lights Program

Green Lights is a voluntary, non-regulatory program that encourages the widespread use of
energy-efficient lighting and the reduction of pollution generated by energy consumption. Green Lights
participants agree to survey their facilities and over five years upgrade 90 percent of their square footage.
The upgrade must be profitable and the lighting quality must be maintained or enhanced. As of July
1993, over 1000  organizations have joined the program. In addition to saving energy, participants receive
positive public recognition.

On July 8, 1993, the State of Ohio officially became  a Green Lights Partner. Ohio is the first state in U.S.
EPAs Region V to join the program. The Ohio Department of Administrative Services is coordinating all
state related projects. Ohio is also promoting Green Lights to other businesses in Ohio through the Ohio
EPA,  Office of Pollution Prevention.

For more information contact:
Green Lights Program
U.S. EPA
401 M Street, SW
(6202J)
Washington, DC 20460
or call the Green Lights Hotline:
Phone: 202/775-6650
Fax: 202/775-6680

For State of Ohio buildings contact:
Ohio Green Lights Office
Department of Administrative Services

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35th Floor, State Office Tower
30 East Broad Street
Columbus, OH 43266
Phone: 614/644-5901

Ohio companies and local governments should contact Ohio EPA, Office of Pollution Prevention.

Pollution Prevention Information Clearinghouse (PPIC) and Pollution Prevention Information Exchange
System (PIES)

The PPIC is dedicated to reducing or eliminating industrial pollutants through technology transfer,
education, and public awareness. It is a free, nonregulatory service of the U.S. EPA which is operated by
the U.S. EPAs Office of Pollution Prevention and Toxics and the Office of Research and Development.
PPIC includes the following information exchange mechanisms to ensure efficient and comprehensive
support:
   •  Repository - a hard copy reference library containing up-to-date information on pollution
      prevention.
   •  PIES - an interactive, PC-based system designed to provide instant access to data bases,
      publications, and on-line access to peers.
   •  Hotline - a free telephone service for those without access to a personal computer. The hotline can
      answer technical questions, locate and order documents and provide referrals.
   •  Outreach efforts - general and industry- specific information packets on prevention opportunities
      as well as workshop training sessions.

PIES is the computerized information network of EPAs PPIC. PIES provides on-line interactive access
through modem and PC to a wide range of pollution prevention information. It is open 24 hours a day
and requires no user fees. PIES features literature search functions, a national calendar of conferences
and workshops relating to pollution prevention, hundreds of case studies of pollution prevention, a
message center for interaction and exchange with participants, and direct access to news and documents.
The International Cleaner Production Information Clearinghouse (ICPIC) and OzonAction are also
available by accessing PIES.

To access PIES, a personal computer, a modem, communications software, and a telephone line are
necessary. PIES is accessible through a regular telephone call, and the SprintNet network.

For more information on PPIC contact:
Pollution Prevention Information Clearinghouse
U.S.EPA,PM211-A
401 M Street, SW
Washington, D.C. 20460
Phone: 202/260-1023
Fax: 202/260-0178

For more information on PIES contact:
Pollution Prevention Information Exchange System c/o SAIC
7600-A Leesburg Pike
Room 369

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Falls Church, VA 22043
Phone: 703/821-4800
Fax: 703/821-4775

National Industrial Competitiveness Through Efficiency: Energy, Environment and Economics (NICE3)

A joint project of the U.S. Department of Energy (U.S. DOE) and U.S. EPAs Office of Pollution
Prevention and Toxics (OPPT), the NICE3 grant program strives to improve energy efficiency, advance
industrial competitiveness, and reduce environmental emissions of industry. Large-scale research and
demonstration projects are targeted at industries with the highest energy consumption and greatest levels
of toxics and chemicals released.

Eligible industries are in SIC codes 26 (paper), 28 (chemicals), 29 (petroleum and coal products), and 33
(primary metal industries). Projects are expected to use the one-time grant funds as seed money to
overcome start-up risks. It is expected that industry will finance continuation of projects past the initial
grant funding period. As part of the grant-funded phase, awardees will design, test, demonstrate, and
assess the feasibility of new processes and/or equipment which can significantly reduce generation of
high-risk pollution.

For more information contact:
David Bassett
Office of Pollution Prevention and Toxics
U.S. EPA
401M Street, SW (7409)
Washington, D.C. 20460
Phone: 202/260-2720

                                      Waste Exchanges

A waste exchange is a specialized service which provides a network for linking wastes (industrial and
municipal) with those who may be able to use the wastes or recycle them. A waste exchange is a medium
for finding uses for wastes which otherwise would be discarded. A waste exchange is like a specialized
classified advertising system where a third party (the waste exchange) maintains confidentiality of the
parties listing available waste or wanting to use recyclable material. Waste exchanges provide
information on reuse and recycling opportunities which is not readily available otherwise and typically
reach thousands of specialists in waste management with information.

National Materials Exchange Network
(800) 858-6625 modem access line
(509)325-0551

Northeast Industrial Waste Exchange
90 Presidential Plaza, Suite 122
Syracuse, New York 13202
(315)422-6572
Fax:(315)422-9051

Canadian Waste Materials Exchange

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ORTECH
Sheridan Park Research Community
2395 Speakman Drive
Mississauga, Ontario, Canada L5K 1B3
(416) 822-4111 Ext. 265
Fax: 416/823-1446

The Indiana Waste Exchange
c/o RTN
P.O. Box 454
Carmel, IN 46032
(317)574-6505
Fax:(317)844-8765

Industrial Material Exchange Service
P.O. Box 19276
2200 Churchill Road, #24
Springfield, Illinois 62794-0276
(217) 782-0450
Fax:(217)782-9142

Kentucky Waste Options
Room 312, Ernst Hall
University of Louisville
Louisville, KY 40292
(502) 588-7260

RENEW, Office of Pollution Prevention
P.O. Box 13087
Austin, Texas 78711-3087
(512)463-7773
Fax:(512)463-8317

Southeast Waste Exchange
Urban Institute
Department of Civil Engineering
Univ. of North Carolina at Charlotte
Charlotte, North Carolina 28223
(704) 547-2307

Gene Jones
Southern Waste Information Exchange
P.O. Box 960
Tallahassee, Florida 32302
(800)441-SWIX
Fax: (904)  574-6704

Waste Net

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401 Mazur St.
Cincinnati, Ohio 45219
(513)421-9768

Waste Reduction Strategies
9060 Outville Road
Pataskala, Ohio 43062
(614)927-2511
Fax:(614)927-1147

Merit Environmental Management
781 Beta Drive, Suite G
Cleveland, Ohio 44143
(216)461-7760
Fax:(216)461-2873

Tencon/Wastelink
P.O. Box 12
Terrace Park, Ohio 45174-0012
(513)248-0012
{ Acronyms  Table of Contents }

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     Ohio  Pollution  Prevention  and Waste

  Minimization Planning Guidance  Manual

I Acronyms Previous Chapter Table of Contents I Next Chapter }


                                    Chapter 6
        Overview of Developing a Pollution Prevention Program

"A pollution prevention program involves developing and implementing a continuous strategy to address
all waste generated by a facility and procedures for prioritizing and systematically reducing these
wastes."


There is often general confusion among the terms pollution prevention program, plan and project. Many
companies have compiled a list of projects and called the list a plan - such a list is not a plan. A pollution
prevention program involves developing and implementing a continuous strategy to address all waste
generated by a facility and procedures for prioritizing and systematically reducing these wastes. A
pollution prevention plan is a written guide used to chart the progress of the program. It reiterates
management support, lists reasons for the program, identifies the pollution prevention team, describes
how waste will be characterized, provides a strategy and schedule for pollution prevention assessments,
includes an evaluation of all costs incurred by producing and handling waste, institutes a cost allocation
system, indicates how technology transfer will take place, addresses training needs, and discusses how
the program and projects will be evaluated and implemented. The plan needs to be periodically updated
to reflect the continuous nature of a pollution prevention program. Pollution prevention projects are the
specific activities undertaken to reduce or eliminate waste.

In the chapters that follow, the steps to establish and maintain a pollution prevention program will be
presented. These steps follow the elements (with limited modifications) outlined in U.S. EPAs 1992
publication, Facility Pollution Prevention Guide (EPA/600/R-92/088). Figure 1 illustrates the major
steps in a pollution prevention  program as described in this guidance manual. These steps include:
               Figure 1: Elements of a Pollution Prevention Program
A. Establishing the pollution prevention program by obtaining support from top management, writing a
policy statement, and building consensus within the company or facility.

B. Getting the program started by naming a task force, stating goals, increasing employee awareness and

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involvement, and training employees in pollution prevention.

C. Doing a preliminary assessment, including reviewing and describing in detail the manufacturing
processes within the facility to determine the sources of waste generation and to define a baseline
inventory to be used to set goals and evaluate progress; and establishing priorities for further assessment
based on the results.

D. Writing the pollution prevention program plan.

E. Conducting a detailed assessment.

F. Identifying potential pollution prevention opportunities for the facility.

G. Determining all costs of current waste generation, management, and disposal, and establishing a
system of proportional waste management charges for those departments that generate waste.

H. Selecting the best pollution prevention options for the company through feasibility analyses of
technical, economic, and environmental considerations.

I. Writing an assessment report to describe results of the assessment and including the report in the
program plan.

J. Implementing the pollution prevention plan, including selecting projects, obtaining funding, and
installing projects

K. Measuring progress by evaluating the pollution prevention program on a company-wide or
facility-wide basis as well as evaluating specific pollution prevention projects.

L. Maintaining and sustaining the pollution prevention program for continued growth and continued
benefits to the company. Reevaluating the program as economic situations change and/or process
equipment require upgrading.

The concepts presented in this manual are applicable to the reduction of all waste regardless of
environmental media, quantity or toxicity. Some interpretation may be needed to make the suggestions
usable by your specific business and facility.

For more detailed information about pollution prevention programs, refer to U.S. EPA's Facility
Pollution Prevention Guide and to the reference section in the appendices  of this guidance manual. U.S.
EPA's Facility Pollution Prevention Guide contains worksheets that may be helpful in implementing and
documenting a pollution prevention program.

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     Ohio Pollution  Prevention and  Waste

  Minimization  Planning Guidance Manual

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                                   Chapter 7
               Establish the  Pollution Prevention Program

"Pollution prevention plans can get people to think about the alternatives, but action requires leadership
and incentive."

                                                                      Tom Zosel, 3M


Executive Level Decision

Top management support is critical to get a pollution prevention program started, to incorporate it into
already existing activities, and to sustain it. Specific types of support needed from management include:
assigning responsibility for progress evaluation, allocating time and budget, and recognizing
achievements. Continuity of the pollution prevention program is important. It should be set up in such a
way that one  step can flow naturally into the following step in a continuous cycle.

Suggestions on how to garner the support of all levels of management include providing them with
information on some of the benefits of implementing a pollution prevention program. Include the
following topics:
   •  cost savings through reduced raw material use and reduced waste, handling, transportation and
     storage costs
   •  increased productivity
   •  improved product quality
   •  regulatory compliance
   •  worker health and safety
   •  reduction of potential long-term liability
   •  examples of what other similar companies have achieved
   •  improved public/corporate image

To get all management levels interested in developing a pollution prevention program and to increase
their knowledge about the subject, bring to their attention case studies from other successful companies.
Bring in outside speakers to talk about benefits of developing pollution prevention programs. If the
company or facility already has some exceptional pollution prevention activities underway, consider
applying for the State of Ohio Governor's Awards for Outstanding Achievement in Pollution Prevention.
Just the act of applying for this or other awards can result in more commitment from all levels of

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management.

Policy Statement

To begin a successful pollution prevention program, draft a brief written policy statement in support of a
pollution prevention program. Obtain endorsement of the policy by all management levels and then
distribute to all employees. In some cases, developing a corporate-wide policy statement can be a lengthy
process. Rather than allow this procedure to delay proceeding with the program, an interim policy or
area-specific policy can be developed. This can get the program started; the corporate policy can follow
later.

As with other policy statements your company develops, your pollution prevention policy  statement
should state why a program is being established, what is to be accomplished in qualitative  terms, and
who will do it. Two example policy statements are given in Figure 2. They differ in level of detail, but
both answer these key questions:
Why are we implementing pollution prevention?
      We want to protect the environment while saving money.
      We want to save money while protecting the environment.
What will be done to implement pollution prevention?
      We will reduce or eliminate the amounts of all types of waste, and we will improve energy
      efficiency.
Who will implement pollution prevention?
      Everyone will be involved.

                              Figure 2. Policy Statement Examples
      POLICY STATEMENT EXAMPLE 1 — "(Your Company or Facility Name) is committed to
      excellence and leadership in protecting the environment. In keeping with this policy, our
      objective is to reduce waste and emissions. We strive to minimize adverse impact on the air,
      water, and land through pollution prevention and energy conservation. By successfully
      preventing pollution at its source, we can achieve cost savings, increase operational efficiencies,
      improve the quality of our products and services, maintain a safe and healthy workplace for our
      employees, and improve the environment. (Your Company or Facility Name)'s environmental
      guidelines include the following:

      — Environmental protection is everyone's responsibility. It is valued and displays commitment to
      (Your Company or Facility Name).

