United States
Environmental Protection
Agency
An Organizational Guide to
Pollution Prevention
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Model
Pollution Prevention Plan
February 1995
WDCR828/001.WP5
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CONTENTS
Preface
Section 1
Section 2
Section 3
Section 4
Section 5
Section 6
Introduction and Regulatory Requirements
Commitment and Program Implementation
Baseline Survey
Pollution Prevention Opportunity Assessment
Pollution Prevention Implementation Plan
Annual Pollution Prevention Reporting
Appendix A
Appendix B
Appendix C
Appendix D
Abbreviations
Definitions
References
Sample Pollution Prevention Survey Forms
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Preface
Introduction
The Army's Model Pollution Prevention Plan (P2 Plan) is a tool for assisting an installation in a
comprehensive program for defining responsibilities, developing guidelines, and establishing
operating standards in preparing its individual pollution prevention plan.
The main objectives of the P2 plan are to establish standardized methods of doing the following:
Identifying and tracking hazardous material usage and generation of waste at each of
the installation's shops or operations.
Identifying opportunities for reducing the volume of hazardous material usage and
waste disposal through source reduction, recycle, or treatment.
Identifying a procedure for preparing an implementation plan for the orderly
adoption of pollution prevention projects.
Executive Order 12856 targets chemicals that are reportable on the Emergency Planning and
Community Right-to Know Act (EPCRA) Section 313 Toxics Release Inventory (TRI), but the
installation should focus its initial efforts on the largest material usage or waste streams generated at
the installation. The largest streams typically offer the greatest opportunities for reduction.
Model P2 Plan Methodology
The P2 Plan was prepared in accordance with the methodology outlined in U.S. Environmental
Protection Agency (EPA) guidance documents. The following specific activities are included as part
of the model plan:
commitment and program implementation
setting of goals
baseline inventory
identification of pollution prevention opportunities
preparation of an implementation plan
annual pollution prevention reporting
The activities are described in the following paragraphs.
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Commitment and Program Implementation
For a P2 Plan to be effective, it needs top management support in both policy statements and
financial resource requests. Pollution prevention needs to be made a part of the organizational
policy. An installation commitment statement and a sample pollution prevention policy statement are
included as part of this model P2 plan.
We recommend that the installation designate the Environmental Quality Control Committee
(EQCC) or equivalent body to be the policy-setting and decision-making body for pollution
prevention for the installation.
Each installation should designate a Pollution Prevention Coordinator who is responsible for
facilitating effective implementation, monitoring, and evaluation of the program.
A Pollution Prevention Assessment Team(s) (PPAT) should be formed as needed to assess
pollution prevention opportunities. The teams should be temporary, having a specific charter to
evaluate a particular waste generation activity, hazardous material usage, or pollution emission from
the installation. The primary responsibilities of the Pollution Prevention Assessment Team(s) are to:
perform pollution prevention opportunity assessments
present the findings of the assessment to the EQCC or equivalent body for approval
and funding
implement projects approved by the EQCC or equivalent body
monitor the performance of their pollution prevention projects
The PPAT should include personnel representing key installation functions that contribute to material
usage or waste streams targeted for analysis. Other support elements necessary for implementing
change in operations to facilitate the reductions also need to be represented. The team should
include members who have direct knowledge of the processes that produce waste or other harmful
emissions and technical advisors. Technical expertise can be supplemented by outside consultants
and by calling on expertise from the following Army technical centers:
Office of Director of Environmental Programs
U.S. Army Environmental Center
U.S. Army Environmental Hygiene Agency
U.S. Army Environmental Policy Institute
U.S. Army Acquisition Pollution Prevention Support Office
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U.S. Army Center for Public Works
U.S. Army Construction Engineering Laboratory
U.S. Army Armament Research, Development, and Engineering Center
National Defense Center for Environmental Excellence
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Setting of Goals
Each installation must set explicit goals for reducing the use of specific hazardous materials and
reducing the volume and toxicity of waste generation within a reasonable time frame. The goals
should support the overall goals of the installation's major command and Army-wide goals.
Baseline Inventory
A baseline inventory shall be conducted to identify the waste streams generated and hazardous
material usage at the installation and to determine the locations from which each stream originates.
The baseline inventory shall be performed on the basis of data obtained from a review of data from
industrial hygiene/safety staff (OHMIS/HHEVI); the facility's Biennial Hazardous Waste Report;
the Water and Waste Department's Hazardous Waste Operations Log for the RCRA-permitted
hazardous waste storage area; DA Form 3917, "Refuse Collection and Disposal"; and DA Form
2788-R, "Facilities Engineering Technical Data," for turn-in of recyclable materials.
Shops identified as major sources of waste or as key components in the installation's handling
system for hazardous waste shall be investigated during a site visit. Investigations may consist of
interviews with shop supervisors and other personnel, a tour of the shop, and a review of the waste-
generating procedures. The information gathered during shop visits can be used for the following
activities:
identifying specific waste-generating processes
highlighting process efficiencies and inefficiencies
identifying specific waste problems
evaluating existing pollution prevention practices
increasing concern of shop personnel for waste reduction
questioning the need for use of particular hazardous materials
Information obtained in the baseline inventory shall be used to rank waste streams or material usage
for reduction efforts. Ranking normally is based on noncompliance issues first, then on the cost of
waste disposal, and finally on the volume of waste generated. Data from the waste audit also will be
evaluated to identify the major sources of each type of waste. The results will allow a more narrow
focus on the larger waste streams and generators.
Identification and Evaluation of Pollution Prevention Opportunities
A range of pollution prevention alternatives shall be developed and screened for each of the major
waste streams and for waste management practices at the installation as a whole. Technological,
operational, and managerial pollution prevention alternatives will be identified.
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Pollution prevention alternatives that pass preliminary screening will be evaluated further for
technical and economic feasibility. Economic analyses will be performed by comparing potential
reductions in treatment and disposal costs with the estimated costs of implementing the change.
Improvements in working conditions and worker safety also should be considered.
Preparation of an Implementation Plan
An implementation plan shall be prepared to incorporate all pollution prevention alternatives that
were found economically feasible and technically practical. The plan shall outline the installation's
overall commitment and planned approach to pollution prevention and describe how each of the
chosen pollution prevention alternatives will be implemented, demonstrated, or evaluated further.
Annual Pollution Prevention Reporting
Installations have the following reporting requirements that relate to pollution prevention:
hazardous waste generator biennial or annual report, from RCRA
annual EPCRA TRI reporting, from EO 12856
Army Compliance Tracking System (ACTS) hazardous waste disposal and
recycling roll-ups, from AR 200-1
RCS 1383 reporting of programming, budgeting, and execution for all
environmental projects, including P2, from AR 200-1
Army Material Command in its ACTS data call requires its installations to report
waste generation and disposal by process category
How To Use This Model Plan
This document has been prepared as a model P2 plan for installations to use in developing their
individual plans. The P2 plan is written to be easily adaptable to meet individual site conditions.
Instructions for personnel using the plans is marked with shading ("redlining") in the text. When the
individual plan is prepared, the shaded text should be deleted. Information is included that may not
apply to a given installation. If a section does not apply, delete it. Additional sections probably will
need to be added to reflect the individual waste streams that are significant at a given installation.
For your ease, at places in the text where the individual installation name should be used, a general
installation name, "INSTALLATION-XXX," is used. When writing the plan using WordPerfect,
do a search-and-replace to replace this term with your installation name.
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Section 1
Introduction and Regulatory Requirements
Introduction
Preventing pollution is INSTALLATION-XXXs top environmental priority. The current emphasis
on pollution prevention is necessary to meet state and national pollution prevention policy goals,
reduce long-term liabilities of waste disposal, save money by reducing the installation's raw material
purchases and waste treatment and disposal costs, and protect public health and the environment.
Pollution prevention is a cost-effective means of meeting environmental objectives in an era when
Army installations are simultaneously subject to stricter standards for pollution control, public
criticism of their environmental records, and declining budgets. The costs of failing to prevent
pollution are dramatically evident; at some installations, cleanup costs are estimated in the hundreds
of millions of dollars.
Environmental liabilities increase directly with the volume of hazardous substances and materials in
use and increase to a lesser extent as a result of other materials used and the solid waste generated.
Reducing these long-term liabilities requires a positive commitment, a sound plan, and an aggressive
program for modifying past attitudes toward the conservation of all materials. Reducing liabilities
also requires actively searching for opportunities to reduce the amount of waste generated and the
use of toxic materials, fuels, and chemicals while still accomplishing INSTALLATION-XXX's
mission.
Background
Identify the installation's primary mission clearly. Include in this section information about impacts
due to the physical location of the installation: environmental, sociopolitical, cultural, and don't forget
environmental justice issues.
Regulatory and Policy Requirements
The Federal Pollution Prevention Act of 1990 was enacted on November 5, 1990. Its purposes
are as follows:
Prevent or reduce pollution at the source whenever feasible.
Promote recycling if pollution cannot be prevented.
Permit treatment if pollution cannot be prevented or recycling cannot
be implemented.
Discourage disposal or other releases into the environment.
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The Act is not limited to hazardous waste or chemicals subject to Toxics Release Inventory (TRI)
reporting under Section 313 of the Emergency Planning and Community Right-to-Know Act of
1986 (EPCRA). It also encompasses all hazardous substances, pollutants, or contaminants.
Federal facilities, including Army installations, were included in the requirements of the Act when, in
1993, President Clinton signed Executive Order 12856, setting the Federal Government's policy on
pollution prevention. The President noted:
. . . federal facilities will set the example for the rest of the country and become the
leader in applying pollution prevention to daily operations, purchasing decisions and policies. In the
process, federal facilities will reduce toxic emissions, which helps avoid cleanup costs and promotes
clean technologies.
EO 12856 requires federal facilities to report TRI releases and to set agency goals of reducing TRI
reportable releases by 50 percent from a 1994 baseline by 1999. It also requires that federal
facilities subject to any of the requirements of EPCRA prepare P2 plans by the end of 1995 that
indicate how the facility will support the Agency's P2 goals. Facility P2 plans should include a
detailed inventory of waste generation, an analysis of pollution prevention opportunities and options,
and a plan for implementing pollution prevention measures.
The Department of the Army (DA) also has issued regulations that stress minimizing the negative
effects of the Army's activities on the environment. Army Regulation (AR) 200-1, Environmental
Quality: Environmental Protection and Enhancement, prescribes DA responsibilities, policies,
and procedures for preserving, protecting, and restoring the quality of the environment. AR 200-1
sets the Army's policy for hazardous waste minimization. It requires Army installations to reduce the
quantity or volume and the toxicity of hazardous wastes whenever economically practical or
environmentally necessary.
This P2 plan is based on current Army guidance and is being used by each installation to comply
with the Federal Pollution Prevention Act of 1990; the Superfund Amendments and Reauthorization
Act of 1986 (SARA); the Toxic Substances Control Act (TSCA); the Clean Air Act Amendments
of 1990; the Clean Water Act of 1987; the Montreal Protocol on Substances that Deplete the
Ozone Layer; Executive Order 12856; and DOD Directive 4210.15, Hazardous Material
Pollution Prevention, dated July 27, 1989. The P2 Plan is framed according to the protocol
outlined in EPA guidance manuals, Waste Minimization Opportunity Assessment Manual
(EPA/625/7-88-003, July 1988), and Facility Pollution Prevention Guide (EPA/600/R-
92/088). The plan was prepared in accordance with Guidance to Hazardous Waste Generators
on the Elements of a Pollution Prevention Program (Federal Register, May 28, 1993).
Include state and local requirements as necessary or applicable.
Definitions of Pollution Prevention Terms
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Under Executive Order 12856, pollution prevention means source reduction 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
protection of natural resources by conservation
The Federal Pollution Prevention Act of 1990 defines "source reduction" to mean any practice that:
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
reduces the hazards to public health and the environment associated with the release
of such substances, pollutants, or contaminants
The term includes equipment or technology modifications, process or procedure modifications,
reformulation or redesign of products, substitution of raw materials, and improvements in
housekeeping, maintenance, training, and inventory control.
Under the Act, recycling, treatment, and disposal are not included in the definition of pollution
prevention. However, some practices commonly described as "in-process recycling" may qualify
as pollution prevention. Examples include solvent recycling using an integral still, continuous filtering
of a plating bath, and recovery of volatile organic compounds (VOCs) from degreasing vents.
Recycling that is conducted in an environmentally sound manner shares many of the advantages of
prevention: It can reduce the need for treatment or disposal and conserve energy and natural
resources.
Techniques for pollution prevention fall into six categories: source reduction, in-process recycling,
process modification, improved plant operations, input substitutions, and changes in end-product.
Before pollution prevention techniques can be used, a waste assessment must be conducted to
show where reduction methods implemented by a facility can be most effective. Potential pollution
prevention methods then are pinpointed. Pollution prevention requires a multimedia assessment.
Transferring pollution from one medium to another does not constitute pollution prevention.
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Section 2
Commitment Goals and Program Implementation
Commitment
INSTALLATION-XXX is committed to reducing the environmental effects of its activities through
an active pollution prevention program. In support of this commitment, the installation's pollution
prevention policy statement (Figure 2-1) has been prepared and disseminated to all affected
individuals in the installation.
Army Pollution Prevention Goals
This subsection will summarize the Army's Pollution Prevention goals and when they are finalized,
targeting particular classes of wastes or materials used and how the particular installation is to
support these goals, as required by EO 12856.