      — We will commit to including pollution prevention and energy conservation in the design of all
      new products and services.

      — Preventing pollution by reducing and eliminating the generation of waste and emissions at the
      source is a prime consideration in research, process design, and plant operations. (Your Company
      or Facility Name) is committed to identifying and implementing pollution prevention
      opportunities through encouraging and involving all employees.

      — Technologies and methods which substitute nonhazardous materials and utilize other source

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      reduction approaches will be given top priority in addressing all environmental issues.

      — (Your Company or Facility Name) seeks to demonstrate its responsible corporate citizenship
      by adhering to all environmental regulations. We promote cooperation and coordination between
      business, government, and the public toward the shared goal of preventing pollution at its
      source."
      POLICY STATEMENT EXAMPLE 2 — "At (Your Company or Facility Name), protecting
      the environment is a high priority. We are pledged to eliminate or reduce our use of toxic
      substances and to minimize our use of energy and generation of all wastes, whenever possible.
      Prevention of pollution at the source is the preferred alternative. When waste cannot be avoided,
      we are committed to recycling, treatment, and disposal in ways that minimize undesirable effects
      on air, water, and land."

      (Adapted from: Waste Reduction Institute for Training and Applications Research, Inc.
      (WRITAR), 1991, Survey and Summaries, and Minnesota Office of Waste Management, Feb.
      1991, Minnesota Guide to Pollution Prevention Planning)
Consensus Building

A pollution prevention program needs to be viewed by all personnel in the facility as a way of doing
business. It can be incorporated within a total quality management (TQM) program because it focuses on
increasing efficiencies and more effectively utilizing raw materials. It also builds nicely on a health or
environmental safety program because it can do the following: reduce the amount/toxicity of chemicals
in the workplace; reduce short and long-term exposure of employees, visitors, and contractors; reduce or
eliminate monitoring requirements; reduce air handling equipment requirements; and, reduce or eliminate
the need for personal protective equipment.

The commitment from all employees to implement a pollution prevention program starts before any
assessment or evaluations have been performed. It is measured as the time and effort needed to raise
employee awareness, establish a cohesive pollution prevention team, and begin to incorporate pollution
prevention ideas into the day-to-day operations of the company. Pollution prevention is a team effort.
The people who enter the facility every day are the most valuable assets to ensure a pollution prevention
program works well.
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                               Establish the pollution
                                prevention program
     Maintain the pollution
      prevention program
   Measure progress:
 Program and project
      evaluation
Organize the pollution
 prevention program
        Do a preliminary
          assessment
 Implement the
    pollution
 prevention plan
        Write the pollution
          prevention plan
Write the assessment
          Do a detailed

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report
              assessment
  Do feasibility analysis
 Define pollution
prevention options
                           Cost considerations

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     Ohio Pollution  Prevention  and  Waste
  Minimization  Planning Guidance Manual
{ Acronyms  Table of Contents }

                                  Appendix D
                        Class I Injection Well Facility
     Ohio Revised Code Requirements for Waste Minimization and
                               Treatment Plans
Effective May 28, 1992, Ohio House Bill 147 amended sections of the Ohio Revised Code (ORC)
regarding the regulation of Class I injection wells for the disposal of sewage, industrial wastes, hazardous
wastes and other wastes. Pursuant to these amendments, each owner or operator of a Class I injection
well facility must prepare and adopt a waste minimization and treatment plan by May 28, 1994. The plan
will identify the specific technically and economically feasible measures that will be taken to prevent or
reduce releases into the environment. Elements that must be included in a waste minimization and
treatment plan are listed on pages D-2 to D-4. Note also that this section of the Ohio Revised Code
contains several definitions of terms. These definitions are similar to definitions given in this guidance
manual; however, there are some differences in definitions.

Table D-l is included to show the similarities between a pollution prevention program as outlined in U.S.
EPA's Facility Pollution Prevention Guide and a waste minimization and treatment plan for a Class I
injection well facility. This comparison table illustrates that although the names of elements and order of
elements may be different, the guide and the Class I injection well facility requirements essentially
describe the same kind of pollution prevention and waste minimization programs.

Owners and operators of Class I injection well facilities may use this guidance manual and U.S. EPA's
Facility Pollution Prevention Guide as a reference for preparing a waste minimization and treatment
plan. These manuals concentrate on pollution prevention and waste minimization. Facilities can use the
elements in these manuals for developing plans. However, the manuals do not discuss treatment options.

Treatment technologies are commonly broken down into several categories: physical, thermal, chemical,
and biological. Table D-2 lists classes of treatment technologies and gives examples of each class.
Facilities should consider all treatment technologies when choosing treatment options, and should also
consider innovative technologies.


Ohio Revised Code, Section 6111.045
Injection of waste into wells
Waste minimization and  treatment plans

Ohio Revised Code , Section 6111.045

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(A)   Not  later  than  twenty-four  months  after  the  effective  date  of
     this section, each  owner  or operator  of  a  class  I  injection
     well facility shall prepare and  adopt a  waste  minimization  and
     treatment  plan  to identify  the specific  technically  and
     economically feasible  measures that will be  taken  to prevent
     or reduce  releases  into the environment  of the industrial
     waste and  other wastes generated at the  facility and,  in the
     case of  such an injection well facility  that is  located on  the
     premises of the industrial  facility,  the industrial  waste and
     other wastes generated at that industrial  facility.  The waste
     minimization and treatment  plan  shall cover  a  three-year
     planning period and shall include  all of the following:

   (1)     The name,  address, and,  if  applicable,  standard
          industrial classification code of the facility;

   (2)     A summary  of the  industrial wastes  and  other  wastes
          generated  at the  facility,  including  supporting data and
          calculations;

   (3)     A description  of  the facility's  historic  efforts  at waste
          minimization and  treatment  and of existing  waste
          minimization and  treatment, source  reduction, and
          recycling  practices  undertaken at the facility  in 1987
          and subsequent years;

   (4)     An  assessment  of  the technically and  economically
          feasible options  for the further elimination  or reduction
          of  such wastes that  considers the impacts of  cross-media
          transfers  and  gives  preference to source  reduction over
          the recycling,  treatment or disposal  of the wastes;

   (5)     The identification of  specific objectives to  prevent,
          reduce, or recycle releases of such wastes  when
          technically and economically  feasible options exist;

   (6)     An  explanation of the  rationale  for the objectives
          identified under  division  (A)(5)  of this  section;

   (7)     A signed policy statement articulating  the  commitment  of
          upper management  and the corporation  to implement the
          waste minimization and treatment plan and its objectives.

(B)   Each waste minimization and treatment plan prepared  and

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     adopted  under  division  (A)  of  this  section  shall  be  retained
     at  the facility  to  which  it applies and  shall  be  made
     available  for  inspection  and review by the  director  of
     environmental  protection  or his  authorized  representative.
     The disclosure of any trade secret  information contained  in
     any such plan  is subject  to section 1333.51 of the Revised
     Code.

(C)   Every three  years after the adoption of  a waste minimization
     and treatment  plan  under  division  (A) of this  section,  the
     owner or operator of the  facility to which  the plan  applies,
     on  or before the anniversary of  the date of the adoption  of
     the plan,  shall  do  all of the  following:

   (1)    Review  the  operation of the facility for  any changes in
         the type  and amount  of industrial waste or other wastes
         generated at the facility that have occurred since the
         adoption  of the plan or the most recent revision of  the
         plan;

   (2)    If  necessary or appropriate, reevaluate the  technically
         and economically feasible options for  reducing  or
         eliminating the generation  of  industrial  waste  or  other
         wastes  at the  facility;

   (3)    If  any  changes in the type  or  amount of wastes  generated
         at  the  facility are  identified under division  (C)(1) of
         this  section or if,  after a reevaluation  conducted under
         division  (C)(2) of this section, the owner or operator of
         the facility determines that the waste minimization  and
         treatment options in the  plan  or most  recent revision of
         the plan  should be updated, amend the  plan to update the
         information contained in  it and include in the  amendment
         an  explanation of the need  for the  amendment.

(D)(1)    Not later than two years  after the  effective date  of this
         section,  each  owner  or operator of  a class I injection
         well  facility  shall  submit  to  the director of
         environmental  protection  an executive  summary of the
         waste minimization and treatment plan  adopted by the
         owner or  operator under division (A) of this section.
         The executive  summary shall include a  synopsis  of  each of
         the elements required to  be included in the  plan under
         divisions (A)(2) to  (6) of  this section and  shall  include
         a signed  policy statement articulating the commitment of
         upper management and the  corporation to implement  the

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          plan  and its  objectives.

   (2)     Every three years  after  the  adoption of  a  waste
          minimization  and treatment plan under division (A)  of
          this  section,  the  owner  or operator  of a class I
          injection well facility,  on  or  before the  anniversary  of
          the date of the adoption of  the plan,  shall  submit  to  the
          director a revised executive summary of  the  plan  that
          meets the requirements of division (D)(1)  of this section
          and contains  revisions to the amendments to  the plan made
          by the most recent review of the plan required under
          division (C)  of this  section.

(E)   No  person  shall fail to comply with  this  section.

(F)   As  used in this section:

   (1)     "Disposal" means the  discharge,  deposit, injection,
          dumping,  spilling,  leaking,  emitting,  or placing  of any
          industrial waste or other wastes into or on  any land or
          ground or surface  water  or into the  air, except if  the
          disposition constitutes  storage or treatment.

   (2)     "Recycling" means  to  use, reuse,  or  reclaim  a material.

   (3)     "Release" means any spilling, leaking, pumping, pouring,
          emitting,  emptying, injecting,  escaping, leaching,
          dumping,  or discharging  into the environment of any
          industrial waste or other wastes,  including  the
          abandonment or discarding of barrels,  containers,  or
          other closed  receptacles that contained  an industrial
          waste or other waste.

   (4)     "Source reduction" means any practice that reduces  the
          amount of any industrial waste  or other  wastes entering
          any waste stream or otherwise released into  the
          environment,  including fugitive emissions, prior  to
          recycling, treatment, or disposal and that reduces  the
          hazards to public  health and the environment associated
          with  the release of such wastes.   "Source  reduction"
          includes equipment or technology modifications, process
          or procedure  modifications,  reformulation  or redesign  of
          products,  substitution of raw materials, and improvements
          in housekeeping, maintenance, training,  or inventory
          control.   "Source  reduction" does not include any
          practice that alters  the physical, chemical,  or

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           biological characteristics  or the volume of an  industrial
           waste  or other wastes through a process or activity that
           is not integral  to and necessary for  the production of a
           product or the providing of a service.

    (5)     "Treatment" means  any method,  technique,  or process
           designed to change the physical, chemical, or biological
           characteristics  or composition of any industrial  waste or
           other  wastes; to neutralize the waste;  to recover energy
           or material resources from  the waste;  to render the waste
           nonhazardous or  less hazardous, safer to transport, store
           or dispose of, or  amenable  for recovery,  storage,  further
           treatment, or disposal; or  to reduce  the volume of the
           waste.

    (6)     "Waste minimization" means  any effort to reduce or
           recycle the quantity of waste generated and, when
           feasible,  to reduce or eliminate toxicity.  "Waste
           minimization" does not include treatment unless the
           treatment  is part  of the recycling process.

HISTORY:   144  v H 147.  Eff 5-28-92
                                   Table D-1
 Comparison of Elements of a Pollution Prevention Program in U.S. EPA's Facility Pollution Prevention
  Guide to Elements of a Waste Minimization and Treatment Plan for a Class I Injection Well Facility
  Facility Pollution Prevention Guide
    Pollution Prevention Program
           Class I Injection Well Facility
      Waste Minimization and Treatment Plan
Establish the pollution prevention program
   • Executive level decision
   • Policy statement
   • Consensus building
ORC 6111.045(A)(7) - A signed policy statement
articulating the commitment of upper management and the
corporation to implement the waste minimization and
treatment plan and its objectives
 Organize the program
   • Name task force
   • State goals
ORC 6111.045(A)(7) - (same as above)

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Do preliminary assessment
   •  Collect data
   •  Review sites
   •  Establish priorities
Write program plan
   •  Consider external groups
   •  Define objectives
   •  Identify potential obstacles
   •  Develop schedule
ORC 6111.045(A)(2) - A summary of the industrial wastes
and other wastes generated at the facility, including
supporting data and calculations
ORC 6111.045(A)(3) - A description of the facility's
historic efforts at waste minimization and treatment and of
the existing waste minimization and treatment, source
reduction, and recycling practices undertaken at the facility
in 1987 and subsequent years
Do detailed assessment
   •  Name assessment teams
   •  Review data and sites
   •  Organize and document information
ORC 6111.045(A)(4) - An assessment of the technically
and economically feasible options for the further
elimination or reduction of such wastes that considers the
impacts of cross-media transfers and gives preference to
source reduction over the recycling, treatment or disposal of
the wastes
Define pollution prevention options
   •  Propose options
   •  Screen options
ORC 6111.045(A)(4) - (same as above)
Do feasibility analysis
   •  Technical
   •  Environmental
   •  Economic
ORC 6111.045(A)(4) - (same as above)
Write assessment report
ORC 6111.045(A) -... prepare and adopt a waste
minimization and treatment plan ...
ORC 6111.045(A)(5) - The identification of specific
objectives to prevent, reduce, or recycle releases of such
wastes when technically and economically feasible options
exist
ORC 6111.045(A)(6) - An explanation of the rationale for
the objectives identified under division (A)(5) of this
section
Implement the plan
   •  Select projects
   •  Obtain funding
   •  Install the selected projects
ORC 6111.045(A)(7) - A signed policy statement
articulating the commitment of upper management and the
corporation to implement the waste minimization and
treatment plan and its objectives