MACOM Pollution Prevention Goals
This subsection will summarize the MACOM Pollution Prevention goals and when they are finalized,
targeting particular classes of wastes or materials used and how the particular installation is to
support these goals.
Installation Pollution Prevention Goals
The long-term goal of INSTALLATION-XXX is to eliminate the use of hazardous materials,
eliminate the generation of wastes, and eliminate emissions of pollutants to the environment (zero
discharge). Achieving the goal of complete elimination is recognized as not being technically or
economically feasible. Thus, goals have been adopted as interim measures with the ultimate goal of
achieving zero discharge (Table 2-1).
Program Implementation
The Pollution Prevention (P2) program at INSTALLATION-XXX will be managed in accordance
with AR420-47 and AR 200-1. This plan and the policies and procedures established to
implement the plan are developed and approved by the EQCC or equivalent. The Pollution
Prevention Program is implemented by the Installation's Pollution Prevention Coordinator, with the
assistance of Pollution Prevention Assessment Teams as needed to develop, evaluate, and
implement specific pollution prevention projects.
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Table 2-1
INSTALLATION-XXX POLLUTION PREVENTION GOALS
Waste Type
Hazardous
Waste
Hazardous
Waste
Hazardous
Waste
Hazardous
Waste
Solid Wastes
Ozone -
Depleting
Chemical Use
TRI Reportable
Releases
Subtype
EPA Toxic 17
Wastes
Solvent Wastes
Acids and
Bases
Reduction Goal
(%)
50%
Baseline Year
1994
Target Year
1999
Environmental Quality Control Committee
The EQCC is the policy-setting and decision-making body for pollution prevention at
INSTALLATION-XXX. The EQCC will closely coordinate their actions with the installation's
Hazardous Waste Management Board (Ref. AR 420-47) to complement actions, not duplicate
them. The following list summarizes the responsibilities of the EQCC:
Brief the installation commander (1C) on all actions necessary or under way to make
a pollution prevention program successful.
Establish overall pollution prevention policies and procedures.
Establish pollution prevention goals.
Direct activities of the Pollution Prevention Coordinator.
Rank the waste streams, processes, or facility areas for assessment.
Establish priorities for implementation of proj ects.
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Obtain funding and establish schedule for implementation.
Monitor or direct implementation progress.
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The EQCC or equivalent is chaired by the following individual:
• Insert EQCC Chairperson here
A field grade officer from any major contributor to the installation's waste stream shall be the
chairperson of the EQCC.
Figure 2-1
INSTALLATION-XXX
Pollution Prevention Policy Statement
INSTALLATION-XXX is committed to an active policy of protecting the environment in all of
our activities. This pollution prevention policy statement is based on our commitment to the
following:
providing a clean and safe environment in our community
ensuring a safe and healthy workplace for our staff
complying with all applicable laws and regulations
efficiently accomplishing our mission
reducing future liability for waste disposal
reducing waste management costs
To accomplish these objectives, we will implement programs for reducing or eliminating
generation of waste through source reduction and other pollution prevention methodologies. This
policy extends to air, wastewater, and solid and hazardous wastes. In addition to meeting the
objectives, there are other important benefits related to pollution prevention.
INSTALLATION-XXX is committed to reducing the weight and toxicity of generated wastes.
As part of this commitment, INSTALLATION-XXX gives priority to source reduction. Where
source reduction is infeasible, other pollution prevention methods, such as recycling, will be
implemented where feasible. The wastes that cannot be prevented will be converted to useful
products or used beneficially, where feasible. Remaining wastes for which no pollution
prevention option is warranted will be effectively treated (to decrease volume or toxicity) and
responsibly managed. INSTALLATION-XXX will select waste management methods that
minimize present and future effects on human health and the environment.
Pollution prevention is the responsibility of all of our staff. INSTALLATION-XXX is
committed to identifying and implementing pollution prevention opportunities through solicitation,
encouragement, and involvement of all employees.
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The EQCC includes the organizations or departments that have significant operational or
administrative interest in developing a pollution prevention plan. The EQCC has representatives of
the following organizations:
Directorate of Public Works
Directorate of Resource Management
Directorate of Logistics
Directorate of Contracting
Directorate of Personnel and Community Activity
Directorate of Transportation
Directorate of Industrial Operations
U.S. Army Medical Activity (MEDDAC)
Additional members of the EQCC could include representatives of Safety and Health; Fire
Protection: Preventive Medicine Services: Public Affairs Office: Staff Judge Advocate: Defense
Reutilization Marketing Office (DRMO), Finance and Accounting; and Army, Air Force Exchange
System (AAFES). An existing council if qualified, may be used instead of establishing a new
board.
Pollution Prevention Coordinator
The Pollution Prevention Coordinator has overall responsibility for the development and
implementation of the P2 plan. The Pollution Prevention Coordinator has the responsibility for
organizing, implementing, managing, or monitoring the following pollution prevention methods and
programs:
integrating pollution prevention in the installation's comprehensive planning
preparing and updating baselines for hazardous material use and waste generation
coordinating the performance of pollution prevention opportunity assessments
(PPOAs) to identify and evaluate pollution prevention procedural changes, projects, and equipment
recommending priorities for funding pollution prevention projects and equipment
establishing policies for identifying, procuring, and tracking hazardous materials
developing the installation's pollution prevention training programs
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Pollution Prevention Assessment Team(s)
Pollution Prevention Assessment Team(s) (PPAT) will be formed as needed to perform PPOAs.
The teams will be temporary, having a specific charter to evaluate a particular waste generation
activity, hazardous material use, or pollution emission from the installation. The primary
responsibilities of the PPAT are to:
perform PPOAs
present the findings of the assessment to the EQCC for approval and funding
implement proj ects approved by the EQCC
monitor the performance of their pollution prevention proj ects
The PPAT may be led by the installation's Pollution Prevention Coordinator or by a team leader
who has a vested interest in the particular waste streams or operations to be investigated.
The PPAT will include personnel representing key installation functions that contribute to material
use or waste streams targeted for analysis. Other support elements necessary for implementing
changes in operations to facilitate the reductions also will be represented. The team will include
members who have direct knowledge of the processes that produce waste or other harmful
emissions and technical advisors.
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Section 3
Baseline Inventory
A baseline inventory is necessary for two reasons. The quantities of waste generation or toxic
material use are assessed to target specific waste streams, materials being used, or activities for
pollution prevention. Annual reports on waste generation and toxic material use will be compared
with the baseline inventories to evaluate the effectiveness of pollution prevention projects and to
monitor progress in achieving INSTALLATION-XXXs pollution prevention goals. For facilitating
this comparison, the same formats are used for the baseline inventory and annual reports.
Measurements of materials used and wastes generated take into account production levels (such as
vehicles maintained or number of soldiers trained), so that P2 is not accomplished solely due to
reductions in training or maintenance.
Baseline inventories have been prepared for the following categories and subcategories of waste
and material use:
Hazardous Waste Generation (Table 3-1)
Solvent Waste Generation
Waste Acids and Bases Generation
EPA Toxic 17 Waste Generation (Table 3-2)
Solid Waste Generation (Table 3-3)
Ozone-Depleting Chemicals (ODCs) Usage (Table 3-4)
TRI Reportable Releases (Table 3-5)
All data in these tables are reported in annual quantities.
Some categories overlap (e.g., solvent wastes, waste acids and bases, and EPA Toxic 17 wastes
also will appear as hazardous waste; some of the EPA Toxic 17 wastes can be solvents). The use
of the baseline inventories will assist in developing projects for meeting the pollution prevention goals
of INSTALLATION-XXX.
This section contains the summary of the Baseline Inventory. Detailed baseline information is in the
appendices.
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Table 3-1
199 ANNUAL HAZARDOUS WASTE GENERATION AT INSTALLATION-XXX
Page 19 of 3
Waste Type
1. Solvent
Wastes
2. Acids &
Bases
3 . Wastewater
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
3-19
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Table 3-1
199 ANNUAL HAZARDOUS WASTE GENERATION AT INSTALLATION-XXX
Page 19 of 3
Waste Type
Treatment
Sludges
4. Fuels
5.
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
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Table 3-1
199 ANNUAL HAZARDOUS WASTE GENERATION AT INSTALLATION-XXX
Page 19 of 3
Waste Type
6.
7.
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
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Table 3-1
199 ANNUAL HAZARDOUS WASTE GENERATION AT INSTALLATION-XXX
Page 19 of 3
Waste Type
8.
9.
10.
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
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Table 3-1
199 ANNUAL HAZARDOUS WASTE GENERATION AT INSTALLATION-XXX
Page 19 of 3
Waste Type
11.
12.
TOTAL
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
100 %
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
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WDCR828/013.WP5
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Table 3-2
199 ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 25 of 5
Waste Type
1 . Benzene
2. Cadmium &
compounds
3. Carbon
Tetrachloride
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
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Table 3-2
199 ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 25 of 5
Waste Type
4. Chloroform
5. Chromium &
compounds
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
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Table 3-2
199 ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 25 of 5
Waste Type
6. Cyanides
7. Dichloromethane
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
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Table 3-2
199 ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 25 of 5
Waste Type
8. Lead & compounds
9. Mercury &
compounds
10. Methyl Ethyl
Ketone
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
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Table 3-2
199 ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 25 of 5
Waste Type
11. Methyl Isobutyl
Ketone
12. Nickel &
compounds
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
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Table 3-2
199 ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 25 of 5
Waste Type
13.
Tetrachloroethylene
14. Toluene
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
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Table 3-2
199 ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 25 of 5
Waste Type
15. Trichloroethane
16. Trichloroethylene
17. Xylene
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
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Table 3-2
199 ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 25 of 5
Waste Type
TOTAL
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
100%
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
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Table 3-3
1 99 SOLID WASTE GENERATION AT INSTALLATION-XXX
Page 3 3 of 3
Waste Type
1. Aluminum Cans
2. Corrugated
Cardboard
3. Office Paper
Waste
(Ibs)
% of Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight by
Shop (Ibs)
% of Waste
Type
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Table 3-3
1 99 SOLID WASTE GENERATION AT INSTALLATION-XXX
Page 3 3 of 3
Waste Type
4. Newspaper
5. Glass
Waste
(Ibs)
% of Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight by
Shop (Ibs)
% of Waste
Type
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Table 3-3
1 99 SOLID WASTE GENERATION AT INSTALLATION-XXX
Page 3 3 of 3
Waste Type
6. Ferrous Cans
7. Plastic (PET soft
drink
bottles, HDPE milk
jugs,
etc.)
8. Yard Waste
Waste
(Ibs)
% of Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight by
Shop (Ibs)
% of Waste
Type
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Table 3-3
1 99 SOLID WASTE GENERATION AT INSTALLATION-XXX
Page 3 3 of 3
Waste Type
9. Unclassified Waste
10. Engine Oils
Waste
(Ibs)
% of Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight by
Shop (Ibs)
% of Waste
Type
3-36
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Table 3-3
1 99 SOLID WASTE GENERATION AT INSTALLATION-XXX
Page 3 3 of 3
Waste Type
11. Engine Coolants
12.
TOTAL
Waste
(Ibs)
% of Total
Waste
100%
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight by
Shop (Ibs)
% of Waste
Type
WDCR828/015.WP5
3-37
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Table 3-4
199 USAGE OF OZONE DEPLETING CHEMICALS (ODCS)AT INSTALLATION-XXX
Page 3 8 of 3
ODC Type
1 . Freons
2. Halons
3. Cleaning Solvents
Usage
(Ibs)
% of Total
Use
ODC
Compound
User/Shop
Process or Operation
Using ODC
Usage by
Shop (Ibs)
% of Type
Usage
3-38
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Table 3-4
199 USAGE OF OZONE DEPLETING CHEMICALS (ODCS)AT INSTALLATION-XXX
Page 3 8 of 3
ODC Type
4. Paint Strippers
5.
Usage
(Ibs)
% of Total
Use
ODC
Compound
User/Shop
Process or Operation
Using ODC
Usage by
Shop (Ibs)
% of Type
Usage
3-39
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Table 3-4
199 USAGE OF OZONE DEPLETING CHEMICALS (ODCS)AT INSTALLATION-XXX
Page 3 8 of 3
ODC Type
6.
7.
8.
Usage
(Ibs)
% of Total
Use
ODC
Compound
User/Shop
Process or Operation
Using ODC
Usage by
Shop (Ibs)
% of Type
Usage
3-40
-------
Table 3-4
199 USAGE OF OZONE DEPLETING CHEMICALS (ODCS)AT INSTALLATION-XXX
Page 3 8 of 3
ODC Type
9.
10.
Usage
(Ibs)
% of Total
Use
ODC
Compound
User/Shop
Process or Operation
Using ODC
Usage by
Shop (Ibs)
% of Type
Usage
3-41
-------
Table 3-4
199 USAGE OF OZONE DEPLETING CHEMICALS (ODCS)AT INSTALLATION-XXX
Page 3 8 of 3
ODC Type
11.
12.
TOTAL
Usage
(Ibs)
% of Total
Use
100%
ODC
Compound
User/Shop
Process or Operation
Using ODC
Usage by
Shop (Ibs)
% of Type
Usage
WDCR828/016.WP5
3-42
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Table 3-5
199 ANNUAL TOXICS RELEASE INVENTORY (TRI) EMISSIONS FOR INSTALLATION-XXX
Page 43 of 3
TRI Chemical
1.
2.
3.
Code
Releas
e (Ibs)
%of
Total
Release
Generator
Unit/Shop
Process or Operation
Emitting
Weight
by Shop
Obs)
% of TRI
Chemical
3-43
-------
Table 3-5
199 ANNUAL TOXICS RELEASE INVENTORY (TRI) EMISSIONS FOR INSTALLATION-XXX
Page 43 of 3
TRI Chemical
4.
5.
Code
Releas
e (Ibs)
%of
Total
Release
Generator
Unit/Shop
Process or Operation
Emitting
Weight
by Shop
Obs)
% of TRI
Chemical
3-44
-------
Table 3-5
199 ANNUAL TOXICS RELEASE INVENTORY (TRI) EMISSIONS FOR INSTALLATION-XXX
Page 43 of 3
TRI Chemical
6.
7.
8.
Code
Releas
e (Ibs)
%of
Total
Release
Generator
Unit/Shop
Process or Operation
Emitting
Weight
by Shop
Obs)
% of TRI
Chemical
3-45
-------
Table 3-5
199 ANNUAL TOXICS RELEASE INVENTORY (TRI) EMISSIONS FOR INSTALLATION-XXX
Page 43 of 3
TRI Chemical
9.
10.
Code
Releas
e (Ibs)
%of
Total
Release
Generator
Unit/Shop
Process or Operation
Emitting
Weight
by Shop
Obs)
% of TRI
Chemical
3-46
-------
Table 3-5
199 ANNUAL TOXICS RELEASE INVENTORY (TRI) EMISSIONS FOR INSTALLATION-XXX
Page 43 of 3
TRI Chemical
11.
12.
TOTAL
Code
Releas
e (Ibs)
%of
Total
Release
100 %
Generator
Unit/Shop
Process or Operation
Emitting
Weight
by Shop
Obs)
% of TRI
Chemical
WDCR828/052.WP5
3-47
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Section 4
Pollution Prevention Opportunity Assessment
The PPOA enables INSTALLATION-XXX to examine the alternatives available for pollution prevention. The modules identify the waste
stream and the operation from which the stream may be generated, describe the process, and present several pollution prevention alternatives.
Each alternative is described along with its advantages and disadvantages.
INSTALLATION-XXX will use these forms to perform the assessment. Included in Appendix D are sample pollution prevention survey
forms. The form should be used by the Pollution Prevention Coordinator or the EQCC as a tool during the survey. The forms contain
questions and note areas to examine when interviewing or working with personnel who generate the waste.
The installation will be required to furnish information on the assessment forms. The needed information is the estimated reduction, a technical
evaluation, and an economic evaluation. Base personnel will have to describe site-specific conditions so that the amount of reduction possible
and the technical and economic feasibility of the alternative can be determined. The information generated by the installation will determine if
these alternatives are good pollution prevention opportunities. Personnel performing the PPOA will have to work with the personnel generating
the waste to find the best methods for reducing the waste stream.
Assessment modules are included for the following areas or waste streams:
Format Example
The following are P2 examples that typically have been found to work. They should be expanded to include materials listed in the format
example. It is important to note that these are example assessment modules and should not be used verbatim. Site-specific information and
cost data will need to be generated to assess the suitability and feasibility of each alternative process or chemical for your installation.
Waste Solvent from Parts Cleaning
Cleanup Solvents from Painting
VOC Emissions from Painting
Scrubber Sludge from Paint Booths
Liquid Paint- Stripping Waste
Dry Paint- Stripping Waste
4-48
3-48
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Battery Acids
Radiator-Cleaning Waste
Solid Waste
Used Oil from Vehicle Maintenance
Used Oil Filters from Vehicle Maintenance
Used Antifreeze from Vehicle Maintenance
Halon Used in Fire Extinguishers
Freon Used in Refrigeration
WDCR828/006.WP5
4-49
3-49
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Pollution Prevention Opportunity Assessment Module
Waste Solvents From Parts Cleaning
Waste Stream: Waste Solvents
Operation: Parts Cleaning
Description
Waste solvents are routinely generated at military facilities during parts cleaning. Parts cleaning typically takes place during maintenance
of vehicles and heavy equipment. The waste stream generated during these activities includes liquid waste solvent and degreasing compounds
containing unwanted film material, air emissions of volatile solvents, solvent-contaminated wastewater, and solid waste consisting of oil, grease,
soil particles, and other film material. There are three common solvent cleaning methods: cold cleaning, vapor degreasing, and precision
cleaning. During cold cleaning, the solvent is applied either by brush or by dipping the items in a solvent dip tank. Vapor degreasing uses steam
coils for heating the solvent to produce a vapor, and the item to be cleaned is inserted into the vapor region, where the solvent condenses,
removes dirt and grease, and drips back into the tank. Precision cleaning flushes the article being cleaned with a solvent.
Alternative 1: Onsite Recycling Using Distillation
Description
Distillation is a recycling method for spent solvents that involves boiling and recovering the solvent. A small amount of sludge remains.
The sludge is the dirt and grease from the cleaning process. Distillation reduces the need for offsite transportation and manifesting. Distillation
units come in various sizes and types. Small batch-style units would be appropriate for facilities with low solvent usage. Larger units are
available that could be centrally located to service several users.
The advantage of onsite distillation is that the facility controls its own hazardous waste. Sending solvents off the site is expensive and
requires manifesting of the waste. The disadvantages are that distillation requires labor, energy, cooling water, and maintenance. Solvents that
are to be recovered by distillation must be segregated.
Prevention Type: Recycling
Estimated Reduction: To be determined by the installation
4-3
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Pollution Prevention Opportunity Assessment Module
Waste Solvents From Parts Cleaning
Technical Evaluation: To be determined by the installation
4-4
-------
Economic Evaluation
Investment Cost: To be determined by the installation
Annual Savings: To be determined by the installation
Payback Period: To be determined by the installation
Alternative 2: Off-Facility Recycling
Description
Companies exist that provide the equipment and solvent for parts cleaning. The equipment is rented, and the company is contracted to
pick up the spent solvent, supply fresh solvent, and recycle the spent material. The spent material will require a manifest. These units typically
are dip tanks.
The advantage of this alternative is that the user does not have to dispose of waste solvents. The disadvantage is that the alternative is
subject to the availability of local recyclers, is more expensive than having an in-house unit, is less convenient, and has the added liability of
having an outside entity responsible for handling the installation's hazardous waste.
Prevention Type: Offsite Recycling
Estimated Reduction: To be determined by the installation
Technical Evaluation: To be determined by the installation
Economic Evaluation
Investment Cost: To be determined by the installation
Annual Savings: To be determined by the installation
4-5
-------
Payback Period: To be determined by the installation
Alternatives: Water-Based Cleaners
Description
Aqueous and semiaqueous cleaners are available that may be substituted for solvents. The cleaners can be alkaline or acidic or alcohol-
based. The advantage of water-based cleaners is that solvent use can be eliminated. Eliminating solvents will reduce environmental liability and
reporting and documentation requirements. The disadvantages are that the effectiveness of water-based cleaners for a specific task will have to
be measured. Water-based cleaning may not be acceptable for all materials or processes. Another disadvantage is that aqueous cleaning still
can produce a significant volume of waste that has to be managed and may be classified as hazardous waste because of its contents or pH.
Prevention Type: Product Substitution
Estimated Reduction: To be determined by the installation
Technical Evaluation: To be determined by the installation
Economic Evaluation
Investment Cost: To be determined by the installation
Annual Savings: To be determined by the installation
Payback Period: To be determined by the installation
WDCR828/022.WP5
4-6
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Pollution Prevention Opportunity Assessment Module
Cleanup Solvents From Painting
Waste Stream: Cleanup Solvents
Operation: Painting
Description
Most painting on Army installations is performed by conventional liquid spray technologies. The paint is mixed with a carrier, usually an
organic solvent, and is applied to the surface with an air-pressurized sprayer. A major source of waste generated during painting is solvents
used to clean painting equipment. Most paints are solvent-based, so they require solvents for cleanup. The solvents used depend on the type of
paint used. Some of 1he more common solvents are methyl ethyl ketone (MEK); xylene; 1,1,1-trichloroethane; toluene; butyl acetate; ethylene
glycol; and alcohol.
Alternative 1: Use painting methods that minimize solvent use.
Description
Solvent use can be reduced by changing painting methods. Powder coating or electrostatic dry-powder painting are two methods that
minimize solvent use. Dry powder is air-blown onto the equipment, and the equipment is cured in an oven to bond the paint to the substrate.
Electrostatic dry-powder painting sprays ionized dry powder onto a surface that has the opposite charge. The major limitation of dry-powder
painting is that the items to be painted must be able to withstand the typical curing temperature of 350°F for 30 minutes.
Alternative 2: Use water-based paint when possible.
Description
Water-based paint is used to eliminate the need for solvent cleaners. The disadvantages of water-based paint are that the surface must
be free of oil and grease so that the paint will adhere, longer drying times are required, and the transfer efficiency may not be as high as solvent-
based paints.
Alternative 3: Use specialized cleaning equipment.
4-7
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Pollution Prevention Opportunity Assessment Module
Cleanup Solvents From Painting
Description
Specialized equipment is available for cleaning paint guns and other paint-application equipment. Waste solvents requiring disposal as a
hazardous waste can be eliminated.
Alternative 4: Collect and recycle cleaning solvent.
Description
Cleaning solvents can be collected and recycled using distillation. Several companies manufacture small distillation units or batch stills.
Solvent can be recovered and reused. The residue from the distillation will have to be disposed of properly, most likely as a hazardous waste.
WDCR828/023.WP5
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Pollution Prevention Opportunity Assessment Module
VOC Emissions From Painting
Waste Stream: Volatile Organic Compounds Emission
Operation: Painting
Description
Volatile organic compounds (VOCs) are used during painting operations and are emitted to the air. Most painting on Army installations
is performed by conventional liquid spray technologies. The paint is mixed with a carrier, usually an organic solvent, and is applied to the
surface with an air-pressurized sprayer. One of the largest volumes of waste generated during painting is air emissions. During typical spray
painting in a spray booth, 50 percent of the paint is deposited on the surface being painted, and the other 50 percent is sprayed into the air. As
the paint dries, the solvent evaporates into the air.
USEPA regulates VOCs emitted from paint coating. Federal VOC limits for paint are 420 g/L for paints that cure below 90°C and
360 g/L for paints that cure above 90°C. Some state air-pollution control agencies are setting strict VOC content limits for paint. For example,
the South Coast Air Quality Management District in California has set a 300 g/L VOC limit for general air-dried paints used for coating metal
parts and products in fabricating and painting shops. Local regulatory agencies also control VOCs by setting total permissible discharge limits
from facilities. The limits include point sources and fugitive sources. The U.S. Environmental Protection Agency is required to develop limits for
toxic air emissions. The limits probably will have an effect on both the types of solvents used in paint and those used in cleanup.
Alternative 1: Use painting methods that minimize solvent use.
Description
VOC emissions can be reduced by changing painting methods. Powder coating or electrostatic dry-powder painting are two methods
that minimize solvent use. Dry powder is air-blown onto the equipment, and the equipment is cured in an oven to bond the paint to the
substrate. Electrostatic dry-powder painting sprays ionized dry powder onto a surface that has the opposite charge. The major limitation in
dry-powder painting is that the items to be painted must be able to withstand the typical curing temperature of 350°F for 30 minutes.
-------
Alternative 2: Use paint formulations that minimize or eliminate solvent use.
Description
VOC emissions can be reduced by using high-solid or low-VOC coatings. The coatings contain about 50 to 95% solids. The coatings
require special spray equipment for application because of their high viscosity. Surface preparation for reducing the presence of grease or oil is
more critical because of less solvent in the paint. In addition, spray application can be wasteful because there is a tendency to apply too much
coating to achieve a "wet" appearance similar to that obtained with normal solvent coatings.
Alternative 3: Use water-based paint when possible.
Description
Use water-based paint to eliminate the need for solvents and the resulting VOC emissions. Water-based paint uses a water-based
solvent as the carrier. The disadvantages of water-based paint are that the surface must be free of oil and grease so that the paint will adhere,
longer drying times are required, and the transfer efficiency may not be as high as for solvent-based paints.
WDCR828/024.WP5
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Pollution Prevention Opportunity Assessment Module
Paint Booth Scrubber Sludge
Waste Stream: Scrubber Sludge from Paint Booths
Operation: Painting
Description
Most painting on Army installations is performed by conventional liquid spray technologies. The paint is mixed with a carrier, usually an
organic solvent, and is applied to the surface with an air-pressurized sprayer. The largest volume of hazardous waste generated in painting
involves air emissions that create paint sludge. For instance, during typical spray painting in a spray booth, 50 percent of the paint is deposited
on the surface being painted, and the other 50 percent is sprayed into the air. As the paint dries, the solvent evaporates into the air. The air
from the paint booth then is exhausted through a water scrubber that separates the paint from the air. The scrubber water normally is recycled,
and paint solids are concentrated into a scrubber sump. When the sumps fill, the sludge is removed and put in drums for disposal.
Alternative 1: Use painting methods with higher transfer efficiencies.
Description
The amount of overspray from painting equipment should be minimized. Conventional air-atomized spray painting techniques are very
inefficient. Some other coating methods that have higher transfer efficiencies include electrostatic spraying, airless spraying, dip coating, and
powder coating.
Alternative 2: Use dry-filter paint booths.
Description
Changing the air-treatment system to dry filters will eliminate the scrubber system. This will reduce water use and potentially the amount
of sludge to be disposed of. However, the filters from the system will have to be disposed of. Testing will be required to determine if the filters
are hazardous waste.
4-10
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Alternative 3: Use water-based paint when possible.