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 Measure progress
    • Acquire data
    • Analyze results
 Maintain the pollution prevention program
                                  ORC 6111.045(C) - Periodic review (every three years) of
                                  waste minimization and treatment plan
Notes:
   1.
The pollution prevention program elements follow the outline of U.S. EPA's Facility Pollution
Prevention Guide (EPA/600/R-92/088).
The waste minimization and treatment plan elements for Class I injection well facilities are listed
in the Ohio Revised Code, Section 6111.045.
                    Table D-2. Classes of treatment technologies and examples

                           (from Appendix to OAC 3745-65-73, Table 2)
 Thermal treatment
                     Physical treatment
                     Separation of components
Physical treatment
Removal of specific components
 Liquid injection incinerator
 Rotary kiln incinerator
 Fluidized bed incinerator
 Multiple hearth incinerator
 Infrared furnace incinerator
 Molten salt destructor
 Pyrolysis
 Wet air oxidation
 Calcination
 Microwave discharge
 Cement kiln
 Lime kiln
                     Centrifugation
                     Clarification
                     Coagulation
                     Decanting
                     Encapsulation
                     Filtration
                     Flocculation
                     Flotation
                     Foaming
                     Sedimentation
                     Thickening
                     Ultrafiltration
Absorption-molecular sieve
Activated carbon
Blending
Catalysis
Crystallization
Dialysis
Distillation
Electrodialysis
Electrolysis
Evaporation
High gradient magnetic separation
Leaching
Liquid ion exchange
Liquid-liquid extraction
Reverse osmosis
Solvent recovery
Stripping
Sand filter
 Chemical treatment
                     Biological treatment

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Absorption mound
Absorption field
Chemical fixation
Chemical oxidation
Chemical precipitation
Chemical reduction
Chlorination
Chlorinolysis
Cyanide destruction
Degradation
Detoxification
Ion exchange
Neutralization
Ozonation
Photolysis
Activated sludge
Aerobic lagoon
Aerobic tank
Anaerobic lagoon
Composting
Septic tank
Spray irrigation
Thickening filter
Trickling filter
Waste stabilization pond
{ Acronyms Table of Contents }

Office of Pollution Prevention
Ohio Environmental Protection Agency
P.O. Box 1049
Columbus, Ohio 43216-1049
Phone (614) 644-3469
Fax (614) 644-2807
E-mail: p2mail@epa.state.oh.us
Navigation Links:
Office of Pollution Prevention Home Page
Ohio EPA Home Page
page last updated: October 30, 2000

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     Ohio  Pollution Prevention and Waste

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                                 Chapter 12
                   Define Pollution Prevention Options

"The diversity of potential strategies for reducing wastes at the source parallels the diversity of pollution
sources and opportunities for prevention."

                                                   Christine Ervin, World Wildlife Fund


Propose Options

A productive way to generate ideas is to conduct an informal meeting in which team members are
encouraged to "brainstorm" and discuss options. The team members should also solicit ideas from other
personnel at all levels, not only in their department but from the entire facility. Many times these
personnel already have ideas for reducing waste but have never had the opportunity to express them. All
options should be written down  and given serious consideration.

Some of the options may be simple to identify and implement such as:
   • Ship/receive materials in bulk to eliminate drum disposal if large quantities are used
   • Reuse containers where possible
   • Order materials "just in time" to avoid expiration
   • Establish a central stockroom/inventory control system
   • Investigate solvent/cleaner alternatives or reducing the total number of different solvents used
   • Reuse solvents where possible
   • Segregate waste streams

Other options that may not be as easily identified but must definitely be considered involve source
reduction. Table 3 provides some examples. Generator checklists for identifying waste reduction
opportunities developed by the Minnesota Technical Assistance Program (MnTAP) can also be used to
help identify pollution prevention options (MnTAP, various dates).

                Table 3. Source Reduction Options
(Source Reduction

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 Substituting less toxic or less hazardous alternatives for raw materials
 Using raw materials that generate less waste
 Using raw materials that require less frequent cleaning of equipment
 Modifying products to eliminate the need for hazardous or toxic materials
 Making process modifications and/or operating conditions that improve efficiency
 Improving preventive maintenance and operating procedures
  (adapted from Pollution Prevention: A Guide to Program Implementation., Illinois Hazardous Waste
                             Research and Information Center, 1993)

Once these options have been applied to specific wastes/processes, further investigation or changes in
product composition may be required. For example, it may be necessary to implement new or existing
techniques/technologies or to identify raw material alternatives. At this point it may be helpful to contact
other facilities, vendors, trade associations, state and local environmental assistance agencies, and
publications for ideas. These groups may be aware of material alternatives or similar pollution prevention
technologies that have been successfully implemented. Further pollution prevention opportunities may be
identified through "upstream" suppliers and "downstream" consumers. These individuals should also be
allowed input into the company's program.

Another way to identify pollution prevention opportunities is through benchmarking. In the
benchmarking process, a company selects an area for improvement and identifies other companies who
have similar practices that they consider to be the best in class. They then compare their own practices to
those companies' processes to determine where differences exist. The company using benchmarking then
implements measures to make their practices more like those of "best in class." A nine step
benchmarking program developed by AT&T is described in detail in Benchmarking: Focus on World
Practices (AT&T Quality Steering Committee, 1992). Working together, AT&T and Intel applied the
benchmarking process to develop a pollution prevention program. Benchmarking teams from both
companies followed the nine-step process to compare their own pollution prevention programs to the best
in class programs of six other companies (Klafter, 1992).

Other waste management options may be considered after pollution prevention strategies have been
exhausted. These include, in order of U.S. EPA's priority, recycling on-site to other processes,
reclamation, recycling off-site or using material exchanges, on-site treatment (physical, chemical, or
biological process that renders a waste less toxic, produces a byproduct that is recyclable or reduces the
volume of the waste stream  for disposal), treatment off-site; and lastly, proper disposal. These alternative
waste management options are  discussed in more detail in Chapter 19. For additional sources of technical
assistance, refer to Appendix B.

Screen Options

A priority approach in selecting options may be developed. Ranking options on a high, moderate, or low
continuum helps to ensure that pollution prevention is not a "one-shot" approach. Moderate and low
priority options should still be considered since circumstances such as a change in raw materials,
regulations or technology could occur.

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                                    Chapter 9
                        Do a  Preliminary Assessment

"Pollution is nothing but the resources we are not harvesting. We allow them to disperse because we are
ignorant of their value."

                                                                    Buckminster Fuller


Understanding Processes and Wastes

To effectively implement a pollution prevention program, it is important to understand the various unit
processes and where in these processes waste is being produced. This chapter will explain how to
determine the various unit process steps in materials use and will present methods to determine where
wastes are being generated. An extensive amount of data gathering may be necessary in this step in order
to achieve a complete process characterization.

Two general approaches characterizing processes and waste generation can be used. One method begins
with gathering information on total multi-media (air, land, and water) waste releases at the end of each
process, and then backtracks to determine waste sources. Another method tracks materials from the point
at which they  enter the plant until they exit as wastes or products. Both methods provide a baseline for
understanding where and why wastes are generated and a basis to measure waste reduced after
implementation of pollution prevention projects. The steps involved in these characterizations include
gathering background information, defining a production unit, general process characterization,
understanding unit processes, and completing a materials balance.

Gathering Background Information

The first step toward understanding processes and waste generation is gathering background information
on the facility. This allows for the accurate determination of the type and quantity of raw materials used,
the type and quantity of wastes generated, the individual production mechanisms, and the
interrelationships between the unit processes. The pollution prevention team should divide up the
responsibilities for obtaining this information. A time frame should be established for assembling the
data and presenting it to the group. Table 1  provides suggestions on data that should be assembled and
where this information might be found.

In addition to these data, useful information can be obtained from line workers, maintenance staff,
process engineers, purchasing, inventory, shipping and receiving; and accounting personnel. These
employees can be interviewed to determine how the processes are run; what types of raw materials,

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cleaning agents, lubricants, etc. are used; what types of waste are generated and how they are handled;
what other types of records are kept; and what information is not recorded on a regular basis. When
gathering this information, begin to track wastes to determine if there are seasonal or shift variations in
wastes generated. Once this information is assembled, the general process can be characterized.

             Table 1. Possible Sources  of Background Information
 Waste Generated
 INFORMATION ON:
 Raw Materials Use
 Production Mechanisms
 Process Interrelationships
INFORMATION GATHERED FROM:
Purchasing records
Inventory records
MSDSs
Vendor information
Production logs
Packaging material discarded
Shipping and receiving logs
Annual report
Waste manifests
TRI data
Sewer records (POTWs)
Permits/applications
Flow diagrams
Annual report
Rejected product
Environmental reporting
Waste collection and storage
Production logs
Environmental violations
Laboratory analyses
Obsolete expired stock
Spill and leak reports
Operations manuals (SOPs)
Vendor information
Control diagrams
Quality control guidebook
Production logs
Flow diagrams
Product specifications
Product-to-raw material data
Flow diagrams
Quality control data
Production logs
Product specifications
Facility layout

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 Economic Information
Cost accounting reports
Operating costs for waste handling and disposal
Pollution control costs
Costs for products, utilities, raw materials, and labor
  (adapted from Pollution Prevention: A Guide to Program Implementation., Illinois Hazardous Waste
                             Research and Information Center, 1993)

Define Production Units

To compare the amounts of waste generated during different time periods, and subsequently measure
relative waste reductions, a production unit should be defined for each process - either the unit process or
the overall process depending on the nature of the facility. A production unit is simply a set quantity of
product that is characteristic of the process - tons of plastic, gallons of acid, number of copies, etc. Try to
choose a production unit that can be related to later waste generation.  Once the production unit is
defined, wastes generated can be quantified as waste per production unit. Since total production can vary,
comparing the total amounts of waste generated for different time periods will not reflect the reductions
achieved due to pollution prevention activities (i.e., waste will increase or decrease with production
changes). For example, a printing press may use 1000 copies for a production unit and might then define
wastes as "waste per 1000 copies." Alternatively, a company might consider the unit of product per unit
of raw material. This measure would be an indicator of yield and process efficiency.

By assembling background information,  process flow diagrams for both the general process  and
individual processes can be developed. These diagrams, along with the materials balance, help provide
an understanding of the processes and the wastes generated. The production unit can be used for waste
reduction comparisons throughout the pollution prevention program.

Characterize General Process

A typical process has raw material inputs, product outputs, and waste  generation. It can be represented by
a general process flow diagram. This diagram may not physically resemble the process but will show the
movement of raw material through the process as well as the generation of final product and waste. A
simple diagram (Figure 3) of a metal parts fabrication facility illustrates this.
Bulk   .
Metal
            Rnlshed
         -> Metal
            Parts
         ^Wastes
   Figure 3:  A Simple Flow Diagram
                       Figure 3: A Simple Flow Diagram
In addition to the raw material, final product, and waste flows, other inputs can be represented on the
general flow diagram such as lubrication fluids, cleaning agents, cooling water, etc. This will provide an
understanding of the overall process and the associated wastes. The general process can then be separated
into individual or unit processes.

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Understand Unit Processes

Most production operations can be subdivided into a series of unit processes. For example, the general
process of metal parts fabrication can be represented by at least seven individual processes.
   1. Receiving and storing bulk metal
   2. Cutting, bending, or shaping metal
   3. Cleaning metal
   4. Painting or coating metal
   5. Assembling parts
   6. Packaging
   7. Shipping of assembled parts

Each unit process has its own inputs and outputs. The product from one step becomes the input material
for the following step. The raw materials, products, and wastes for each unit process can be shown on a
more detailed flow diagram. This diagram should contain the type/composition and quantity of raw
materials, products, and wastes to all media. The diagram should also include other inputs (lubrication
fluids, tooling water, cleaning agents, etc.) along with the quantities used. The background information
obtained previously will be helpful to determine the types/compositions and quantities of these streams.
The subdivision of the general process  of metal parts fabrication is illustrated in Figure 4.
               K",:\ i:
Figure 4: Simplified general process flow design
The flow diagrams for the unit processes (and in some cases the general process) can be completed using
either of two approaches: 1) start with the wastes and products generated and then determine the sources
of the waste by going backwards through each of the unit processes, or 2) start with the raw materials and
track them through each of the unit processes until products and wastes are generated. For cases where
waste streams are not separated but rather are combined prior to handling, the second method may be the
preferred initial approach. The two methods may also be combined to complete the unit process flow
diagrams and thus a detailed overall process diagram.