Description
Water-based paint is used to eliminate the need for solvents and the resulting VOC emissions. Water-based paints use a water-based
solvent as the carrier. The disadvantages of water-based paint are that the surface must be free of oil and grease so that the paint will adhere,
longer drying times are required, and the transfer efficiency may not be as high as for solvent-based paints.
Alternative 4: Implement better employee operating practices.
Description
Paint-spray systems often are manually operated, so employee training will reduce the amount of paint used and promote waste
reduction. Keeping the air pressure low and the spray gun perpendicular to the surface adds several degrees of accuracy to the system by
preventing overspray and minimizing sludge in the air-treatment system.
WDCR828/025.WP5
4-11
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Pollution Prevention Opportunity Assessment Module
Liquid Paint-Stripping Wastes
Waste Stream: Liquid Paint-Stripping Waste
Operation: Paint Stripping
Description
Paint stripping is the process of removing paint and paint-type coatings from surfaces, usually as a preparation for inspection,
dismantling, reconditioning, or repainting. Solvents or solvent-chemical mixtures are applied to the surface to destroy either the paint coating
itself or the coating's ability to stick to the surface. When this process is complete, the residue of paint or solvent is removed from the surface,
usually by a pressurized water wash or by scraping. In many instances, the solvent stripper must be reapplied to remove multiple coats or paint
that is particularly resistant.
The wastes generated in the stripping process are a significant source of pollutants. The wastes include solvent or paint residue, which
can be collected separately, and waste washwater, which contains solids and dissolved chemicals from paints and solvents. Collected solvent
or paint residue typically is put in drums and transported to a licensed hazardous waste disposal site. Waste washwater requires treatment in an
industrial wastewater treatment plant to remove the paint-stripping solvents (usually phenolic or methylene chloride components) and the metals
either in the paint or in the material being stripped.
Alternative 1: Use mechanical methods for removing paint.
Description
A new plastic medium has been developed for blast-stripping painted surfaces without damaging the undersurface. This new material
has many advantages over other materials, including engineered abrasive characteristics. It is recyclable, durable, and nonhazardous. The
material is constructed of soft plastic formed into rough-edged granular media. Old paint is dislodged using the new media and conventional
sand-blasting equipment. The resulting dry waste of pulverized paint and plastic media has significantly less volume and is more readily disposed
of than the wastewater produced in solvent-based paint stripping. The plastic medium can be separated from the paint using a cyclone. The
medium also can be recycled or reclaimed.
4-12
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Pollution Prevention Opportunity Assessment Module
Liquid Paint-Stripping Wastes
One disadvantage is that mechanical stripping is not appropriate for the equipment. Another problem may be that the volume of material
requiring paint stripping may not be great enough to justify the capital cost of the system. Advantages include elimination of solvent use, which
results in less environmental liability, lower solvent emissions, and less waste shipped off the site as hazardous waste.
Alternative 2: Use different stripping solution.
Description
Nonphenolic stripping solutions can be substituted for traditional stripping solutions. Substances such as benzyl alcohol can be used to
remove paint. Benzyl alcohol is not a regulated substance under SARA. The effectiveness of any substituted product will have to be evaluated.
The disadvantage of this alternative is that the effectiveness of the new product must be determined. While eliminating solvent use, the new
product may generate more waste than before. If product substitution works, then the liabilities, solvent emissions, and disposal costs
associated with traditional paint stripping will be eliminated or greatly reduced.
WDCR828/026.WP5
4-13
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Pollution Prevention Opportunity Assessment Module
Dry Paint-Stripping Waste
Waste Stream: Dry Paint-Stripping Waste
Operation: Paint Stripping
Description
Conventional sand blasting, abrasive blasting, and glass-bead blasting have been used to remove paint and rust from metal surfaces.
These techniques cannot be used in many applications, because the abrasive media can damage aluminum or fiberglass surfaces and small or
delicate steel parts. In the late 1980s, plastic media blasting was developed and manufactured for blast-stripping painted surfaces without
damaging the undersurface. The new material has many advantages over other materials: It is recyclable, durable, and nonhazardous.
Today, spent plastic media are used routinely at Army corrosion-control and paint shops during normal paint- and corrosion-removal
activities. Both media are used to remove paint from aluminum and steel vehicles, aircraft, and ground equipment parts. The operation takes
place in a sealed booth. The spent media and the paint dust are removed through a vacuum and mechanically sorted. Reusable media are
returned to the hopper for reuse; spent (pulverized) media and paint dust are discharged to a drum for disposal. This waste normally is
characterized as hazardous because it contains concentrations of chromium, cadmium, and lead.
Alternative: Recycle and Reuse
Description
Plastic media that cannot be recovered through mechanical sorting could be recycled into other products. Vendors may be able to
accept the spent material and reprocess the material back into basic plastic materials. Other options include mixing the spent material with paint
to create a rough finish where needed, such as for a floor or other surface. Some companies rent the blasting media. When it becomes spent,
the vendors take the material back. The vendor then reprocesses or separates the usable material for inclusion as raw materials into other
products.
The advantage of recycling is the reduction or elimination of a waste stream. The disadvantages are that vendors may not be readily
available or capable of accepting the facility's specific waste stream.
4-14
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Pollution Prevention Opportunity Assessment Module
Dry Paint-Stripping Waste
WDCR828/027.WP5
4-15
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Pollution Prevention Opportunity Assessment Module
Battery Acid from Vehicle Maintenance
Waste Stream: Battery Acid
Operation: Vehicle Maintenance
Description
Battery acid is a main component of lead acid batteries from vehicles. Sulfuric acid typically is used in lead acid batteries. Military
installations have a high demand for batteries. There are two typical methods for handling battery acid from dead batteries: (1) draining the
battery and neutralizing the acid and (2) shipping the battery to a recycler without removing the acid. Potential environmental and safety
problems of battery acid are its corrosive nature and the typically high concentrations of lead. Use of metal equipment during draining
operations should be prohibited.
Alternative: Return wet batteries.
Description
If the current operating practice is to drain batteries, explore the opportunities for returning or recycling batteries with the acid still inside.
Returning wet batteries eliminates potential environmental problems from draining or treatment. The advantages include elimination of the acid
waste stream that contains corrosive waste and lead. The disadvantages may include the limited number of vendors that want to accept
batteries containing acid. Wet batteries also will require heated storage areas to prevent freezing and cracking of the batteries. This alternative
is more desirable if such a storage area is readily available.
WDCR828/046.WP5
4-16
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Pollution Prevention Opportunity Assessment Module
Radiator-Cleaning Wastes
Waste Stream: Radiator-Cleaning Wastes
Operation: Radiator Cleaning
Description
Spent radiator-cleaning solution must be disposed of as hazardous waste because of its heavy-metal content. Radiators are drained and
then cleaned by immersing them in a tank that is covered and heated. The tank is commonly called a "boil-out tank" or a "hot tank."
Radiator-cleaning solution, typically sodium hydroxide-based, is prepared from a powdered concentrate and added to the boil-out tank.
Depending on use, the radiator-cleaning solution is spent after 3 to 12 months of use. The buildup of dissolved oils and grease causes the
solution to become buffered. There usually is no visual indication of a loss in strength, such as buildup of floating oil and grease in the tank.
Increased foaming during heating can indicate a loss of strength. The spent solution typically contains up to 50,000 mg/L of lead at a pH of 11
to 12. The spent solution also contains solids, which normally settle to the bottom of the boil-out tank as sludge.
Alternative 1: Minimizing Change- Out of Boil- Out Tank
Description
The manufacturers of the cleaning solution typically state that the minimum change-out frequency is once per year. Depending on the
number of radiators cleaned, precleaning procedures, and bath maintenance, however, bath life can be extended to as long as 10 years. Sludge
should be shoveled from the boil-out tank weekly, and a maintenance charge of fresh chemical should be added to the bath every 2 weeks.
Bath life also can be extended by minimizing the buildup of oil and sludge by some combination of draining, rodding, flushing, or blowing
out radiators before they are inserted into the boil-out tank. Also important is removing as much oil as possible from the oil cooler before
insertion of the radiators into the boil-out tank.
Alternative 2: Reducing Waste Volume
Description
4-17
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Pollution Prevention Opportunity Assessment Module
Radiator-Cleaning Wastes
The volume of waste requiring disposal as a hazardous waste can be minimized by removing the bath and trapping the solids by settling
or filtration. The separated liquid can be returned to the tank for reuse. Alternatively, the boil-out tank can be outfitted with a side-stream
filter/strainer and pump to remove solids and oil from the bath, thereby minimizing sludge generation and extending bath life.
Another technique is to increase the temperature of the bath, open the bath cover, and evaporate as much of the bath as possible,
thereby minimizing the volume for disposal. The sludge may be removed by shovel, and the bath may be reused.
Alternative 3: Replacing Boil- Out Tank
Description
The volume of waste generated may be minimized by modifying or replacing the existing boil-out tank. Consideration should be given to
obtaining a smaller-volume boil-out tank capable of processing the same number of radiators. For example, 120-gallon tanks are available for
processing up to 64 radiators per day. The dimensions of the cleaning bath must be matched to each radiator's dimensions.
Ultrasonic cleaning tanks that use as low as 50 gallons of cleaning solution also are available.
Alternative 4: Sludge Dewatering
Description
The sludge generated by the boil-out tank probably is heavily contaminated with lead. Disposal cost can be minimized by removing as
much water as possible from the sludge. Sludge shoveled from the boil-out tank can be placed into drums and allowed to air-dry over time or
can be placed in 5-gallon buckets, allowing the solids to settle before decanting the liquid to the boil-out tank. A cloth or paper filter can be
used to separate the liquid from the solids. Sludge also can be dried in drums by using electric band drum heaters.
WDCR828/028.WP5
4-18
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Pollution Prevention Opportunity Assessment Module
Solid Waste
Waste Stream: Solid Waste
Operation: All Base Activities
Description
Solid waste is generated throughout INSTALLATION-XXX and is disposed of at to be inserted by installation A waste audit was
performed, and tons of solid waste were estimated as being generated in 19—.
Alternative 1: Modification of Purchasing Practices.
Description
Purchase products that are reusable and durable and that have reduced volume or weight.
1. Require suppliers to ship orders in reusable or returnable packaging, such as wooden pallets and polystyrene peanuts,
so that those items can then be reused in INSTALLATION-XXX packaging and shipping operations.
2. Install hot-air dryers or cloth-towel rolls instead of using paper towels in restrooms.
Alternative 2: Staff Education
Description
Educate staff to use fewer materials:
1. Use central bulletin boards or computer bulletin boards for memos, reports, and announcements instead of making one
copy for each staff member.
2. Use electronic mail.
4-19
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Pollution Prevention Opportunity Assessment Module
Solid Waste
3. Use double-sided copying.
4-20
-------
Alternative 3: Donation or Sale of Usable Materials.
Description
Donate or sell usable materials:
1. Donate leftover and surplus food to a food bank.
2. Identify and donate old supplies to a charity or a school or offer them for sale to staff or to the general public.
Alternative 4: Reduction of Yard Waste
Description
Reduce the amount of yard waste generated:
1. Recycle grass clippings by leaving them on the lawn and allowing them to decompose naturally.
2. Convert clippings, brush, and pruned branches to yard mulch.
Alternative 5: Office Recycling
Description
Reduce the amount of solid waste disposed of:
1. Recycle waste paper by locating recycling bins at copy machines and other locations. Equip each office with a separate
container for disposing of waste paper.
2. Recycle aluminum soft drink cans by locating recycling bins in kitchens, lunch rooms, break rooms, and other areas
where soft drink machines and refrigerators are located. Provide manual can compactor to reduce volume of waste and quantity of cans that
can be stored in the recycling bin.
4-21
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4-22
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Alternative 6: Residential Recycling
Description
Reduce the amount of solid waste disposed of by segregating the following from the trash for curbside pickup:
1. Newspapers
2. Aluminum Cans
3. Ferrous Cans
4. Glass
Alternative 7: Mixed-Waste Recycling
Description
Mixed-waste or back-end recycling relies on separating recyclables from a mixed-waste stream at a centralized processing facility on
the installation or off the installation if recycling is mandatory in the local community. Glass, plastic, aluminum cans, and ferrous cans can be
removed from the mixed-waste stream and recycled. Organic materials (food, yard waste, etc.) can be composted. Other remaining wastes
can be disposed of in a landfill or incinerated.
1. Newspapers
2. Aluminum Cans
3. Ferrous Cans
4. Glass
WDCR828/029.WP5
4-23
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Pollution Prevention Opportunity Assessment Module
Used Oil From Vehicle Maintenance
Waste Stream: Used Oil
Operation: Vehicle Maintenance
Description
Waste included under this general clarification are lubricating and hydraulic fluids generated from servicing vehicles and other equipment.
The major source of waste oil is the used motor oil generated by regular engine oil changes performed at motor pools. Oil changes routinely
are performed on a set schedule as determined by Army policy. Standard vehicles receive oil changes every 6 months or 6,000 miles. Special
vehicles are serviced every 400 to 600 operating hours. A single oil change can generate anywhere from 6 quarts for a gasoline engine in a
typical automobile to 33 gallons for a 12-cylinder diesel engine.
Alternative 1: Motor Oil Testing (to extend life)
Description
Generation of used oil can be reduced by extending the time between oil changes. The current oil change standards are based on
service-wide policy. However, the performance characteristics and life of motor oil varies, depending on the conditions under which the
equipment is operated.