Outputs

It is critical to determine the types/compositions and quantities of raw materials consumed, product yield,
and wastes generated as accurately as possible for each unit process. All wastes released to the
environment (gas, liquid, and solid) should be characterized. These wastes can include: emissions from
stacks; vent emissions from process areas; fugitive emissions from pipes, tanks, or vessels and leaking
equipment; spent wash waters/cleaning solvents; cooling water; over spray from painting operations;
cleaning rags; material scrap (e.g., metal, packaging, etc.); and other wastes. By subdividing the process
into individual components, these types of wastes become more evident. With this information, a

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materials balance can be performed for the unit processes and then for the overall facility.

Perform Materials Balance

A materials balance accounts for all inputs and outputs into a process; in other words, what goes in must
come out. A materials balance should be performed for each unit process and for the overall production
line. Although this typically is a very involved procedure, and while it is usually possible to identify
sources of waste without having completed a materials balance, there are long term benefits to having
done a materials balance. However, because a materials balance can be very involved, your facility may
want to consider this an optional step, especially if you operate a small business. You may want to
concentrate on developing process flow charts. Companies may also prefer to develop process flow
charts in the preliminary assessment and complete a materials balance later in the pollution prevention
program.

A materials balance can help determine if fugitive losses are occurring in the process (e.g., fugitive loss
from a solvent tank = difference between solvent in and solvent out). In a physical process, one in which
there is no chemical change of materials, the raw materials that are not converted to product generally
end up as waste. For example, a materials balance can be performed on the metal parts fabrication
process as shown in Figure 4. For a chemical process, the materials balance becomes more complicated
as raw material  inputs are converted to  products through one or more chemical reactions. Some unreacted
raw materials may also end up as waste along with reaction by-products.

For these processes, a standard materials balance may already be available as part of the daily production
log or cycle. Where possible, however, actual measurements of the amounts of materials used and
generated should be used to produce the materials balance. The reason for this is that manufacturing
processes can change over a period of time to a point where the actual materials balance would differ
from that derived from the standard operating procedures.

Once the materials balance has been performed, the actual amount of each waste generated by a process
and the source becomes apparent if not already known. These numbers are the baseline amounts of total
waste generated at the start of the pollution prevention assessment and can be used for comparison
throughout the implementation of the program.

                         Table 5. Materials Balance
 Key Elements of a Materials Balance
 Quantity of raw material brought on-site
 Quantity produced on-site including amounts produced as production by-product
 Quantity consumed on-site
 Quantity shipped off-site as, or in, product
 Total waste generation (before recycling and treatment) and waste characteristics
 Amount of raw material in beginning and ending inventory
 An indicator of production levels involving the chemical
 Release and transfer rate
  (adapted from Pollution Prevention: A Guide to Program Implementation., Illinois Hazardous Waste
                             Research and Information Center, 1993)

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Establish Priorities
Before conducting an assessment to identify what pollution prevention opportunities are present, wastes
and unit processes should be prioritized to determine which should be examined first. The flow diagrams
prepared in this chapter provide a good starting point for prioritization because they show all of the input
and output streams for each unit process. Both the pollution prevention team and top management should
be involved in this decision-making process since each will have their own ideas of what areas should be
addressed initially.
When establishing priorities for pollution prevention, all of the input and output streams should be
ranked - beginning with those which require immediate attention, followed by those which are less
urgent. Each company will have their own procedures for establishing priorities. Companies should
estimate the risks posed each stream and consider the risks in the ranking process. These factors should
be considered when ranking the streams:
   •  U.S. EPA's  17 target chemicals from  the 33/50 program (see Appendix B)
   •  Toxic Release Inventory (TRI) waste
   •  High purchase, disposal and other costs
   •  High potential cost savings
   •  Highly toxic
   •  Hazardous waste
   •  Particular regulatory concerns
   •  High use and/or release rate
   •  Potential for removing bottlenecks in production or waste treatment
   •  Potential liability due to endangerment of employees, environment or the pubic
   •  Potential for successful implementation
   •  High volume waste (may include tonnage)
   •  Carcinogens
   •  Hazardous Air Pollutants (HAPs)
   •  Chlorofluorocarbons (CFCs) and other ozone-depleting or future banned materials
   •  Local citizens' concerns
Once the streams are ranked, candidate input and output streams  (especially wastes) can be identified for
the initial pollution prevention assessment, keeping in mind the goals set at the beginning of the program.
As the assessment proceeds, these priorities may change.
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                                   Chapter 11
                          Do a  Detailed Assessment

"To investigate opportunities for pollution prevention within your company, you need to assess your
current operations."


This chapter provides guidelines for beginning pollution prevention assessments in the facility, starting
with the highest priority and/or targeted wastes. The pollution prevention team should name assessment
teams, review wastes and processes, and organize and document information before and after the
assessments.

When the candidate wastes are established, the assessment for identifying specific pollution prevention
opportunities can begin. This procedure involves first looking at the processes associated with the
candidate streams and then expanding the assessment to the entire facility so that all potential
opportunities are addressed. The pollution prevention team should discuss the potential wastes and the
staffing of the overall facility to determine who should conduct the initial process assessment. Typically
a team of two to three people is effective.

The assessment team should first become familiar with the targeted processes. The flow diagrams
developed in Chapter 9 provide an understanding of the process but may not explain why certain
materials are used and why wastes are generated. For this information, the team must go into the facility
and study the processes in detail. This study should be conducted while the process is in operation
(ideally during  all shifts) and, if possible, during a shut-down/clean-out/start-up period to identify what
materials are used and wastes are generated by this procedure. When studying the process, the team
should note any potential pollution prevention opportunities and should pay particular attention to the
following:
   • Observe  procedures of operation by line workers
   • Quantities and concentrations of materials (especially wastes)
   • Collection (including exact sources) and handling of waste (note if wastes are mixed)
   • Any record keeping - and obtain copies of these if not already done
   • Flow diagram - follow through actual process
   • Leaking  lines or poorly operating equipment
   • Any spill residue
   • Damaged containers
   • Physical  and chemical characteristics of the waste or release

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It may also be helpful to photograph the process to recall specific details later. Often, details can be better
captured visually than with words. However, this should be cleared with the appropriate personnel first.

The assessment team should talk with the line personnel, including operators, supervisors, and foremen,
as much as possible. In doing so, they should determine the required operating conditions, product
specifications, and equipment specifications for the process. They should discuss the points previously
listed as well as the daily routine the workers follow. Specifically, the team should try to identify when
waste is generated, not just by the regular process, but by upsets, off-spec products, spills, etc. The team
should also talk with the maintenance and housekeeping personnel who service the process to determine
when, why, and how the process is serviced. Is preventive maintenance being done or are maintenance
people always responding to breakdowns? It is important to talk with these individuals as they generally
have the best working knowledge of the processes. The team should also compare written operating
procedures for various unit operations to actual in-plant practices.

After examining the targeted processes, the assessment team  should set a schedule for looking at the
other processes in a similar manner. Assessment for non-targeted sources should be thorough, but it may
take more time to completely assess these. Implementing pollution prevention projects on targeted
processes  can begin before assessments are completed for every process. This will help build momentum
and corporate support for a sustained program.

The team should also conduct an overall survey of the facility. This survey consists of investigating
supplemental operations such as shipping/receiving, purchasing, inventory, vehicle maintenance, waste
handling/storage, laboratories, powerhouses/boilers, cooling towers, and maintenance. Again, the team
should discuss daily routine with the personnel in these departments and should note potential
opportunities for pollution prevention. Some specific topics to cover in these departments are listed in
Table 2.

Once the process assessments and plant survey are completed, the data obtained should be reviewed for
thoroughness by all of the pollution prevention team members. This review will also initiate the
brainstorming process for ideas to reduce waste at the source.
        Table 2. Topics to Cover in Assessing Support Departments
 Shipping/receiving
Packaging materials - what is done with waste?
How are materials shipped/received - drums, bulk?
Can containers be returned/recycled?
Are you required to return empty containers to vendor?
What happens to pallets?
 Purchasing
Who orders materials?
How far in advance are materials ordered?
Can materials be ordered as needed (just-in-time)?
Is the minimum amount ordered?

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Waste handling
and storage
 Inventory
Vehicle maintenance
 Laboratories
Powerhouse/boiler
 Cooling towers
 Maintenance
What is the shelf-life of all materials?
Is there an inventory control system?
Bar coding?
Is there a central stockroom (no individual orders)?
Do you operate by "just-in-time" philosophy?
Do you operate by "first in, first out" principle?
Are solvents used for parts cleaning?
Are solvents recycled and have solvent alternatives been tested?
Do you recycle batteries, used oil, or antifreeze?
How are used oil filters/carburetor cleaners handled?
Are waste streams segregated?
Do you know the sources of all waste?
Do you have a "waste inventory" control system?
How often is waste shipped off-site? Treated on-site?
How is waste handled once shipped off-site?
How are chemicals ordered? In what quantities?
What is the shelf life of all chemicals?
How are expired chemicals handled?
Are solvents recycled/reused (e.g., first rinse)?
How are gases stored?
How are laboratory wastes handled?
Are laboratory wastes segregated?
How is fly ash/slag handled?
How is tube clean-out material handled?
What type of fuel is used? Are alternatives used?
What type of boiler water treatment chemicals are used?
How is boiler blow-down handled?
What type of chemical additives are used?
How is bottom sediment handled?
What is your water source? Is water recycled?
What types of cleaners are used?
Are solvents used? Are they recycled/reused?
Have solvent/cleaner alternatives been tested?
How are waste oil/greases handled?
How are other wastes generated and handled?
  (adapted from Pollution Prevention: A Guide to Program Implementation., Illinois Hazardous Waste
                             Research and Information Center, 1993)

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                                   Chapter 13
                             Cost Considerations

"In order to receive funding, it is essential that pollution prevention projects successfully compete in the
company's capital funding sequence or before the bank's loan committee."
                                                American Institute for Pollution Prevention
Before pollution prevention projects are evaluated for economic feasibility, the full cost of waste
generation must be determined. This full cost is necessary to develop the economics of pollution
prevention techniques/technologies, including calculating the cost savings and payback periods. Methods
for true cost determination and economic analysis are presented in this chapter. A cost accounting system
for all wastes generated in the facility will also be described.

Determine Full Cost of Waste

The full cost of waste generation includes more than just treatment or disposal costs; it includes all the
costs incurred by producing and handling waste. All of the expenditures associated with the waste, both
direct and indirect, should be identified. These include, but are not limited to, the following: purchasing,
storage and inventory, and in-process use of materials; air and water emissions, solid waste collection,
waste storage, on-site treatment or recycling; waste disposal; waste transportation; lost raw materials;
labor costs; and capital depreciation. Often, wasted raw material costs are three fourths of the full cost of
generating waste. Waste disposal costs are typically less than half the total costs (Selman and Czarnecki,
1988). Many pollution prevention options will not appear to be justified if only half, or less, of the  likely
savings are considered. Some examples of waste associated costs to consider are presented in Table 4.

   TABLE 4. Costs to Consider Determining Full Costs of a Waste Stream
 RAW MATERIAL AND HAZARDOUS SUBSTANCE USE
 Purchasing
Taxes on hazardous and other products
Safety training
MSDS filing
Safety equipment
Extra insurance premiums
Labor

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Storage and Inventory
Special storage facilities
Safety equipment
Storage area inspection and monitoring
Storage container labeling
Safety training
Emergency response planning
Spill containment equipment
Lost product from spills, evaporation, etc.
Labor
SARA Title III (TRI) reporting
In-Process Use
Safety training
Safety equipment
Containment facilities and equipment
Clean-up supplies
Labor
Lost Raw Materials
Labor for handling
Equipment for clean-up
Reporting
WASTE GENERATION
Air and Water Emissions
Air emission permits and controls
TRI measurements/estimates
TRI reporting
TRI fees
Worker health monitoring
Sewer discharge fees
NPDES permits
Water quality monitoring
Sampling training
Pretreatment equipment
Pretreatment system operation
Solid Waste Collection
Safety training
Safety equipment
Collection supplies
Container labels
Container labeling
Recordkeeping
Truck maintenance (for in-house fleet)
Waste Storage
Storage permits
Special storage facilities
Spill containment equipment
Emergency response planning
Safety training
Storage area inspection and monitoring

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 On-Site Treatment or Recycling
 Disposal
Capital and operating costs
Depreciation
Utilities
Operator training
Safety equipment
Emergency response planning
Permits
Inspection and monitoring
Insurance
Sewer fees
Container manifesting
Disposal vendor fees
Preparation for transportation
Transportation
Insurance and liability
Disposal site monitoring
 (adapted from Pollution Prevention Planning, Washington State Department of Ecology, January, 1992)

Develop Economics

Once the full costs of the waste streams are determined, an economic analysis of each specific pollution
prevention project can be conducted. This analysis will provide management information on the costs
and benefits associated with the techniques/technologies so they can decide whether it is economically
feasible to proceed with implementation. Certain benefits, such as reduced long-term liability, reduced
worker exposure to toxic chemicals, and improved community relations, will be difficult to quantify.

There are essentially two steps in an economic analysis after the true costs of waste generation have been
determined:  calculate the initial cost of implementing the pollution prevention strategy, and determine
the annual cost savings and payback period (if applicable) for the project.  In some cases, the total capital
and operating costs (including the waste handling costs) for the existing process and the "new" process
must be considered if they are substantially different. For example, some pollution prevention options
involve increased use of utilities which must be taken into account.