In an oil analysis program, oil samples are collected at a set interval and are submitted to a field laboratory for analysis. Analyses
include a spectrometric test for metals and physical tests for water content, viscosity, and other contaminants.
Alternative 2: On-Board Bypass Filtration
Description
Most internal-combustion engines are equipped with a full-flow oil-filtration system. In this type of system, all of the oil that lubricates
the engine first passes through an oil filter. The filter must be quite porous for the oil to pass at the required flow rate, so the filter is designed to
remove only relatively large particles (larger than 40 microns) that could seriously damage an engine. Other contaminants that could degrade the
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Pollution Prevention Opportunity Assessment Module
Used Oil From Vehicle Maintenance
oil's protective properties, create sludge, and cause engine wear, such as metals, microscopic dirt and carbon particles, and water, pass through
readily.
A bypass filter system consisting of a much less porous element slowly filters a portion of the oil flow (usually less that 1/2 gpm
compared with the 4 to 5 gpm that is typical for a full-flow oil filter). Oil is drawn from the bottom of a crankcase, passed through the bypass
filter, and returned to the crankcase. Some bypass filters remove not only solids to the submicron level but also moisture.
Oil analyses have shown that a properly serviced bypass oil filter system can maintain motor oil in a condition where it need not be
replaced. These systems have been shown to prolong engine life. Bypass filtration appears to be particularly effective on expensive large
engines.
One filter system uses inexpensive paper-towel rolls as filter elements. These filters remove particulate contaminants down to 1 micron
and reduce moisture to less than 40 ppm. Filter changes are recommended at 5,000 to 10,000 miles.
Alternative 3: Burning in Space Heaters
Description
Specially designed space heaters are available that can burn used oil and similar waste streams, such as automatic-transmission fluid,
with little or no pretreatment. The heat generated from burning the waste oil is used for space heating, saving on disposal costs and lowering
heating-fuel costs.
A typical space heater that burns used oil can generate between 150,000 and 500,000 BTU/hour by burning from 1 to 3.6 gallons of oil
per hour. The heaters generally are located in a vehicle maintenance facility where the oil is produced.
Federal regulations for burning used oil in space heaters are addressed in 40 CFR 279 Subpart C. On-specification used oil generated
on the site can be burned in space heaters without restriction. Off-specification used oil can be burned only if the oil is generated on the site, the
heater has a maximum capacity of 500,000 BTU/hour, and combustion gases are vented to the ambient air. Hazardous oil cannot be burned in
space heaters.
Alternative 4: Offsite Oil Rerefining
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Description
Rerefining involves processing used lubricating oil to return it to virgin oil specifications so that it can be reused as a motor oil. Rerefining
involves elaborate and expensive processing and is therefore only feasible as an offsite recycling program, handled either through a broker or
directly with a rerefining facility. Current rerefining techniques include filtration, heating, settling, flash dehydration, vacuum stripping, and vacuum
distillation.
WDCR828/030.WP5
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Pollution Prevention Opportunity Assessment Module
Used Oil Filters From Vehicle Maintenance
Waste Stream: Used Oil Filters
Operation: Vehicle Maintenance
Description
Used oil filters are generated during the regular maintenance of vehicles and equipment. DOD establishes the policy that dictates
scheduled intervals. Normally, standard vehicles receive oil changes every 6 months or 6,000 miles. Special vehicles are serviced every 400 to
600 operating hours. Oil filters normally are changed as an integral part of the oil change.
Federal regulations covering the disposal of used oil filters are in 40 CFR 261. The regulations require that used oil filters be tested for
toxicity characteristics and disposed of accordingly. However, an exemption from testing is provided for non-tin-lead alloy plated used filters
that are drained in any of the following ways:
puncturing the filter and hot-draining for 12 hours
hot-draining for 12 hours and crushing
dismantling and draining for 12 hours
using an equivalent oil-draining method that removes used oil
Alternative 1: Crush filters to reduce volume.
Description
Used filters are drained of as much oil or fuel as possible and then are crushed and disposed of in 55-gallon drums. This can be
accomplished in a specially designed filter crusher. Filter draining and crushing is done for several reasons. First, it separates the liquid oil waste
from the solid filter to the greatest extent possible. Second, it compacts the filter and allows more filters to be disposed of in each drum, thereby
reducing the number of drums and pounds for disposal.
Alternative 2: Recycle off the site.
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Pollution Prevention Opportunity Assessment Module
Used Oil Filters From Vehicle Maintenance
Description
Recycling vendors for oil filters operate in many parts of the country. They process spent filters by shredding them and then separating
the paper element from the metal casing. The metal casing is recycled as scrap metal, and the paper is disposed of or burned as a fuel. Most
recyclers require that filters be drained for 12 hours and that they not be crushed.
Alternative 3: Separate filter elements and recycle metal.
Description
Oil filters can be cut open, and the paper element can be removed from the casing. The metal casing then can be drained and sold as
scrap metal. There is an oil filter element cutter that, like a large can opener, cuts the bottom off the filter casing so that the element can be
removed.
WDCR828/031.WP5
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Pollution Prevention Opportunity Assessment Module
Used Antifreeze From Vehicle Repair and Maintenance
Waste Stream: Used Antifreeze
Operation: Vehicle Repair and Maintenance
Description
Used antifreeze is generated during repair and maintenance of gasoline and diesel engines. Antifreeze becomes a waste when it no
longer meets the specifications required to perform its intended purpose (temperature and corrosion protection). Disposal and replacement are
rarely based on performance; instead, they are based on engine running time or mileage.
Although antifreeze is not by itself regulated as a hazardous waste, contaminants, such as heavy metals, can make it hazardous.
Alternative 1: Antifreeze Testing (to extend life)
Description
Antifreeze properties that typically would be tested include specific gravity, freezing point, boiling point, pH, general corrosivity,
aluminum corrosivity, and foaming. The American Society for Testing and Materials (ASTM) has established standard specifications for
properties of antifreeze for automobile and light-duty engines and for heavy-duty engines. The standards and the ASTM test methods used to
determine them are shown in Table 1.
Antifreeze testing can be applied through several types of programs. For large engines, such as power generators, when the appropriate
laboratory facilities are available, it may be cost-effective to test antifreeze on an engine-by-engine basis. At regular intervals, samples would be
collected and tested. Antifreeze not meeting specifications would be replaced, and the used antifreeze would be recycled or disposed of.
A less-extensive program would involve testing antifreeze samples from representative vehicles in a motor pool to establish an average
antifreeze life for each vehicle class. On the basis of test results, a schedule for changing the antifreeze of all vehicles in that class would be
implemented.
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Pollution Prevention Opportunity Assessment Module
Used Antifreeze From Vehicle Repair and Maintenance
A third type of program would involve changing antifreeze on a regular basis and consolidating and testing the used antifreeze from a
number of vehicles. Test results would govern whether the antifreeze would be reused, recycled, or disposed of.
Table 1
ASTM ANTIFREEZE SPECIFICATIONS
Parameter
Freezing point °F (°C)
(50% volume in distilled water)
Boiling point °F (°C)
(50% volume in distilled water)
pH
(50% volume in distilled water)
Chloride (ppm)
Corrosion in glassware
(weight loss, mg/specimen)
Copper
Solder
Brass
Steel
Cast Iron
Aluminum
Corrosion of cast aluminum
(mg/cm2/week)
Range
-34 (-37)
226 (107)
7.5 to 11.0
25 maximum
10 maximum
30 maximum
10 maximum
10 maximum
10 maximum
30 maximum
1.0 maximum
ASTM Test Method
D 1177
D 1120
D 1287
D3634
D 1384
D4340
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Foaming tendency
(volume, ml)
150 maximum
D 1881
Source: Reference 8
Alternative 2: Onboard Recycling
Description
Onboard recycling involves the use of filter systems that are installed on the engine. Antifreeze traveling through the engine cooling
system is filtered to remove contaminants that adversely affect its properties. Onboard filtration systems can be either full-flow or bypass.
Supplemental coolant additives can be added on a regular basis to replace corrosion and foam inhibitors.
Onboard filtration is particularly effective and often is necessary for long-running heavy-duty gasoline and diesel engines that need
antifreeze to be maintained in prime condition to protect expensive components and reduce maintenance cost and vehicle downtime. This
technology has been used in this application for more than 25 years. Most engines are not factory-equipped with onboard filters; typically, the
filters are installed by the owner. Recommended coolant life can be as long as 240,000 engine miles when onboard recycling is used, compared
with 36,000 to 40,000 miles when it is not. Onboard filtration has not been used much on automobiles and light trucks because it is not cost-
effective. For small engines, off-board recycling technologies appear to be more useful.
Alternative 3: Antifreeze Recycling
Description
Off-specification antifreeze often can be restored through simple physical processes that remove contaminants and through replacement
of chemical additives. Specific recycling methods that are seeing relatively widespread use include:
standard particle filtration
ultrafiltration
distillation
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In standard particle filtration, multistage filters in the 5- to 25-micron range are used to remove solids, such as dirt, rust, and suspended
metals, that can act as abrasives and cause engine wear. This can be followed up with ion exchange, which removes dissolved metals that cause
corrosion, or with aeration/filtration, which removes oils that can affect the freezing and boiling point or increase foaming. Additives usually must
be added to precipitate out metals, reduce foam, and restore color. Virgin antifreeze can be added to lower the freezing point.
Several types of standard filtration systems are available in the automotive repair industry. Large stationary fleet-sized treatment units
operate in 50- to 100-gal batches. The units can be set up to draw used antifreeze from a feed drum or a small tank, treat it, and discharge the
recycled product to a second container. Portable units are available that can be hooked up directly to a vehicle's radiator. With all of these
filtration units, filter elements must be replaced regularly and often have to be disposed of as a hazardous waste.
Another type of filtration system for antifreeze recently has been developed at the request of the U.S. Air Force. This relatively simple
system uses rolls of household paper towels as elements and can remove particles smaller than 1 micron. The filters can be mounted on a
portable skid or trailer and used throughout a maintenance facility to recycle antifreeze that has been collected in containers, or the filters can be
attached directly to the engine to provide continuous filtration during engine use.
Ultrafiltration uses a multistage filtration process where the initial filter typically is in the 5-micron range and the final filter is in the 0.001-
micron range. Ultrafiltration is designed to remove molecular-size contaminants, such as sulfates and chlorides, which are the primary causes of
corrosion.
There is an Ultrafiltration unit that uses 5- and 0.0025-micron filters. This device is reportedly capable of restoring antifreeze to meet all
applicable ASTM standards, including corrosion. As with other antifreeze-recycling technologies that use filtration, additives and new antifreeze
must be added to restore some properties.
Antifreeze distillation is a two-step process. In the first step, water is distilled under atmospheric pressure. In the second step, ethylene
glycol is distilled under a vacuum. The two streams are condensed separately and collected in drums as processed ethylene glycol and distilled
water. Dissolved and suspended solids and other contaminants remain in the process vessel and are disposed of. The recycled ethylene glycol
then can be mixed with the proper amount of distilled water and additives and can be reused.
A batch-operated still, applicable for use in a maintenance garage, will operate in 15- to 20-gal batches. Each batch takes 10 to 15
hours to treat and generates 0.5 to 1 gal of still bottoms requiring disposal.
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WDCR828/032.WP5
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Pollution Prevention Opportunity Assessment Module
Halon Use in Fire Extinguishers
Waste Stream: Halons
Operation: Portable Fire Extinguishers
Description
Halon is used as a liquid fire suppressant (streaming agent) in portable fire extinguishers. The fire extinguishers are used for To be
inserted by installation. Approximately of these units are located throughout INSTALLATION-XXX, containing approximately
pounds of Halon. Approximately pounds of halons are emitted during testing of the fire extinguishers.
Alternative 1: Discontinue testing of fire extinguishers containing Halon.
Description
Testing of fire extinguishers containing Halons will be discontinued. Alternative chemicals and methods are available for testing.
Alternative 2: Substitute fire suppressant.
Description
Carbon dioxide, water, dry-chemical, or foam portable fire extinguishers are currently available. Therefore, complete replacement of
portable fire extinguishers using halon could be accomplished in the short term.
WDCR828/033.WP5
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Pollution Prevention Opportunity Assessment Module
Refrigerants (CFCs) from Refrigeration,
Cooling-Equipment Maintenance
Waste Stream: Refrigerants (CFCs)
Operation: Refrigeration, Cooling-Equipment Maintenance
Description
Chlorofluorocarbons (CFCs) are used as heat-transfer fluids in the refrigeration cycle of air conditioners, freezers, and refrigerators.
The refrigerant remains in a sealed system throughout the refrigeration cycle and is not emitted until the unit is disposed of, although small
quantities may leak from the system or be emitted during servicing. The Clean Air Act Amendments require capture and recycling of
refrigerants during servicing operation. The Clean Air Act Amendments and DOD Directive 6050.9 require phasing out various CFCs.
Alternative 1: CFC Substitution
Description
Much research has been and is being performed on finding replacements for CFCs. The advantage to CFC replacements is the
reduced use of ozone-depleting chemicals. Reducing CFC use will comply with regulatory requirements and DOD directives.
Two problems are associated with CFC substitution. Replacement compounds not requiring retrofitting of equipment are not
commercially available, and replacements that are available require equipment modification.
Fluoroiodocarbons recently were announced as true "drop-in" replacements for CFCs. However, these compounds are still
undergoing testing and are not expected to be available for commercial use until 1996.