The initial cost of the implemented technique/technology should include capital requirements for new
equipment, start-up costs, training costs for new equipment or procedures, and any costs for regulatory
compliance. The full cost for waste generation should also be calculated for the new option using the
procedure described previously in this chapter. The strategy in question may have only limited initial
costs associated with it, such as capital and start-up expenditures, since it may be as simple as a raw
material substitution or making a minor process modification. In these cases, the annual waste cost
savings may be the principle factor considered. However, there may be costs associated with
implementation of the pollution prevention project such as process down-time or upsets.

A good general reference for cost considerations in pollution prevention is the American Institute for
Pollution Prevention's 1993 document, A Primer for Financial Analysis of Pollution Prevention Projects.
An additional source to consult for in-depth coverage, worksheets, and resources on pollution prevention
is U.S. EPAs Facility Pollution Prevention Guide.

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Once the total initial cost for implementing the pollution prevention strategy is determined, the cost
savings should be determined. To calculate this, the following equation may be used:

Cost savings = (Existing full cost of waste) minus (Projected full costs of waste after implementation)

For options which do not involve capital investments or other initial expenditures, waste handling cost
savings may be the primary consideration for economic feasibility. For most pollution prevention
options, some projected costs will be reduced if the existing full costs for waste generation are identified.

For strategies that involve initial expenditures, such as capital investments and startup costs, each
company will have its own criteria of feasibility to consider. It will usually be necessary to calculate the
economics of a project by methods specifically determined and approved by the company.

A quick test for initial feasibility is the payback period. Additional methods of determining long-term
costs include net present value, internal rate of return, and profitability index. Further information on
applying these methods  can be found in U.S. EPAs Total Cost Assessment: Accelerating Industrial
Pollution Prevention through Innovative Project Financial Analysis (1992). The payback period is
defined as the amount of time (generally expressed in years) it takes to recover the initial investment
through annual cost savings. The following equation can be used as a simple calculation of the payback
period. Note that this equation does not account for depreciation, interest, etc. A very thorough and
in-depth examination of full cost accounting can be found in Appendix F of U.S. EPAs Facility
Pollution Prevention Guide.

Simplified Payback Period = (initial investment (capital + start-up + other costs)) divided by (annual
full waste handling cost savings)

In options where there is a substantial difference in the total operating costs of the existing process and
the  "new" process (e.g.,  use of utilities increases significantly), the total annual operating cost savings
(including waste handling cost savings) should be used in place of the annual true waste handling when
calculating the payback  period.

Establish a Cost Allocation System

A cost allocation system is an important element of a pollution prevention program. A cost allocation
system charges each department or process for the total waste management costs for the wastes they
generate. The charges should cover the full cost of the waste as explained previously in this chapter. This
cost allocation system should lower the total overhead cost because most companies charge waste
disposal costs to overhead (i.e., the environmental department). It will also provide incentives for
employees associated with the departments/processes that are charged for the waste handling to reduce
their waste generation and subsequently their costs.

By calculating the full cost of waste generation, the parameters for determining the economic feasibility
of pollution prevention strategies (annual cost savings and payback period) can be developed. These will
be used in the following chapter to evaluate the pollution prevention options and to decide which option
could be implemented first. Establishing a cost allocation system will provide employees, including
management, with a better awareness of the costs associated with waste generation in their
department/process.

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                                   Chapter 19
                     Other Waste Management Options
"Pollution prevention is not the only strategy for reducing risk but is the preferred one. Where prevention
or recycling are not feasible, treatment followed by safe disposal as a last resort will play an important
role in achieving environmental goals."
                                                    Carol Browner, U.S. EPA Administrator
As described in Chapters 4 and 5, it is national and Ohio EPA policy that pollution be prevented or
reduced at the source whenever feasible. Despite the tremendous progress some have made in preventing
wastes, it is often not economically or technically feasible to eliminate all wastes from industrial
processes. For any remaining wastes the preferred management options in order of preference are on-site
recycling or reuse, off-site recycling or reuse, treatment, and disposal in landfills. This is commonly
referred to as the waste management hierarchy. U.S. EPA and Ohio EPA have taken the position that the
hierarchy should be viewed as establishing a set of preferences, rather than an absolute judgment that
prevention is always the most feasible option.

For safety or economy-of-scale reasons in some specific situations recycling or treatment may be more
feasible than source reduction or in-process recycling. Environmentally sound recycling can have many
of the advantages of source reduction because it achieves reduction in the amount of wastes needing
treatment or disposal and conserves energy and other resources. However, on-site recycling and
treatment are generally preferred over off-site processing because releases often occur during transport
and handling and the chances for spills increase.

Some companies lack the skills to operate recycling or treatment equipment properly. The permitting
process required for an on-site waste treatment facility is both time consuming and expensive and may
require a public hearing. Other companies do not generate a large enough quantity of waste for  economic
operation of recycling equipment. In those cases, off-site recycling or treatment where wastes from
multiple facilities are combined can be an excellent waste management approach.

Other technologies that do not in themselves reduce the mass of contaminants produced also may be
beneficial. For example, more efficient use of water in plating by rinsing through use of counter-current
flow or spray rinse systems increases the cost effectiveness of in-process metal recovery and reuse. More
energy efficient lighting can bring substantial savings.

The emphasis in managing waste should be to continually try to move up the hierarchy toward source
reduction. Although a company may have an environmentally sound recycling program for certain

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wastes, the generation of these wastes may reflect inefficiencies in operation. Recycling is often much
more expensive than source reduction, especially when the cost of scrap and other excess materials are
completely determined. Obviously, if more of these wastes can be turned into product, the company will
decrease its costs and should increase profits.

In summary, source reduction techniques and in-process recycling which prevent and reduce waste
generation are preferred over recycling, treatment, and disposal options that deal with wastes after they
are produced. Once pollution prevention options have been fully considered, additional methods of
handling and controlling wastes should be evaluated according to the waste management hierarchy.
Often these approaches need to be used in combination to be most effective. Technical advancements in
production processes and waste management technologies make it desirable for each company to
routinely review and improve its pollution prevention and waste management practices.

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                                   Chapter 8
               Organize the Pollution Prevention  Program

"Plasticolors (Ashtabula) reduced waste,  lowered operating costs and used its saving to reward
employees. It's a good example of how pollution prevention pays off for everyone."

                                                          Governor George V.  Voinovich


This chapter outlines a method to incorporate a pollution prevention program into daily company
activities. The steps involved include: designating a pollution prevention coordinator, developing a
pollution prevention team, setting goals, increasing employee awareness and involvement, and rewarding
and training employees.

Name the Pollution Prevention Task Force

Designate a Pollution Prevention Coordinator

While a pollution prevention program needs top down support and commitment, it also needs bottom up
input and implementation. This means teamwork and participation from  all levels within the company
are essential. A key element for success is to find a good advocate and leader for the pollution prevention
program.

The pollution prevention coordinator will be responsible for establishing the pollution prevention
team(s), conducting meetings, and making sure the company is working  toward its pollution prevention
goals. The coordinator can come from any level in the company. He or she needs to be well organized, an
advocate for the program, a cheerleader, and a motivator of people. If the coordinator has top
management support and the confidence of supervisors and others on the team, he or she will likely
develop a very successful program.

The coordinator will act as the key liaison to top management. This helps to ensure that the best pollution
prevention ideas in terms of need, feasibility, and benefit to the company are delivered to top
management for consideration. Also, the coordinator will need to obtain  interdepartmental cooperation
and resources on a continuing basis.

Develop a Pollution Prevention Team

A pollution prevention team needs to be organized prior to beginning the assessment process. These
responsibilities should not be assigned to any one department. Some suggested key personnel to consider

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including are: representatives (both supervisors and line workers) from maintenance, production,
environmental, health and safety, purchasing, accounting, shipping and receiving, legal and engineering
departments, research and development, and plant and executive managers. Not every company will have
these designations, and other personnel may be more appropriate. The final composition of the team
should be based on what is most appropriate for your company. It is important to include those
individuals knowledgeable about the processes generating wastes and involve them from the beginning.

In addition to those individuals assigned duties on the pollution prevention team, others may wish to
help. Do not turn away volunteers - everyone should be encouraged to participate in the pollution
prevention program. All volunteers should be commended in some way (the in-house newsletter, etc.) for
their interest in helping the company, their co-workers, and the environment. One important point to
continually stress throughout the development and implementation of the pollution prevention program is
the need to work together. Employee suggestions should continually be encouraged - supervisors need to
listen carefully because innovative ideas can come from any employee. Pollution prevention must
continue for the life of the facility; establishing a sound, cooperative program from the start will be
beneficial  in future years.

The initial pollution prevention team meeting should be an informal session to discuss what pollution
prevention is, why the company should do it, and where and how to begin. General information about the
company's processes and operational procedures should be reviewed. The team will be responsible for
developing a formal pollution prevention plan as outlined in the next chapter. This is also a good time for
the company to emphasize top management support for the pollution prevention program and for the
team's planning process.

State Goals

There are different types of goals a company should set when beginning their pollution prevention
program. Some goals will be waste specific, while others will be activity oriented. The team should
discuss what types of goals are appropriate for the company. For example, a company may want to set an
ultimate goal of zero percent waste generation to acknowledge the fact that pollution prevention is a
continuing challenge. This is very similar to company goals like "zero product defects" or "zero lost
workdays". Another goal may be to replace some or all of the toxic substances used with non-toxic
substances and thus reduce risk to employees, the public, and the environment. Numerical goals for
waste reduction may be established once the wastes are characterized. Goals may consider economic and
technical feasibility.

In addition to specific goals targeted at source reduction, more general goals should also be set. These
could include improving worker health and safety in the facility or improving the  company image and
attractiveness to investors.  Activity goals could include incorporating pollution prevention into
performance evaluations of all management staff, installing a revised accounting system that charges the
cost back to the production line generating the waste, training all employees in pollution prevention, or
holding monthly team meetings.

Goals should be continually updated as they are achieved. This emphasizes the concept of continuous
quality improvement and is an important component of a pollution prevention program. Do not remain
static. Build on the successes achieved. Specific goals will vary over time and should be based on the
size of the facility and the type of production processes undergoing change.  It is a good idea to set a

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number of measurable goals to track progress within a given period.

Increase Employee Awareness and Involvement

One method of increasing pollution prevention knowledge is through a corporate/facility awareness
program. Supervisors should discuss the status of the pollution prevention program at weekly meetings.
They should encourage the employees to bring pollution prevention ideas to them so they can forward
them on for the facility pollution prevention team meetings, or encourage employees to submit ideas
directly to the team. Some companies may already have "quality circles" in place to improve product
quality and production efficiency. The team should work with these groups to develop ideas for pollution
prevention initiatives. The pollution prevention team should include the following aspects in developing
their awareness program:
   •  provide a definition and explanation of the primary components of pollution prevention
   •  state company policies and guidelines clearly
   •  identify company goals to reduce waste generation and to improve operations
   •  stress that pollution prevention is not only essential but also beneficial
   •  encourage employee participation as extremely important to improve facility and environmental
      conditions
   •  make management and pollution prevention team members available to employee suggestions and
      new ideas
   •  present facts on safety improvements that occur when a pollution prevention program is
      implemented
   •  stress the relationship between the cost of generating waste to company competitiveness
   •  equate savings from pollution prevention with the company's fiscal health (i.e., increasing job
      security to encourage employee involvement).

Train Employees

Specialized pollution prevention training programs tailored for management, line, and maintenance staff
should be incorporated into company procedures. Consolidated training for different groups can also
stimulate discussion between employees who would not interact otherwise. Additional personnel training
may be needed if materials handling or accounting changes are made. The facility or company may want
to include a pollution prevention orientation program for all new employees, regardless of their job
function. Employees will need thorough training on any new technologies or techniques added to unit
processes. Depending upon the size of the facility,  this may require training on more than one shift.

Another option is to have performance evaluation systems reflect pollution prevention responsibilities.
As pollution prevention strategies are identified, the training requirements must be considered by the
pollution prevention team prior to implementation.

Reward Pollution Prevention Successes

To stimulate additional interest and participation in pollution prevention, establish an employee incentive
award or recognition program for the facility or company.  Competition in larger plants may motivate

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participation. Shifts, departments, or even individuals can be encouraged to compete against their own
past year's performance. Recognition in the form of an awards ceremony, a bonus, a special parking
place, or added vacation time, provides a tangible reward to individuals and departments who have
achieved their pollution prevention goals. Further recognition may be promoted in a regular pollution
prevention column in the company newsletter which recognizes pollution prevention efforts and
successes. When a company newsletter is not available, a short one page fact sheet on pollution
prevention could be started that acknowledges employee participation and accomplishments.
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                                   Chapter 10
               Write the Pollution Prevention Program Plan

"Pollution prevention plans should be a practical business plan for attacking today's environmental
concerns through the reduction or elimination of waste at its source of generation."
                                         Dennis G. Willis, Capsule Environmental Engineering

After the pollution prevention team has been organized and the preliminary assessment has been
completed, the pollution prevention team should write the pollution prevention plan. This plan should
include all the ideas developed by the team such as the statement of support from management, the
pollution prevention team's structure, organizational guidelines, and statement of purpose; the methods
for fostering participation by all employees; the company's general goals; the structure of an
incentive/reward program; the procedures, criteria and schedule for implementing pollution prevention
projects; and the provisions for  employee training.
The formal written pollution prevention plan should include the following elements:
   • Corporate policy statement of support for pollution prevention
   • The company's general goals
   • Description of your pollution prevention planning team(s) makeup, authority, and responsibility
   • Description of how all of the groups (production, laboratory, maintenance, shipping, marketing,
     engineering, and others) will work together to reduce waste generation and energy consumption
   • Plan for publicizing and gaining company-wide support for the pollution prevention program
   • Plan for communicating the successes and failures of pollution prevention programs within your
     company
   • Description of the processes that produce, use, or release wastes, including clear definition of the
     amounts and types of substances, materials, and products under consideration
   • List of treatment, disposal, and recycling facilities and transporters currently used
   • Preliminary review of the cost of pollution control and waste disposal
   • Description of current and past pollution prevention activities at your facility
   • Evaluation of the effectiveness of past and ongoing pollution prevention activities
   • Criteria and schedule for prioritizing candidate facilities, processes, and wastes for pollution
     prevention projects
   • Provisions for employee training

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Define Objectives

During the preliminary assessment phase, the program team will have identified opportunities for
pollution prevention and will have worked with the executive group to establish priorities. These will be
the starting point for defining short- and long-range objectives.

Objectives are the specific tasks that will be necessary to achieve goals. For example, in order to reach a
goal of reducing waste, the objectives might be defined as reducing solvent, paper, and packaging wastes
by specific amounts over a stated period of time.

Objectives can be defined at the facility- or the department-level, depending on the size and diversity of
your company. A small company could decide to develop a single set of objectives to cover all of its
operations. A larger company with many facilities or products might develop an overall corporate plan
describing goals and objectives, supplemented by facility- or product-specific goals. In any case, the
management at each location must understand and support its objectives if the pollution prevention
program is to be successful.

Objectives should be stated in quantitative terms and should have target dates. These two attributes make
objectives effective tools for directing effort and measuring progress.

Identify Potential Obstacles

During the development of the pollution prevention program and plan, the team may have encountered a
number of factors that could complicate the process. These factors need to be recognized, and the means
for overcoming them need to be defined.  The team should list economic, technical, regulatory, and
institutional obstacles and define procedures for addressing them. Apparent obstacles will be less likely
to impede the process if everyone understands that there is a mechanism for addressing them in a later
stage.

Develop Schedule

The final aspect of planning your pollution prevention program is to  list the milestones within each of the
stages from detailed assessment through implementation and assign realistic target dates. The execution
of these stages (described in the following chapters) should follow this schedule closely. Significant
deviations may cause the program to falter because certain steps are not completed. Adherence to the
schedule will also help control the startup or implementation costs of the program.

The pollution prevention program plan should be presented and agreed to by management so that they
understand how the pollution prevention team will proceed and what resources/support will be required
from them. The plan should be modified on an annual basis as pollution prevention experience is gained
and goals are reached. A company should strive to continually improve the entire program.

Augment the Plan

After the facility has completed each of the later steps in the pollution prevention program, results and a
written summary of each step should be added to the pollution prevention plan. Writing summaries and
adding them to the pollution prevention plan will provide a record of all pollution prevention activities in

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the program. The compilation of reports will be a good reference for anyone who is interested in
reviewing your facility's entire pollution prevention program, including implementation, measuring
progress, and maintaining the program.

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Bulk
metal
  Metal
Fabrication
Finished
Metal
Parts

Wastes
   Figure 3: A Simple flow Diagram

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                       Metal Parts Fabrication
    packaging waste
                     metal scrap
                              cutting fluid
Bulk
Metal
Receiving
                                      spent
                                    wash fluid
                                        paint waste
         Metal     Fabrication
(cutting, grinding)
                                     Metal
                               Parts
ripnninn I  Clean  » I Finishing/
CleaninQ          '
       \ Metal Parts
                             cutting fluid
                                      clean
                                    wash fluid
                                               Finished
Metal
Parts
                                        paint
      Figure 4:  Simplified general process flow design

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                                   Chapter 14
                            Do Feasibility Analysis

"We have found that up to 65 percent of the waste generated by industrial plants can be prevented at
little or no cost to the plant. Most of the recommendations we make to companies have a pay-back period
of less than one year."

                                                   Charles A. Czarnecki, Waste Advantage


Once suggestions for pollution prevention options are gathered and the costs associated with these
options calculated, they should be reviewed by the pollution prevention team and the least beneficial
options eliminated from further consideration. These options may be reviewed again at a later time since
pollution prevention is a continuous process and what is less beneficial now may work better in the
future. The remaining options should then be examined in more detail to determine their overall benefits.
Technical, economic and environmental feasibility of each option, based on the company's requirements
for these criteria, should be studied. For example, each company has their own standards for economic
evaluation, feasibility for implementation, levels of expertise, operational requirements, etc. Those
options found to be consistent with the company's goals can then be scheduled for implementation. There
may even be cases in which certain benefits of a project override low economic return.

The benefits to be gained by implementing a pollution prevention project should be identified. Along
with reduced waste generation (and associated costs), these benefits may include improved worker
safety/morale, better community relations, reduced liability, reduced regulatory concerns, and improved
relations with regulatory agencies. These benefits may be difficult to quantify but should be emphasized
when evaluating options for implementation approval.

Technical Evaluation

There are many factors which should be considered when determining if a project is technically feasible.
Table 6 presents some of these factors.

         Table 6. Factors to Consider in  Determining Feasibility
(Process related                (Company related

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 Existing technology available
 Amount of downtime required
 Equipment/procedure compatibility
 Utility requirements/availability
 Specific training required
 Acceptable service from vendor
 Ease of implementation
 Quality assurance
Pollution prevention goals
Product quality maintained
Customer acceptance of product
Likelihood of success
Creation of other environmental concerns
Reduction of treatment/disposal costs
Payback period
Regulatory compliance costs
New markets for modified products
  (adapted from Pollution Prevention: A Guide to Program Implementation., Illinois Hazardous Waste
                              Research and Information Center, 1993)

Personnel that will be directly affected by implementing the project should be consulted and included in
the decision-making process. They typically have knowledge of process details that may inhibit the
project success and are essential in proper implementation. For projects that involve a new technology or
technique, a bench-scale or pilot test may be required to assess the technical feasibility. At this point, if it
is determined that an option is not feasible by these criteria, the option should be deferred for
consideration at a later time when the circumstances for evaluation may be different.  If possible,
illustrate effects of an option by modifying flow diagrams of existing processes to show how potential
options will improve plant processes.

Economic Evaluation

Once a pollution prevention project has been found to be technically feasible, the economics of the
project should be examined. In the previous chapter, the full cost of waste generation and the cost
savings for implementing a pollution prevention option were determined. In cases which involve capital
and start-up expenditures, the payback period or other economic criteria were calculated. This
information is necessary when evaluating the economic feasibility of a project.

Any project that yields a cost savings (annual waste handling or annual operating costs) has potential for
profitability. If there are no initial costs involved, then a project can be considered economically feasible
if there is a cost savings. Options such as better operating practices may be the most practical to
implement first since they do not require an initial capital investment.

For projects with capital and start-up costs, an additional profitability criterion must be examined:
payback period and other economic criteria (as calculated in Chapter 13). Typically, if the payback
period is less than two years, the project may be considered economically feasible. This criteria varies
depending on the company. There may also be other profitability measures that must be considered; this,
too, will depend on the company. Before making the final economic feasibility determination, the
accounting department controller should be consulted since his/her approval will usually be necessary
before the project may proceed. Give the accountant or controller copies of the pollution prevention cost
references mentioned in the previous chapter.

Environmental Evaluation
Factors to consider when conducting an environmental evaluation include:

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   •  effect on number and toxicity of wastes
   •  transfer of pollutants to other media
   •  environmental impact of alternative input materials
   •  energy consumption.

The team should review information on the environmental aspects of the relevant product, raw material,
or constituent part of the process. The team should consider the environmental effects not only of the
production phase and product life cycle but also of extracting and transporting the alternative raw
materials and of managing any new wastes.

Companies should start working with the appropriate regulatory agencies as early in the evaluation
process as possible.  Some pollution prevention projects will require new permits or changes to existing
permits. It will also be necessary to learn what regulations might apply to the project. Appendix B and
Appendix G of this manual provide contacts for assistance in the environmental evaluation of pollution
prevention options.

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                                  Chapter 15
                        Write the Assessment Report
"An assessment report will help you focus subsequent pollution prevention efforts and will be useful as a
record of what aspects of your business you examined for pollution prevention opportunities."

The task force should write a report that summarizes the results of the pollution prevention assessment at
the company level. Table 7 lists the report contents. The report will provide a schedule for implementing
prevention projects and will be the basis for evaluating and maintaining the pollution prevention
program. It may also be needed to secure internal funding for projects that require capital investment, if
the members of the pollution prevention assessment task force do not have the authority to commit funds.
You may be tempted to omit this step if your company has an owner-manager and only a few employees.
A summary assessment report may not be needed to resolve pollution prevention project conflicts among
different areas, and your funding approvals probably are not a formal procedure requiring cost
justifications. However, an assessment report will help you focus subsequent pollution prevention efforts
and will be useful as a record of what aspects of your business you examined for pollution prevention
opportunities.
                 Table 7. Elements to Include in an Assessment Report
 For each process that is assessed, the report should include:
    •  The results of the assessment
    •  The options proposed
    •  The results of options screening
    •  The results of feasibility analysis
    •  The project proposal for each selected option
 For each project proposal, the report should include:
    •  The project's pollution prevention potential
    •  The maturity of the technology and a discussion of successful applications
    •  The overall project economics
    •  The required resources and how they will be obtained
    •  The estimated time for installation and startup
    •  Possible performance measures to allow the project to be evaluated after it is implemented

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Input of the Assessment Teams

In a company that has several assessment teams, the task force will need to evaluate the results and
resolve any conflicts that might exist among the teams about the approach and the resources required for
the projects they propose.

As input to this integration effort, each assessment team should prepare a summary report, presenting the
results of their investigations and listing the options they screened. Each report should describe in some
detail the options that the team has determined are feasible and propose a schedule for implementing
them. The options recommended for immediate implementation should then be described in detail as
proposed projects.

These proposals should evaluate each project under different scenarios. For example, the profitability of
projects could be estimated under both optimistic and pessimistic assumptions. Where appropriate,
sensitivity analyses indicating the effect of key variables on  profitability should be included. Each
proposed project should outline a plan for adjusting and fine-tuning the initial projects as knowledge and
experience increases. The proposals should include a schedule for addressing those areas and wastes with
lower priorities than the ones selected for the initial effort.

Preparing and Reviewing the Assessment Report

The task force will use the assessment teams' reports and project proposals to prepare the summary
assessment report and implementation plan. The report should include a qualitative evaluation of the
indirect and intangible costs and benefits to your company and employees of a pollution prevention plan.
It will provide the basis for obtaining funding of pollution prevention projects. Pollution prevention
projects should not be sold on their technical merits alone; a clear description of both tangible and
intangible benefits can help a proposed project obtain funding.

Before the report is issued in final form, managers and other experienced people in the production units
that will be affected by the proposed projects should be asked to review the report. Their review will help
to ensure that the projects proposed are well-defined and feasible from their perspectives. While they
probably were involved in the site reviews and other early efforts of the task force, they may spot
inaccuracies or misunderstandings on the part of the assessment teams that were not apparent before. In
addition to ensuring the quality of the assessment report and implementation plan, this review will help
ensure the support of the people who will be responsible for the success of the project.

The final assessment report should be included as a part of the original pollution prevention program plan
(see "Augmenting the Plan" in Chapter 10). As stated above, the report will provide a schedule for
implementing prevention projects and will be the basis for evaluating and maintaining the pollution
prevention program.

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                                   Chapter 16
                  Implement the Pollution Prevention  Plan

"You can state corporate positions, write detailed mission statements, outline ambitious goals and
prepare detailed plans, but the way you reduce waste is by installing projects that reduce waste."

                                                             Ken Nelson, Dow Chemical


Select projects

Once the pollution prevention team selects the projects to be implemented, management approval must
be obtained. If management support was obtained as described in Chapter 7, the approval process should
not be difficult (providing the project benefits, profitability, and feasibility are acceptable). The pollution
prevention coordinator (or whoever will be in charge of the project) should present to management the
details of the project along with the budget and project justification (particularly economics). Individual
companies will have their own procedures to be followed for project endorsement.

Obtain funding

When approval has been obtained, the necessary funding for the project should be acquired. Again, this
procedure will vary with the company. It may be worthwhile to contact the Ohio Department of
Development, the Federal Small Business Administration, and other governmental offices. These
organizations may provide loans or grants for pollution prevention projects. A joint project of U.S. DOE
and U.S. EPA, the National Industrial Competitiveness Through Efficiency: Energy, Environment, and
Economics (NICE3) provides one-time grant funds for research and demonstration projects (see
Appendix B).