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Pollution Prevention Opportunity Assessment Module
Refrigerants (CFCs) from Refrigeration,
Cooling-Equipment Maintenance
Most of the alternative refrigerants proposed and marketed today require physical retrofits of the equipment and the lubricants. They
are less efficient than the CFCs they are replacing, which can lead to the need to replace existing equipment with higher-capacity equipment to
accomplish the same level of service.
Substitute refrigerants include the following:
HCFC-123 or HCFC-124 for CFC-11
HFC-134a or HCFC-22 for CFC-12
HFC-125 or HCFC-22 for CFC-502
Alternative 2: CFC Recycling
Description
CFCs, like other solvents, can by recycled through distillation. The CFCs must be removed from the equipment by certified technicians
using registered equipment. The CFCs then are reprocessed either on the site or off the site, using distillation technology. The CFCs removed
from the equipment will be replaced with recycled CFCs. The advantage of CFC recycling is that it allows continued use of equipment until a
suitable CFC replacement is commercially available, and no new supplies of CFCs will have to be purchased. The disadvantage is that DOD is
directing the phase-out of ozone-depleting chemicals, so reusing CFCs contradicts regulatory and DOD requirements. The availability of CFC
recyclers also may be a hindrance to this alternative.
WDCR828/047.WP5
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Section 5
Pollution Prevention Implementation
The following plan was developed to implement the pollution prevention options that have been determined to be feasible. Pollution prevention
projects are separated into three categories:
Past Pollution Prevention Proj ects
Current Pollution Prevention Projects
Future Pollution Prevention Proj ects
Current and future pollution prevention projects are summarized in Table 5-1.
The installation should demonstrate management commitment to P2 by giving the dollars spent on P2 and P2 activities in the past and projected
expenditures for the future.
In this section, discuss how P2 success has been measured in past efforts and how it will be measured in the future. Note that units of
measurement should take into account production levels so that P2 is not accomplished simply by reducing the workload.
In this section, identify barriers expected. Barriers include institutional (mission priorities, MILSPECS), financial, technical, and regulatory.
Identify how the installation will find ways to reduce the effect of the barriers during implementation of P2. The following procedures can be
tried to overcome the barriers.
Institutional Barriers
Institutional barriers can be overcome by raising the environmental awareness of the troops, civilian employees, contractors, and tenant
organizations. Methods of accomplishing this include the following:
• Installation Commander's pollution prevention directives
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Pollution prevention news stories in post newspaper
Outreach bulletins from environmental groups
Pollution prevention training
; Clear definition of communication channels between groups
Financial Barriers
Financial barriers can be overcome by demonstrating that a pollution prevention project will result in a cost saving. Tools that may help in
overcoming economic stumbling blocks include the following:
• Selecting projects with the greatest "bang for the buck"
; Using well-defined economic analyses. POD has guidelines on economic analysis in POD Initiative 7041 3, "Economic
Analysis and Program Evaluation for Resource Management."
; Investigating alternative funding sources - IC's discretionary funds, recycling proceeds, O&M funds
Technical Barriers
Technical barriers can be overcome by attempting the following:
; Include installation's best technical expertise (personnel who operate the processes) during assessment evaluation, planning, and
implementation of P2 options.
; Include other expertise on the installation (civil engineering, logistics, design, maintenance).
; Consult with organizations external to the installation (your major Command, other Commands, Corps of Engineers).
Regulatory Barriers
Typical environmental regulations emphasize control, treatment, and end-of-pipe treatments. It may be difficult to break the thinking of doing
only what is necessary to come into regulatory compliance. Try to be proactive and take a multimedia approach. Determine the regulatory
effects on all media of implementing a P2 project.
Note awards and incentives offered, both Army-wide (POD P2 awards) and within the installation. Available awards include the following:
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; ASA(FM) has an Army-wide hazardous waste reduction award program.
; Each installation is required to have an incentive award for encouraging and promoting maximum awareness of the installation's
P2 program.
; The Secretary of Defense presents an annual award to the POD installation that has achieved noteworthy improvements in
environmental quality in the preceding 2 years. An individual award is given to the military or civilian employee who has made the most
significant contribution to the environmental quality program during the preceding 2 years.
; The Secretary of the Army presents an environmental quality award to the individual and the installation that have shown the
most noteworthy contributions toward protecting and preserving the quality of the environment during the preceding 2 years (see AR 200-1 for
nominating procedures).
Past Pollution Prevention Projects
The status of past pollution prevention projects are discussed. Each project will be described to include location implemented, implementation
date, targeted waste type (e.g., hazardous waste, EPA Toxic 17 Wastes, ozone-depleting chemicals), actual waste reduction, actual
implementation costs, actual savings, and funding sources. The following example is provided for guidance.
Project Title: Paint-Booth Conversion to Dry Filtration
Description: Paint-booth scrubber sludge was eliminated through installation of dry filters. Filters are replaced on a month interval.
Location: Paint booths in Motor Pool , Building
Implementation Date: December 10, 1993
Targeted Waste Type(s): Hazardous Wastes, Waste Solvents
Waste Reduction: 19,000 Ibs/year
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4-34
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Implementation Costs: Parts and Labor: $9,500
Savings: Elimination of the waste stream has saved the installation $6,000 per year in reduced waste disposal cost.
Funding Source: O&M account
Current Pollution Prevention Projects
The status of currently funded pollution prevention projects are discussed next. Each project will be described to include location to be
implemented, anticipated implementation date, targeted waste type (e.g., hazardous waste, EPA Toxic 17 Wastes, ozone-depleting chemicals),
expected waste reduction, estimated implementation costs, estimated savings, and funding sources. The following example is provided for
guidance.
Project Title: Antifreeze Recycling
Description: Used antifreeze from nontactical vehicles is disposed of as a waste, sometimes as a characteristic hazardous waste. Planned
equipment is a used-antifreeze filtration system, which will allow used antifreeze to be filtered and returned to the vehicle.
Location: Motor Pool , Building
Implementation Date: CY 1994
Targeted Waste Type(s): Hazardous Wastes, Solid Wastes
Waste Reduction: 5,000 Ibs/year
Implementation Costs: $7,200
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Savings: Elimination of the waste stream has saved the installation $1,000 per year in reduced costs of waste-antifreeze disposal and drum and
drum handling.
Funding Source: O&M account
Future Pollution Prevention Projects
The status of proposed pollution prevention projects is discussed next. Each project will be described to include location to be implemented,
anticipated implementation date, targeted waste type (e.g., hazardous waste, EPA Toxic 17 Wastes, ozone-depleting chemicals), expected
waste reduction, estimated implementation costs, estimated savings, and funding sources. The following example is provided for guidance.
Project Title: Cardboard Balers
Description: The installation will be able to recycle corrugated cardboard currently disposed of in an off-base landfill. The corrugated
cardboard will be collected by Recycling Program employees, baled at the recycling center, and sold.
Location: Recycling Center
Implementation Date: CY 1995
Targeted Waste Type(s): Solid Wastes
Waste Reduction: 400,000 Ibs/year
Implementation Costs: $99,000
Savings: Waste Reduction - $10,000/year
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Cardboard Sales - $20,000/year
Total Savings - $30,000/year
Funding Source: Capital account
1383 Status: Submitted
WDCR828/049.WP5
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Table 5-1
INSTALLATION-XXX POLLUTION PREVENTION IMPLEMENTATION PLAN
Project Title
Cardboard Baler
Location
Recycling Center
Waste Type
Solid Waste
Reduction
Expected
(Ibs./year)
400,000
Estimated
Cost ($)
$99,000
Estimated
Savings
($/yr.)
$30,000
Expected
Implemen-
tation Date
CY95
1383
Status
Entered
5-38
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WDCR828/048.WP5
5-39
4-39
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Section 6
Annual Pollution Prevention Reporting
To assess progress in achieving the installation's pollution prevention goals, the following reports will be generated annually and are in this P2
plan:
Annual Hazardous Waste Generation Report (Table 6-1)
Annual EPA Toxic 17 Waste Generation Report (Table 6-2)
Annual Solid Waste Generation Report (Table 6-3)
Annual Ozone-Depleting Chemicals (ODCs) Usage Report (Table 6-4)
Annual Toxics Release Inventory Emissions Report (Table 6-5)
Annual Pollution Prevention Goals Achievement Report (Table 6-6)
In addition, the following report will be prepared and disseminated to identify the costs of hazardous waste disposal.
Annual Hazardous Waste Cost Allocation Report (Table 6-7)
The goal of INSTALLATION-XXX is to charge individual operations for the costs of managing and disposing of their hazardous wastes.
WDCR828/008.WP5
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199
Table 6-1
ANNUAL HAZARDOUS WASTE GENERATION AT INSTALLATION-XXX
Page 41 of 3
Waste Type
1. Solvent
Wastes
2. Acids &
Bases
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
6-41
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Table 6-1
199 ANNUAL HAZARDOUS WASTE GENERATION AT INSTALLATION-XXX
Page 41 of 3
Waste Type
3 . Wastewater
Treatment
Sludges
4. Fuels
5.
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
6-42
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Table 6-1
199 ANNUAL HAZARDOUS WASTE GENERATION AT INSTALLATION-XXX
Page 41 of 3
Waste Type
6.
7.
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
6-43
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Table 6-1
199 ANNUAL HAZARDOUS WASTE GENERATION AT INSTALLATION-XXX
Page 41 of 3
Waste Type
8.
9.
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
6-44
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Table 6-1
199 ANNUAL HAZARDOUS WASTE GENERATION AT INSTALLATION-XXX
Page 41 of 3
Waste Type
10.
11.
12.
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
6-45
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199
Table 6-1
ANNUAL HAZARDOUS WASTE GENERATION AT INSTALLATION-XXX
Page 41 of 3
Waste Type
TOTAL
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
100 %
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
WDCR828/017.WP5
6-46
4-46
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199
Table 6-2
ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 47 of 5
Waste Type
1 . Benzene
2. Cadmium &
compounds
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
6-47
4-47
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199
Table 6-2
ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 47 of 5
Waste Type
3. Carbon
Tetrachloride
4. Chloroform
5. Chromium &
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
6-48
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Table 6-2
199 _ ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 47 of 5
Waste Type
compounds
6. Cyanides
7. Dichloromethane
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
6-49
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199
Table 6-2
ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 47 of 5
Waste Type
8. Lead & compounds
9. Mercury &
compounds
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
6-50
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199
Table 6-2
ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 47 of 5
Waste Type
10. Methyl Ethyl
Ketone
11. Methyl Isobutyl
Ketone
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
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Table 6-2
199 _ ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 47 of 5
Waste Type
12. Nickel &
compounds
13.
Tetrachloroethylene
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
6-52
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Table 6-2
199 _ ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 47 of 5
Waste Type
14. Toluene
15. Trichloroethane
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
6-53
4-53
-------
Table 6-2
199 _ ANNUAL EPA TOXIC 17 WASTE GENERATION AT INSTALLATION-XXX
Page 47 of 5
Waste Type
16. Trichloroethylene
17. Xylene
TOTAL
Waste
Code(s)
Waste
(Ibs)
%of
Total
Waste
100%
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight
by Shop
(Ibs)
% of Waste
Type
6-54
4-54
-------
WDCR828/018.WP5
6-55
4-55
-------
Table 6-3
1 99 SOLID WASTE GENERATION AT INSTALLATION-XXX
Page 56 of 3
Waste Type
1. Aluminum Cans
2. Corrugated
Cardboard
3. Office Paper
Waste
(Ibs)
% of Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight by
Shop (Ibs)
% of Waste
Type
6-56
4-56
-------
Table 6-3
1 99 SOLID WASTE GENERATION AT INSTALLATION-XXX
Page 56 of 3
Waste Type
4. Newspaper
5. Glass
Waste
(Ibs)
% of Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight by
Shop (Ibs)
% of Waste
Type
6-57
4-57
-------
Table 6-3
1 99 SOLID WASTE GENERATION AT INSTALLATION-XXX
Page 56 of 3
Waste Type
6. Ferrous Cans
7. Plastic (PET soft
drink
bottles, HDPE milk
jugs,
etc.)
Waste
(Ibs)
% of Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight by
Shop (Ibs)
% of Waste
Type
6-58
4-58
-------
Table 6-3
1 99 SOLID WASTE GENERATION AT INSTALLATION-XXX
Page 56 of 3
Waste Type
8. Yard Waste
9. Unclassified Waste
10. Engine Oils
Waste
(Ibs)
% of Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight by
Shop (Ibs)
% of Waste
Type
6-59
4-59
-------
Table 6-3
1 99 SOLID WASTE GENERATION AT INSTALLATION-XXX
Page 56 of 3
Waste Type
11. Engine Coolants
12.
Waste
(Ibs)
% of Total
Waste
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight by
Shop (Ibs)
% of Waste
Type
6-60
4-60
-------
Table 6-3
1 99 SOLID WASTE GENERATION AT INSTALLATION-XXX
Page 56 of 3
Waste Type
TOTAL
Waste
(Ibs)
% of Total
Waste
100%
Generator
Unit/Shop
Process or Operation
Generating Waste
Weight by
Shop (Ibs)
% of Waste
Type
WDCR828/019.WP5
6-61
4-61
-------
Table 6-4
199 USAGE OF OZONE-DEPLETING CHEMICALS (ODCS)AT INSTALLATION-XXX
Page 62 of 3
ODC Type
1 . Freons
2. Halons
3. Cleaning Solvents
Usage
(Ibs)
% of Total
Use
ODC
Compound
User/Shop
Process or Operation
Using ODC
Usage by
Shop (Ibs)
% of Type
Usage
6-62
4-62
-------
Table 6-4
199 USAGE OF OZONE-DEPLETING CHEMICALS (ODCS)AT INSTALLATION-XXX
Page 62 of 3
ODC Type
4. Paint Strippers
5.