Install the selected projects

When funding is in place, project implementation can begin. The phases of implementation will be the
same as for most other projects in the company. Personnel that will be directly affected by the project
(line workers, engineers) should be involved from the start. Those personnel indirectly affected (e.g.,
controllers, purchasing agents) should also be involved as project implementation proceeds. Any
additional training requirements should be identified and arrangements made for instruction. All
employees should be periodically informed of the project status and should be educated as to the benefits
of the project to them and to the company. Encourage employees to comment on the plan and to suggest
additional reduction options. This may ease the natural resistance to change.

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                               Appendix G
                     Ohio EPA Information Sources

Please see Divisions and Offices of the Ohio EPA for updated information.
Central Office (CO)
1800 Watermark Dr.
P.O. Box 1049
Columbus, Ohio 43216-1049
(614)644-3020
Central District Office (CDO)
P.O. Box 1049
3232 Alum Creek Drive
Columbus, Ohio 43216-1049
(614)728-3778
(800) 686-2330
                           Southwest District Office (SWDO)
                           401 East Fifth Street
                           Dayton, Ohio 45402-2911
                           (513)285-6357
                           (800) 686-8930
                           Northeast District Office (NEDO)
                           2110 East Aurora Road
                           Twinsburg, Ohio 44087
                           (216)963-1200
                           (216)425-9171
                           (800) 686-6330
Northwest District Office (NWDO) Southeast District Office (SEDO)
                           2195 Front Street
                           Logan, Ohio 43138
                           (614)385-8501
                           (800) 686-7330
347 North Dunbridge Road
P.O. Box 466
Bowling Green, Ohio 43402
(419)352-8461
(800) 686-6930
Executive Offices
Division of Air Pollution Control
Division of Drinking and Ground Water
Division of Emergency and Remedial Response
Environmental Education Fund
                                      (614) 644-2270
                                      (614) 644-2905 and 644-2752
                                      (614) 644-2924
                                      (614) 644-2873
Division of Environmental and Financial Assistance (614) 644-2798
Division of Environmental Services
Division of Hazardous Waste Management
Legal Office
Office of Pollution Prevention
Public Interest Center
Division of Solid and Infectious Waste
Division of Surface Water
                                      (614)294-5841
                                      (614) 644-2917
                                      (614)644-2115
                                      (614) 644-3469
                                      (614)644-2160
                                      (614) 644-2621
                                      (614) 644-2001 and 644-2856

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                                   Chapter 18
                Maintain the Pollution Prevention Program

"The most successful companies are those that maintain an ongoing series of challenges - setting tough,
long-term goals, and revising them up if they seem too easy."

                                                            JoelMakower, "the e factor"


Now that a pollution prevention program is underway, it must be sustained in future years. This involves
reaffirming commitment to the program at all levels including upper management. Employee enthusiasm
and interest must be maintained to ensure continuation of the program. Ideally, the entire cycle should be
repeated following the successful implementation of each pollution prevention project. Some specific
ideas for sustaining the program include bringing new personnel into the pollution prevention team,
training, and publicizing success stories.

Rotate Pollution Prevention Team

To maintain the flow of fresh ideas, the pollution prevention team members should be rotated to
introduce new perspectives. With an ongoing pollution prevention program, there may be new employees
who join the company over the years that want to participate. A new team leader may step in with high
energy, enthusiasm and creativity. If some members do step down, they can serve as consultants to the
new team. There may also be dedicated team members who wish to remain on the team; this should be
encouraged as they have gained valuable experience. The composition of the team should still include
employees from all levels and departments. The importance of a written pollution prevention plan is that
it will outline the operating procedures for the program and provide continuity even when team members
are replaced.

Refresher Training

Pollution prevention awareness and training should be conducted on a periodic basis so that all new or
reassigned employees understand the company's commitment to pollution prevention. Pollution
prevention training should be incorporated into a number of the companies existing training programs
(health and safety, environmental, processes, etc.). This training should be an ongoing process.

Publicize Success Stories

Publicity is one of the most effective means to sustain the pollution prevention program. Internal
publicity raises the awareness of employees of activities going on at the facility and encourages further

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participation. The results of the various projects should be relayed through bulletin boards, newsletters,
interoffice memos, etc. The names of the pollution prevention team members, as well as those employees
offering suggestions, should be included in these publications. If individual successes are recognized,
other employees may wish to join in to receive the same recognition. Presentation ceremonies for
employee/team incentive awards will also help publicize successes. Cost savings, waste reductions, and
product quality improvements due to pollution prevention activities/projects should be highlighted.

The pollution prevention program can be a key public relations tool. Any reduction in waste is a benefit
to employees, the community and the environment and should be publicized. News releases should be
prepared for local and state media documenting the project and the benefits gained by the company and
the surrounding community. Reporters could also be invited to the facility for a demonstration of a new
technology.

Further public recognition can be facilitated through national, state, county, and local award programs.
The Ohio EPA solicits nominations for the Governor's Awards for Outstanding Achievement in Pollution
Prevention each year. These awards are presented to individuals; environmental, community, educational
and non-profit organizations; business, industry, agricultural, trade, or professional organizations; and
local governments that demonstrate significant achievements in  pollution prevention.

Trade association meetings and publications are another good avenue for promoting a company's
pollution prevention program. Case studies can be submitted which demonstrate the company's
progressive stance in environmental protection while describing the use of innovative technologies and
techniques to reduce waste. These case studies should emphasize the benefits gained by the company -
not only waste reduction but also cost savings, quality improvements, safety improvements, regulatory
compliance, and better community relations. Applying for state or national pollution prevention awards
can also be a means to publicize the company's efforts.
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                                  Chapter 17
           Measure Progress: Program and Project Evaluation
"Pollution prevention performance must be measured if it is to be improved, and it must be improved if it
is to be praised."
                                                                     Joel Hirschhorn
Once a pollution prevention program is established it should be continuously evaluated and updated. This
periodic review by the pollution prevention team should be conducted for all stages of the program, from
management support and team selection to project implementation. Once the elements have been
examined, the program can be modified and goals redefined to improve overall effectiveness.

Program Evaluation

The progress of the pollution prevention program can be determined by looking at the individual
activities and projects. One way of measuring progress is quantitative. For example, look at actual waste
reduction, both in terms of actual change in quantity and change in hazard level. The actual change in
quantity is the difference between the waste per production unit reported in the current year and the
waste per production unit reported in the previous year. The change in hazard level is based on toxicity,
reactivity, ignitability, and corrosivity of the waste and industrial hygiene/employee exposure-type
measurements. This comparison measurement is most useful when evaluating an alternative material
substitution such as switching from an organic solvent to a water based solvent. These measures of waste
reduction may not be appropriate for all facilities and wastes. Other quantitative measurements are
adjusted quantity change and throughput ratio. Additional guidelines and detailed descriptions on
measuring waste reduction can be found in Chapter 4 of U.S. EPAs Facility Pollution Prevention Guide.

Progress  can also be measured qualitatively through employee involvement, attitude and number of ideas
suggested. Some examples of qualitative evaluation criteria are presented in Table 8.

                  Table 8. Program Evaluation Criteria
       Project Element
     Management support
          Evaluation Criteria
Statements of support
Approval of projects
Providing ideas/input
Praise and publicity of successes

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 Team aspects/program initiation
     Understanding process
     Project implementation
     Continuing the program
Employee enthusiasm and participation
Using skills from training
Supporting projects
Providing ideas
Processes characterized
Flow diagrams developed
All wastes and sources identified
Waste accounting system implemented
Projects completed within budget
Projects completed on schedule
Waste reduction achieved
Cost savings attained
Raw material savings achieved
Product quality improved
Worker safety improved
Cost allocation system implemented
Follow-up and review procedures established
Employees kept informed and involved
Pollution prevention team composition rotated
  (adapted from Pollution Prevention: A Guide to Program Implementation., Illinois Hazardous Waste
                             Research and Information Center, 1993)

When evaluating the elements of the program, it is important to identify those strategies and techniques
which have been very successful, marginally successful, or have failed. If possible, the reasons why these
projects were or were not successful should be determined. This information will be beneficial for
modifying the program and redefining goals.

Program Modification

To ensure continuing progress and success of the pollution prevention program, the individual
components and the overall plan should be modified using the knowledge gained from experience.
Successful strategies and techniques can be used again or adapted to other areas where progress has been
slow or impeded. The initial pollution prevention goals should be redefined and/or expanded, reaching
for the ultimate goal of zero waste generation.

This is also an appropriate time to check to see if results and a written summary of the implementation of
each step of the program have been added to the pollution prevention plan. As discussed in Chapter 10,
writing summaries and adding them to the pollutionprevention plan will provide a record of all pollution
prevention activities in the program. The compilation of reports will be a good reference for anyone who
is interested in reviewing your facility's pollution prevention program.

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     Ohio Pollution  Prevention and  Waste
  Minimization  Planning  Guidance Manual
{ Acronyms  Table of Contents }

                                  Appendix A
                                   References
American Institute for Pollution Prevention. 1993. A Primer for Financial Analysis of Pollution
Prevention Projects. EPA/600/R-93/059. U.S. EPA, Risk Reduction Engineering Laboratory, Cincinnati,
Ohio.

AT&T Bell Laboratories. 1992. Benchmarking: Focus on World Class Practices. AT&T Bell
Laboratories, Indianapolis, Indiana.

Hazardous Waste Research and Information Center. 1993. Pollution Prevention: A Guide to Program
Implementation. Hazardous Waste Research and Information Center, Champaign, Illinois.

Klafter, B. 1992. Pollution Prevention Benchmarking: AT&T and Intel Work Together with the Best.
Total Quality Environmental Management, Vol. 2, No. 1, p. 27-34.

Minnesota Office of Waste Management. 1991. Minnesota Guide to Pollution Prevention. Minnesota
Office of Waste Management, St. Paul, Minnesota.

Minnesota Technical Assistance Program. Various dates. Generator checklists for identifying waste
reduction opportunities (including cleaning; coating/painting; formulating; machining; operating
procedures; plating/metal finishing). Minnesota Technical Assistance Program, Minneapolis, Minnesota.

Selman, Belle F. and Charles A. Czarnecki. 1988.  Industrial Waste Prevention: Guide to Developing an
Effective Waste Minimization Program. Waste Advantage, Southfield, Michigan.

U.S. EPA. 1993. 1993 Reference Guide to Pollution Prevention Resources. EPA/742/B-93-001. U.S.
EPA, Office of Pollution Prevention and Toxics, Washington, D.C.

U.S. EPA. 1993. Interim Final Guidance: Guidance to Hazardous Waste Generators on the Elements of a
Waste Minimization Program. Federal Register, Vol. 58, No. 102. May 28, 1993.

U.S. EPA. 1992. Facility Pollution Prevention Guide. EPA/600/R-92/088. U.S. EPA, Risk Reduction
Engineering Laboratory, Cincinnati, Ohio.

U.S. EPA. 1992. Total Cost Assessment: Accelerating Industrial Pollution Prevention through Innovative
Project Financial Analysis. EPA/741/R-92/002. U.S. EPA, Office of Pollution Prevention and Toxics,
Washington, D.C.

Washington State Department of Ecology. 1992. Pollution Prevention Planning - Guidance Manual for

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Chapter 173-307 WAC. Publication #91-2. Washington State Department of Ecology, Waste Reduction
Recycling and Litter Control Program, Olympia, Washington.

WRITAR. 1991. Survey and Summaries: State Legislation Relating to Pollution Prevention. Waste
Reduction Institute for Training and Applications Research, Inc., Minneapolis, Minnesota.

{ Acronyms Table of Contents }

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    Ohio Pollution Prevention and Waste
 Minimization Planning  Guidance Manual
{ Acronyms  Table of Contents }
                               Appendix E
              Examples of Pollution Prevention Activities
             Table E-1. Pollution Prevention Through Good Operating Practices

             (adapted from Facility Pollution Prevention Guide, U.S. EPA, 1992)
Good Operating Practice
Program Ingredients
Waste segregation
Prevent mixing of hazardous wastes with nonhazardous wastes
Store materials in compatible groups
Segregate different solvents
Isolate liquid wastes from solid wastes
Preventive Maintenance Programs
Maintain equipment history cards on equipment location,
characteristics, and maintenance
Maintain a master preventive maintenance (PM) schedule
Keep vendor maintenance manuals handy
Maintain a manual or computerized repair history file
Training/Awareness-Building Programs
Provide training for:
   • Operation of the equipment to minimize energy use and
     material waste
   • Proper materials handling to reduce waste and spills
   • Emphasize importance of pollution prevention by
     explaining the economic and environmental
     ramifications of hazardous waste generation and
     disposal
   • Detecting and minimizing material loss to air, land, or
     water
   • Emergency procedures to minimize lost materials during
     accidents

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Effective Supervision
Closer supervision may improve production efficiency and
reduce inadvertent waste generation
Centralize waste management. Appoint a safety/waste
management officer for each department. Educate staff on the
benefits of pollution prevention. Establish pollution prevention
goals. Perform pollution prevention assessments.
Employee Participation
"Quality circles" (free forums between employees and
supervisors) can identify ways to reduce waste
Solicit and reward employee suggestions for waste reduction
ideas
Production Scheduling/Planning
Maximize batch size to reduce clean out waste
Dedicate equipment to a single product
Alter batch sequencing to minimize cleaning frequency
(light-to-dark batch sequence, for example)
 Cost Accounting/Allocation
Charge direct and indirect costs of all air, land, and water
discharges to specific processes or products
Allocate waste treatment and disposal costs to the operations
that generate the waste
Allocate utility costs to specific processes or products
 Acronyms Table of Contents }
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   Ohio Pollution Prevention and Waste

 Minimization Planning  Guidance Manual

                      Appendix F
    Pollution Prevention Information Available from Ohio EPA
Please see Order Forms for updated version.
{ Acronyms Table of Contents }


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    Ohio  Pollution  Prevention  and Waste
 Minimization  Planning Guidance Manual
{ Acronyms  Table of Contents }

                               Appendix H
              Trade Secrets and Confidentiality Requests
This appendix provides information about trade secrets and confidentiality requests for pollution
prevention and waste minimization plans. Specific provisions for permitted hazardous waste facilities,
Class I injection well facilities, air pollution control, and water pollution control are listed for reference.
Other related information about trade secrets and confidentiality requests include: Toxic Chemical
Release Reporting, Ohio Administrative Code Rule 3745-100-13, Trade Secret Claims; and
Miscellaneous Rules, Ohio Administrative Code Rule 3745-49-031, Inspection of Public Records.

Facilities should contact the appropriate Ohio EPA program before submitting trade secret or
confidential information to confirm the most current procedures for requesting confidentiality.

General Provisions for Trade Secrets

The general provision for trade secrets for the State of Ohio can be found in the Ohio Revised Code
Section 1333.51, Theft or conversion of trade secret.

Ohio Revised Code Section 1333.51 Theft or conversion of trade secret
(A) As used  in  this section:
      (1)  "Article"  means any object, material,  device, or
      substance,  or  copy thereof, including any writing, record,
      recording,  drawing, sample, specimen,  prototype, model,
      photograph,  blueprint, or map.
      (2)  "Representing" means describing,  depicting, containing,
      constituting,  reflecting, or recording.
      (3)  "Trade secret" means the whole  or any portion or phase  of
      any  scientific or technical information,  design, process,
      procedure,  formula, or improvement,  or any business plans,
      financial  information, or listing of names,  addresses, or
      telephone  numbers, which has not been published or
      disseminated,  or otherwise become a matter of general public
      knowledge.   Such scientific or technical  information, design,
      process, procedure, formula, or improvement,  or any business
      plans,  financial information, or listing  of names, addresses,

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     or  telephone numbers,  is presumed to be  secret when the  owner
     thereof takes measures designed to prevent  it, in the  ordinary
     course of business,  from being available  to persons other than
     those selected  by the owner  to have access  thereto for limited
     purposes.
      (4)  "Copy" means  any facsimile,  replica,  photograph, or
     reproduction of an article,  or any note,  drawing, or sketch
     made of or from an article.

 (B) No person shall, with intent  to deprive or withhold from  the
owner thereof the control of a trade secret,  or  with intent to
convert  a trade secret to his own use or the  use of another,  obtain
possession of or access to an article representing a trade  secret.

 (C) No person,  having  obtained possessions of  an article
representing a trade secret or access thereto  with the owner's
consent,  shall convert such article to his own use or that  of
another  person, or thereafter without the owner's consent make or
cause to be made a copy of such article, or exhibit such article to
another.

 (D) No person shall, by force, violence, threat,  bribe, reward,  or
offer of anything of value on or  to another person or member  of his
family,  obtain or attempt to obtain from such  other person  an
article  representing a trade secret.

 (E) No person shall, without authorization, enter upon the  premises
of another with intent to obtain  possession of or access to an
article  representing a trade secret.

Permitted Hazardous Waste Facilities

The Ohio Revised Code Section 3734.12(G) instructs the Director of Ohio EPA to establish procedures
to ensure protection of trade secrets. Trade secrets are defined in the Section and this definition is the
same as the definition in Ohio Administrative Code Rule 3745-50-30 (see below). Ohio Hazardous
Waste Facility Installation and Operation Permits contain a standard condition for confidential
information. The Ohio hazardous waste rules also include a rule, Ohio Administrative Code Rule
3745-50-30, for trade secrets and request for confidentiality. The condition and the rule are listed below.

Ohio Hazardous Waste Facility Installation and Operation Permit Condition
Confidential Information

Ohio Administrative Code Rule  3745-50-30
In accordance with Ohio Revised Code Chapter  3734 and the rules
adopted  thereunder,  the Permittee may request  confidentiality of
any information required to be submitted by the  terms and

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conditions of this permit.

Ohio Administrative Code Rule 3745-50-30 Trade secrets - request for confidentiality.
(A) Any record, report or other information obtained under  the
hazardous waste rules or Chapter 3734. of the Revised  Code  shall
not be available to the public upon a showing satisfactory  to the
Ohio EPA that all or part of such record, report or other
information  (other than discharge or emission data) would divulge
methods or processes entitled to protection as trade secrets of
such person, in which instance, the Ohio EPA shall consider such
record, report or other information or part thereof confidential
and administer such record, report or other information pursuant to
this rule.

(B) A request for confidentiality shall be submitted to the Ohio
EPA simultaneously with submissions of the specific record, report
or other information, and such request shall be accompanied by
sufficient supporting documentation.  Failure to make  such  timely
request shall constitute a waiver of the right to prevent public
disclosure.

(C) A decision as to the confidentiality request shall be made by
the Ohio EPA within forty-five days of receipt of a request filed
in accordance with rule 3745-49-031 of the Administrative Code.
Until such decision is made, the record, report, or other
information or part thereof, shall be confidential.  The person
requesting confidentiality shall be notified by mail of the
decision.

(D) Any record, report or other information determined to be
confidential may be disclosed, without such person's consent:
     (1)  To officers, employees, or authorized representatives of
     the state or a federal agency;
     (2)  In any judicial proceeding; and
     (3)  In any hearing conducted by Ohio EPA or the board.

(E) As used in this rule, "trade secrets" may include but are not
limited to,  any formula, plan, pattern, process, tool, mechanism,
compound, procedure, production data or compilation of information
which is not patented, which is known only to certain  individuals
within a commercial concern who are using it to fabricate,  produce,
or compound an article, trade or service having commercial  value,
and which gives its user an opportunity to obtain a business
advantage over competitors who do not know or use it.

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Class I Injection Well Facilities

The Ohio Revised Code Section 6111.045(B), discusses trade secret information in waste minimization
and treatment plans and references Ohio Revised Code, Section 1333.51, Theft or conversion of trade
secrets. The Ohio underground injection control program rules also include a rule, Ohio Administrative
Code Rule 3745-34-03, for confidentiality of information. The section and the rule are listed below.

Ohio Revised Code Section 6111.045(6)

Each waste  minimization and treatment plan prepared and adopted
under division  (A)  of this section shall be retained  at the
facility  to which it applies and  shall  be made available  for
inspection  and review by the director of environmental  protection
or his authorized representative.   The  disclosure of  any  trade
secret information contained in any such plan is subject  to section
1333.51 of  the Revised Code.

Ohio Administrative Code Rule 3745-34-03 Confidentiality of information
(A) Any record,  report or other  information obtained by  the Ohio
environmental  protection agency  shall be made available  to the
public, except that upon a showing  satisfactory to the director by
any person  that  such record, report or other information,  or
particular  part  thereof  (other than data concerning the  amounts of
contents of discharges or the quality of the receiving waters),  if
made public, would divulge methods  or processes entitled to
protection  as  trade secrets of such person, the Ohio environmental
protection  agency shall consider such record, report or  other
information, or  particular part  thereof confidential.  Any
confidential record, report, or  information may be disclosed to
other officers,  employees, or authorized representatives of the
state, another state,  or of the  United States, concerned with
carrying out this act or when relevant in any proceeding under
these regulations.  Prior to divulging any  confidential trade
secret information, the director shall give ten days' written
notice to the  person claiming trade secrecy.

(B) A request  for confidentiality shall be submitted to  the Ohio
environmental  protection agency  simultaneously with submission of
the specific record, report or other information, and such request
shall be accompanied by sufficient  supporting documentation.
Failure to  make  such timely request shall constitute a waiver of
the right to prevent public disclosure.

(C) A decision as to the confidentiality request shall be made by

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the Ohio environmental protection agency within forty-five days of
receipt of the request and  accompanying documentation.  Until such
decision is made, the record,  report,  or other information or part
thereof, shall be confidential.   The person requesting
confidentiality  shall be notified by mail of the decision.

Air Pollution Control

Ohio Revised Code Section 3704.08 Records to be available for public inspection; exception.


(A)  Any records, reports, or  information obtained under Chapter
3704. of the Revised Code shall  be available for public inspection,
except that upon a showing  satisfactory to the director of
environmental protection by any  person that such records,  reports
or other information, or particular part thereof,  other than
emission data, to which the director has access under such chapter,
if made public,  would divulge methods or processes entitled to
protection as trade secrets of such person, the director shall
consider such record, report  or  other information, or particular
part thereof confidential,  except that such record,  report, or
information may  be disclosed  when necessary to sustain an action
brought pursuant to section 3704.06 of the Revised Code ordering an
adjudication hearing conducted by the director on the denial,
modification, or revocation of a variance or permit.

Water Pollution Control

Ohio Revised Code Section 6111.05 Investigation of alleged acts of pollution; right of entry.
...  Any records, reports,  or  information obtained under Chapter
6111. of the Revised Code  shall  be  available for public inspection,
except that:

(A)  Upon a  showing  satisfactory  to  the director of environmental
protection  by any person that  such  records,  reports or information,
or any particular part  thereof,  other than data concerning the
amounts or  contents of  discharges or the quality of the receiving
waters, to  which the director  has access under this chapter, if
made public would divulge  information entitled to protection as
trade secrets of such person,  the director shall consider such
record, report or information  or particular part thereof
confidential.  Prior to divulging any alleged trade secret
information pursuant to this  division,  the director shall give ten
day's written notice to the person  claiming trade secrecy.

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{ Acronyms Table of Contents }

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                                          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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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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Waste Minimization Assessment
PfOC Unit/Qper
Proj. No.

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Sh<

WORKSHEET
10

;illill||||llill^
pared By
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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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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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Firm
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                              Waste Minimization Assessment
                              Proc. Unit/Oper	
                              Proj. No.	
 Prepared By	
 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.

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Cl
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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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  Waste Minimization Assessment
 Proc. UnR/Oper.	
 Proj. No.	
           Prepared By	
           Checked By 	
           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
Site
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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Date
                     Waste Minimization Assessment

                    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.	
Prepared By	
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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Waste Minimization Assessment
Prnn. Unif/Opar
Proj. No.

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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.
Prepared By	
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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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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.	
Prepared By	
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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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Firm
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 Waste Minimization Assessment
Proc. Unit/Oper	
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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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                      Proc.
                      Proj. No.
Prepared By	
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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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Firm
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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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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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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

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                                          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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Waste Minimization Assessment
Simplified Worksheets
Proi. No.
Prepared Bv
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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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 Firm
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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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Waste Minimization Assessment
Simplified Worksheet*
Pmj No-

Prepared By
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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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Firm
Site
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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Firm
Site
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).

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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 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

-------
 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

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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) 
-------
             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
Qpilo_n 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-:vX->x •: •
   Level
Revision No.:
Revision Date:
      Pollution Prevention Opportunity Assessment
                    Process Flow Diagram

 PPOA Title or PPOA ID Code(s): 	
 Inputs:
                       /Process:
                     Outputs:
(jNJHh)
(NH2)
(NH3)
Solid
Liquid
Air
(cm)
(§&
©
Solid
Liquid
Air
                    J
                            Product
                         Hazardous- RCRA
                        Hazard, non RCRA
                          Toxic, TSCA
                         Non-Hazardous
                            Other
                         to worksheet 3B
                         (for radioactive wastes)
(pm)
(PR2)
(PR3)
Solid
Liquid
Air
(HRI)
(HR2)
(JHJR3)
Solid
Liquid
Air
(HNI)
(HN2)
(K)
Solid
Liquid
Air
                                                     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.            	

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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
ProcessDescription:
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 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

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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.

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    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:

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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.

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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

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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.

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                                                            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

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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.

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: •: •: -x—x-^xvx-x>> x-:vX->x •: •
   Level
Revision No.:
Revision Date:
      Pollution Prevention Opportunity Assessment
                    Process Flow Diagram

 PPOA Title or PPOA ID Code(s): 	
 Inputs:
                       /Process:
                     Outputs:
(jNJHh)
(NH2)
(NH3)
Solid
Liquid
Air
(cm)
(§&
©
Solid
Liquid
Air
                    J
                            Product
                         Hazardous- RCRA
                        Hazard, non RCRA
                          Toxic, TSCA
                         Non-Hazardous
                            Other
                         to worksheet 3B
                         (for radioactive wastes)
(pm)
(PR2)
(PR3)
Solid
Liquid
Air
(HRI)
(HR2)
(JHJR3)
Solid
Liquid
Air
(HNI)
(HN2)
(K)
Solid
Liquid
Air
                                                     Solid
 Liquid

 Air
                                                                11/93

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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).

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                                                  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

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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.

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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

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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
ProcessDescription:
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

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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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