Usage
(Ibs)
% of Total
Use
ODC
Compound
User/Shop
Process or Operation
Using ODC
Usage by
Shop (Ibs)
% of Type
Usage
6-63
4-63
-------
Table 6-4
199 USAGE OF OZONE-DEPLETING CHEMICALS (ODCS)AT INSTALLATION-XXX
Page 62 of 3
ODC Type
6.
7.
Usage
(Ibs)
% of Total
Use
ODC
Compound
User/Shop
Process or Operation
Using ODC
Usage by
Shop (Ibs)
% of Type
Usage
6-64
4-64
-------
Table 6-4
199 USAGE OF OZONE-DEPLETING CHEMICALS (ODCS)AT INSTALLATION-XXX
Page 62 of 3
ODC Type
8.
9.
10.
Usage
(Ibs)
% of Total
Use
ODC
Compound
User/Shop
Process or Operation
Using ODC
Usage by
Shop (Ibs)
% of Type
Usage
6-65
4-65
-------
Table 6-4
199 USAGE OF OZONE-DEPLETING CHEMICALS (ODCS)AT INSTALLATION-XXX
Page 62 of 3
ODC Type
11.
12.
Usage
(Ibs)
% of Total
Use
ODC
Compound
User/Shop
Process or Operation
Using ODC
Usage by
Shop (Ibs)
% of Type
Usage
6-66
4-66
-------
Table 6-4
199 USAGE OF OZONE-DEPLETING CHEMICALS (ODCS)AT INSTALLATION-XXX
Page 62 of 3
ODC Type
TOTAL
Usage
(Ibs)
% of Total
Use
100%
ODC
Compound
User/Shop
Process or Operation
Using ODC
Usage by
Shop (Ibs)
% of Type
Usage
WDCR828/020.WP5
6-67
4-67
-------
Table 6-5
199 ANNUAL TOXICS RELEASE INVENTORY (TRI) EMISSIONS FOR INSTALLATION-XXX
Page 68 of 3
TRI Chemical
1.
2.
3.
Code
Releas
e (Ibs)
%of
Total
Release
Generator
Unit/Shop
Process or Operation
Emitting
Weight
by Shop
(Ibs)
% of TRI
Chemical
6-68
4-68
-------
Table 6-5
199 ANNUAL TOXICS RELEASE INVENTORY (TRI) EMISSIONS FOR INSTALLATION-XXX
Page 68 of 3
TRI Chemical
4.
5.
Code
Releas
e (Ibs)
%of
Total
Release
Generator
Unit/Shop
Process or Operation
Emitting
Weight
by Shop
(Ibs)
% of TRI
Chemical
6-69
4-69
-------
Table 6-5
199 ANNUAL TOXICS RELEASE INVENTORY (TRI) EMISSIONS FOR INSTALLATION-XXX
Page 68 of 3
TRI Chemical
6.
7.
Code
Releas
e (Ibs)
%of
Total
Release
Generator
Unit/Shop
Process or Operation
Emitting
Weight
by Shop
(Ibs)
% of TRI
Chemical
6-70
4-70
-------
Table 6-5
199 ANNUAL TOXICS RELEASE INVENTORY (TRI) EMISSIONS FOR INSTALLATION-XXX
Page 68 of 3
TRI Chemical
8.
9.
10.
Code
Releas
e (Ibs)
%of
Total
Release
Generator
Unit/Shop
Process or Operation
Emitting
Weight
by Shop
(Ibs)
% of TRI
Chemical
6-71
4-71
-------
Table 6-5
199 ANNUAL TOXICS RELEASE INVENTORY (TRI) EMISSIONS FOR INSTALLATION-XXX
Page 68 of 3
TRI Chemical
11.
12.
Code
Releas
e (Ibs)
%of
Total
Release
Generator
Unit/Shop
Process or Operation
Emitting
Weight
by Shop
(Ibs)
% of TRI
Chemical
6-72
4-72
-------
Table 6-5
199 ANNUAL TOXICS RELEASE INVENTORY (TRI) EMISSIONS FOR INSTALLATION-XXX
Page 68 of 3
TRI Chemical
TOTAL
Code
Releas
e (Ibs)
%of
Total
Release
100 %
Generator
Unit/Shop
Process or Operation
Emitting
Weight
by Shop
(Ibs)
% of TRI
Chemical
WDCR828/053.WP5
6-73
4-73
-------
Table 6-6
INSTALLATION-XXX 199 _ POLLUTION PREVENTION ACHIEVEMENT REPORT
Waste Type
Hazardous Waste
Hazardous Waste
Hazardous Waste
Hazardous Waste
Solid Wastes
Ozone- Depleting
Chemical Use
TRI Chemicals
Subtype
EPA Toxic 17
Wastes
Solvent Wastes
Acids and Bases
Reduction Goal (%)
Baseline
(Ibs./year)
Current
(Ibs./year)
Achieved to Date
(%)
WDCR828/009.WP5
6-74
4-74
-------
Table 6-7
199 ANNUAL WASTE DISPOSAL COST ALLOCATION AT INSTALLATION-XXX
Page 75 of 3
Generator
Unit/Shop
Waste Type
Waste Code(s)
Disposed by Shop
(Ibs)
Unit Cost ($/lb.)
Disposal Cost ($)
TOTAL For Shop
2.
TOTAL For Shop
3.
6-75
4-75
-------
Table 6-7
199 ANNUAL WASTE DISPOSAL COST ALLOCATION AT INSTALLATION-XXX
Page 75 of 3
Generator
Unit/Shop
TOTAL For Shop
Waste Type
Waste Code(s)
Disposed by Shop
(Ibs)
Unit Cost ($/lb.)
Disposal Cost ($)
4.
TOTAL For Shop
5.
6-76
4-76
-------
Table 6-7
199 ANNUAL WASTE DISPOSAL COST ALLOCATION AT INSTALLATION-XXX
Page 75 of 3
Generator
Unit/Shop
TOTAL For Shop
Waste Type
Waste Code(s)
Disposed by Shop
(Ibs)
Unit Cost ($/lb.)
Disposal Cost ($)
6.
TOTAL For Shop
7.
6-77
4-77
-------
Table 6-7
199 ANNUAL WASTE DISPOSAL COST ALLOCATION AT INSTALLATION-XXX
Page 75 of 3
Generator
Unit/Shop
TOTAL For Shop
Waste Type
Waste Code(s)
Disposed by Shop
(Ibs)
Unit Cost ($/lb.)
Disposal Cost ($)
TOTAL For Shop
9.
TOTAL For Shop
6-78
4-78
-------
Table 6-7
199 ANNUAL WASTE DISPOSAL COST ALLOCATION AT INSTALLATION-XXX
Page 75 of 3
Generator
Unit/Shop
Waste Type
Waste Code(s)
Disposed by Shop
(Ibs)
Unit Cost ($/lb.)
Disposal Cost ($)
10.
TOTAL For Shop
11.
TOTAL For Shop
12.
6-79
4-79
-------
Table 6-7
199 ANNUAL WASTE DISPOSAL COST ALLOCATION AT INSTALLATION-XXX
Page 75 of 3
Generator
Unit/Shop
TOTAL For Shop
TOTAL
Waste Type
Waste Code(s)
Disposed by Shop
(Ibs)
Unit Cost (Wo.)
Disposal Cost ($)
WDCR828/021.WP5
6-80
4-80
-------
Appendix A
Abbreviations
AAFES
AR
CAAA90
COE
DA
DEH
DFE
DIG
DLA
DOD
DRMO
EO
EQCC
EPA
EPCRA
FAO
FOA
FE
Army, Air Force Exchange System
Army Regulation
Clean Air Act Amendment of 1990.
Corps Of Engineers
Department of the Army
Director of Engineering and Housing
Director of Facility Engineering
Director of Industrial Operations
Defense Logistics Agency
Department of Defense
Defense Reutilization and Marketing Office
Executive Order
Environmental Quality Control Committee
Environmental Protection Agency
Emergency Planning and Community Right-to-Know Act of 1986
Finance and Accounting Office
Field Operating Agency
Facility Engineer
6-81
4-81
-------
GMP
GOCO
HMIS
HWM
fflWM
1C
ISCP
MACOM
MCA
MEDDAC
MWR
O&M
PPAT
POL
PPOA
RCRA
SARA
SOP
SPCC Plan
TRI
TSCA
Good Management Practice
Government-Owned, Contractor-Operated
Hazardous Material Information System
Hazardous Waste Management
Installation Hazardous Waste Manager
Installation Commander
Installation Spill Control Plan
Major Army Command
Military Construction, Army
Medical Department Activity
Moral, Welfare, and Recreation
Operation and Maintenance
Pollution Prevention Assessment Team
Petroleum, Oil, and Lubricants
Pollution Prevention Opportunity Assessment
Resource Conservation and Recovery Act
Superfund Amendments and Reauthorization Act of 1986
Standard Operating Procedure
Spill Prevention Control and Countermeasures Plan
Toxics Release Inventory
Toxic Substance Control Act
6-82
4-82
-------
TSDF Treatment, Storage or Disposal Facility
TSG The Surgeon General
VOC Volatile Organic Compound
WDCR828/010.WP5
6-83
4-83
-------
B-84
4-84
-------
Appendix B
Definitions
B-85
4-85
-------
Appliance: Any device that contains and uses a Class I or Class n substance as a refrigerant and that is used for household or commercial
purposes, including any air conditioner, refrigerator, chiller, or freezer.
Cartridge Filter: A discrete filter unit containing both filter paper and activated carbon that traps and removes contaminants from petroleum
solvent, together with the piping and ductwork used in installing this device.
Characteristic Waste: The characteristics of ignitability, corrosivity, reactivity, and toxicity that identify hazardous waste.
Chemical Warfare Agent: A substance that because of its chemical properties is used in military operations to kill, seriously injure, or
incapacitate humans or animals or deny use of indigenous resources.
Container: Any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled.
Designated Facility: A hazardous waste treatment, storage, or disposal facility (TSDF) that is identified on a manifest as the destination of a
hazardous waste shipment. The facility must have an appropriate permit, have interim status, or be regulated under specific recycling
requirements.
Nonattainment Area: Any area designated as being in nonattainment with the National Ambient Air Quality Standard (NAAQS) for ozone
pursuant to rulemaking under section 107(d)(4)(A)(ii) of the CAA.
B-86
4-86
-------
Disposal: The discharge, deposit, injection, dumping, spilling, leaking, or placing of any solid waste or hazardous waste into or onto any land or
water so that such solid waste or hazardous waste or any constituent thereof may enter the environment or be emitted into the air or discharged
into any waters, including groundwaters.
EPA Hazardous Waste Number: The number assigned by USEPA to each hazardous waste listed in 40 CFR 261, Subpart D, and to each
characteristic identified in 40 CFR 261, Subpart C.
Facility: All contiguous land and structures, other appurtenances, and improvements on the land, used for treating, storing, or disposing of
hazardous waste. A facility may consist of several treatment, storage, or disposal operational units (i.e., one or more landfills, surface
impoundments, or combination of them).
Federally Enforceable: All limitations and conditions enforceable by the Administration, including those requirements developed pursuant to 40
CFR, requirements within any applicable state implementation plan, and any permit requirements established pursuant to 40 CFR.
Generator: Any person or group whose act or process produces hazardous waste identified or listed in 40 CFR 261 or whose act first causes a
hazardous waste to become subject to regulations.
Good Management Practice (GMP): A practice that, although not mandated by law, is encouraged to promote safe operating procedures.
Hazardous Waste: A solid waste, not specifically excluded from the restrictions of Federal regulation (42 USC 6901), that meets the criteria
listed in 40 CFR 261 or is specifically named as a hazardous waste in Federal regulations.
B-87
4-87
-------
Household Waste: Includes material discarded by single and multiple residential dwellings, hotels, motels, and other similar permanent or
temporary housing.
Incinerator: Any furnace used in the process of burning solid waste for the purpose of reducing the volume of the waste by removing
combustible matter.
Infectious Waste: 1. Equipment, instruments, utensils, and fomites of a disposable nature from the rooms of patients who are suspected to have
or have been diagnosed as having a communicable disease and who must therefore be isolated as required by public health agencies. 2.
Laboratory waste, such as pathological specimens and disposable fomites (any substance that may harbor or transmit pathological organisms).
3. Surgical operating room pathological specimens and disposable fomites attendant thereto and similar disposable materials from outpatient
areas and emergency rooms.
Landfill: A disposal facility or a part of a facility where waste is placed in or on land and that is not a land treatment facility, a surface
impoundment, an underground injection well, a salt bed formation, an underground mine, or a cave.
Hazardous Waste Management: The systematic control of the collection, source separation, storage, transportation, processing, treatment,
recovery, and disposal of hazardous waste.
Material-Tracking System: Each generator developing an in-house system to ensure that all hazardous materials and wastes are controlled from
purchase to release or disposal in order to reduce loss and spillage.
B-88
4-88
-------
Medical Waste: When defined as applicable to municipal waste combustors, any solid waste generated in the diagnosis, treatment, or
immunization of human beings or animals, in research pertaining thereto, or in production or testing of biological agents. Medical waste does not
include hazardous waste identified under RCRA-C or any household waste as defined in RCRA, subpart C.
Off-Specification Used Oil: Used oil burned for energy recovery and any fuel produced from used oil that exceeds the following allowable
limits:
Arsenic
Cadmium
Chromium
Lead
Flash Point
Total halogens
5 ppm max.
2 ppm max.
10 ppm max.
100 ppm max.
100 °F min.
4000 ppm max.
Particulate Emissions: Any airborne finely divided solid or liquid material, except uncombined water, emitted to the ambient air.
Pollution Prevention: Source reduction 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. Recycling, energy, treatment, and
disposal are not included in the definition of pollution prevention. However, some practices commonly described as "in-process recycling" may
qualify as pollution prevention. Examples might include solvent recycling, metal recovery from a spent plating bath, and recovery of volatile
organic compounds (VOCs).
B-89
4-89
-------
Qualifying Recycling Program: Organized operations that require concerted efforts to (a) divert or recover scrap or waste from waste streams;
(b) identify, segregate, and maintain the integrity of the recyclable materials to maintain or enhance the marketability of the material.
Recyclable Material: Material that normally has been or would be discarded (such as scraps and waste) and material that may be reused after
undergoing some type of physical or chemical processing. Recyclable materials may include discarded materials that have undergone
demilitarization or mutilation at an installation before being transferred to the property disposal office for sale. Recyclable materials do not
include (1) precious-metal-bearing scrap; (2) those items that may be used again for their original purpose or functions without any special
processing, such as used vehicles, vehicle or machine parts, bottles (not scrap glass), electrical components, and unopened containers of unused
oil or solvent.
Recycling: The process by which recovered materials are transformed into new or usable products.
Resource Recovery Facility: Any physical plant that processes residential, commercial, or institutional solid waste biologically, chemically, or
physically and recovers useful products (such as shredded fuel, combustible oil or gas, steam, metal, or glass) for resale or reuse.
Sludge: Any solid, semi solid, or liquid waste generated from a municipal, commercial, or industrial wastewater treatment plant, water supply
treatment plant, or air pollution control facility exclusive of the treated effluent from a wastewater treatment plant.
Source Reduction: Any practice that reduces the amount of any hazardous substance, pollutant, or contaminant entering any waste stream or
emitted to the environment (including fugitive emissions) before recycling, treatment, or disposal. The term includes equipment or technology
modifications, process or procedure modifications, reformulation or redesign of products, substitution of raw materials, and improvements in
housekeeping, maintenance, training, and inventory control.
B-90
4-90
-------
Source Separation: The setting aside of recyclable materials at their points of generation by the generator.
Sump: Any pit or reservoir that meets the definition of tank and the troughs or trenches connected to it that serve to collect hazardous waste for
transport to hazardous waste TSDFs, except that as used in the landfill, surface impoundment, and waste pile rules, "sump" means any lined pit
or reservoir that serves to collect liquids drained from a collection and removal system or a leak-detection system for subsequent removal from
the system.
Treatability Study: A study in which a hazardous waste is subjected to a treatment process to determine one or more of the following:
Whether the waste is amenable to the treatment process
What pretreatment, if any, is required
The optimal process conditions needed to achieve the desired treatment
The efficiency of a treatment process for a specific waste or wastes
The characteristics and volumes of residuals from a particular treatment process.
Treatment: Any method, technique, or process (including neutralization) designed to change the physical, chemical, or biological character or
composition of any hazardous waste.
B-91
4-91
-------
Used Oil: Any oil that has been refined from crude oil or any synthetic oil that has been used and as a result of such is contaminated by physical
or chemical impurities.
B-92
4-92
-------
Volatile Organic Compound (VOC): Any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides,
carbonates, and ammonium carbonate, that participates in atmospheric photochemical reactions.
WDCR828/011.WP5
B-93
4-93
-------
Appendix C
References
ENVIRONMENTAL PROTECTION AGENCY GUIDANCE
General Guidance
Waste Minimization Opportunity Assessment Manual, EPA/625/7-88/003, 1988.
Facility Pollution Prevention Guide, EPA/600/R-92/088, 1992.
Pollution Prevention in the Federal Government: Guide for Developing Pollution Prevention Strategies for Executive Order 12856
andBeyond,EPA/300/B-94/007, 1994.
Pollution Prevention andRight-to-Know in the Government: Executive Order 12856, EPA/100/K-93/001, 1993.
Setting Priorities for Hazardous Waste Minimization, EPA/530/R-94/015, 1994.
A Primer for Financial Analysis of Pollution Prevention Projects, EPA/600/R-93/059, 1993.
Pollution Prevention Act of 1990, Public Law 101-508, 1990.
Industry-Specific Guidance
These guides list source-reduction and recycling techniques for specific industries. The guides have been published by the Pollution Prevention
Research Branch of EPA's Office of Research and Development as a series of industry-specific pollution prevention guidance manuals.
C-94
4-94
-------
Industrial Category
EPA Document No.
Date
Automotive Refinishing Industry
Auto Repair Industry
The Commercial Printing Industry
The Fabricated Metal Industry
Fiberglass Reinforced and Composite Plastics
Marine Maintenance and Repair
The Paint Manufacturing Industry
The Pesticide Formulating Industry
Pharmaceutical Preparation
Photoprocessing Industry
Printed Circuit Board Manufacturing Industry
Research and Educational Institutions
Selected Hospital Waste Streams
Mechanical Equipment Repair Industry
Metal Casting and Heat Treating Industry
Metal Finishing Industry EPA/625/R- 92/011
EPA/625/7-91/016
EPA/625/7-91/013
EPA/625/7-90/008
EPA/625/7-90/006
EPA/625/7-91/014
EPA/625/7-91/015
EPA/625/7-90/005
EPA/625/7-90/004
EPA/625/7-91/017
EPA/625/7-91/012
EPA/625/7-90/002
EPA/625/7-90/010
EPA/625/7-90/009
EPA/625/R-92/008
EPA/625/R-92/009
10/91
10/91
1990
7/90
1991
1991
1990
1990
1991
1991
1990
6/90
6/90
1992
1992
1992
C-95
4-95
-------
Fact Sheets
The following fact sheets contain overviews, tips, or guidelines for pollution prevention. Some provide only general information or advice on
how to set up programs; others identify pollution prevention opportunities for specific industries, processes, or materials. EPA, state agencies,
and local governments produced the fact sheets. In many cases, multiple sources have published fact sheets on particular topics. Fact sheets on
the topic areas below are available from the EPA library, 401 M Street, SW, Washington DC 20460 (202/260-1963). The source of this
information is Pollution Prevention Resources and Training Opportunities in 1992, EPA, Office of Pollution Prevention and Toxics and
Office of Environmental Engineering and Technology Demonstration, EPA/5650/8-92-002, January 1992.
FACT SHEETS
General and Introductory Information
Conservation Tips for Business
General Guidelines
Getting More Use Out of What We Have
Glossary of Waste Reduction Terms
Guides to Pollution Prevention
Hazardous Waste Fact Sheet for Minnesota Generators
Hazardous Waste Minimization
How Business Organizations Can Help
Increase Your Corporate and Product Image
C-96
4-96
-------
Industrial Hazardous Wastes in Minnesota
Local Governments and Pollution Prevention
Pollution Prevention (General)
Pollution Prevention Fees
Pollution Prevention Training and Education
Pollution Prevention Through Waste Reduction
Recent Publications
Reduce Hazardous Waste
Reuse Strategies for Local Government
Source Reduction Techniques for Local Government
U.S. EPA's Pollution Prevention Program
Video Tapes Available from the Virginia Waste Minimization Program
Waste Exchanges: Everybody Wins!
Waste Exchange Services
Waste Minimization Fact Sheet
Waste Minimization in the Workplace
Waste Reduction Can Work For You
Waste Reduction Overview
Waste Reduction/Pollution Prevention: Getting Started
Waste Reduction Tips for All Businesses
Waste Source Reduction
Waste Source Reduction Checklist
C-97
4-97
-------
What is Pollution Prevention
Why Reduce Waste?
Legislative Information/EPA and State Initiatives
About Minnesota's "But Recycled Campaign"
Alaska State Agency Waste Reduction and Recycling
EPA's 2 % Set Aside Pollution Prevention Projects
C-98
4-98
-------
EPA's "List of Lists" Projects
EPA's Pollution Prevention Enforcement Settlement Policy
EPA's Pollution Prevention Incentives for States
EPA's Pollution Prevention Strategy
Introducing the Colorado Pollution Prevention Program
Michigan's Solid Waste Reduction Strategy
Minnesota's Toxic Pollution Prevention Act
New Form R Reporting Requirements
Oregon's Toxic Use Reduction Act
Pollution Prevention Act of 1990
Promoting Pollution Prevention in Minnesota State Government
Setting Up A Program
1991 Small Business Pollution Prevention Grants
An Organization Strategy for Pollution Prevention
Considerations in Selecting a Still for Onsite Recycling
Colorado Technical Information Center
Onsite Assistance (Colorado only)
Pollution Prevention Grant Program Summaries and Reports
Procuring Recycled Products
Recycling Market Development Program
C-99
4-99
-------
Selecting a Supplier, Hauler, and Materials Broker
Solid Waste Management Financial Assistance Program
Source Reduction at Your Facility
Starting Your Own Waste Reduction Program
The Alexander Motor's Success Story
The Eastside Plating Success Story
The Wacker Payoff
C-100
4-100
-------
Waste Reduction Checklists
- General
- Cleaning
- Coating/Painting
- Formulating
- Machining
- Operating Procedures
- Plating/Metal Finishing
Waste Source Reduction: Implementing a Program
Process/Material Specific
Aerosol Containers
Aircraft Rinsewater Disposal
Acids/Bases
Chemigation Practices to Prevent Groundwater Contamination
Corrugated Cardboard Waste Reduction
Demolition
Empty Containers
Gunwasher Maintenance
Lead Acid Batteries
Machine Coolants:
C-101
4-101
-------
- Prolonging Coolant Life
- Waste Reduction
Metal Recovery:
- Dragout Reduction
- Ion Exchange/Electrolytic Recovery
- Etchant Substitution
Old Paints, Inks, Residuals, and Related Materials
Pesticides:
- Disposal of Unused Pesticides, Tank Mixes, and' Rinsewater
- In-Filled Sprayer Rinse System to Reduce Pesticide Wastes
- Pesticide Container Disposal
- Preventing Pesticide Pollution of Surface and Groundwater
- Preventing Well Contamination by Pesticides
- Protecting Mountain Springs from Pesticide contamination
- Reducing and Saving Money Using Integrated Pest Management
Metals Recycling
Office Paper Waste Reduction
Plastics:
- The Facts About Production, Use, and Disposal
- The Facts on Degradable Plastics
- The Facts on Recycling Plastics
- The Facts on Source Reduction
C-102
4-102
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Printing Equipment
Refrigerant Reclamation Equipment/Services
Reverse Osmosis
Safety Kleen, Inc. Users
Shop Rags from Printers
Small Silver Recovery Units
Solvents:
- Alternatives to CFC-113 Used in the Cleaning of Electronic Circuit Boards
- Onsite Solvent Reclamation
- Reducing Shingle Waste at a Manufacturing Facility
- Reducing Solvent Emissions from Vapor Degreasers
- Small Solvent Recovery Systems
- Solvent Loss Control
- Solvent Management: Fiber Production Plant
- Solvent Reuse: Technical Institute
- Trichloroethylene and Stoddard Solvent Reduction Alternatives
- Solvent Recovery: Fiber Production Plant
- Solvent Reduction in Metal Parts Cleaning
Ultrafiltration
Used Containers: Management
Used Oil Recycling
Waste Management Guidance for Oil Cleanup
C-103
4-103
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Water and Chemical Reduction for Cooling Towers
Waste Water Treatment Opportunities
Industry- Specific
Aerospace Industry
Auto Body Shops
Automotive Painting
Automotive/Vehicle Repair Shops
Auto Salvage Yards
Asbestos Handling, Transport, and Disposal
Chemical Production
Coal Mining
Concrete Panel Manufacturers
Dairy Industry:
- Cut Waste and Reduce Surcharges for Your Dairy Plant
- Dairy CEO's: Do You Have a $500 Million Opportunity?
- Liquid Assets for Your Dairy Plant
- Water and Wastewater Management in a Dairy Processing Plant
Dry Cleaners
Electrical Power Generators
Electroplating Industry:
C-104
4-104
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- Dragout Management for Electroplaters
- Plating 'with Trivalent Chrome Instead of CR+6
- Water Conservation Using Counter Current Rinsing
- Water Conservation: Tank Design
- Water Conservation: Rinsewater Reuse
- What Should I Do With My Electroplating Sludge ?
Fabricated Metal Manufacturers
Fiberglass Fabricators: Volatile Emissions Reduction
Machine Toolers
C-105
4-105
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Metal Finishers:
- General
- Effluent Minimization
- Rinsewater Reduction
Oil Refiners
Paint Formulators
Paper Manufacturers
Pesticide Formulating Industry
Photofmishers/Photographic Processors
Poultry Industry:
- Poultry CEO's: Do You Have a $60 Million Opportunity?
- Poultry Processor: You Can Reduce Waste Load and Cut Sewer Surcharges
- Survey Shows That Poultry • Steel Manufacturers
Processors Can Save Money By • Textile Industry:
Conserving Water - Dye Bath and Bleach Bath
- Systems for Recycling Water in Reconstitution
Poultry Processing - Water Conservation
Printed Circuit Board • Wire Milling Operations: Process
Manufacturers Water Reduction
Printing Industry
Radiator Service Firms
Shrimp Processors
C-106
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U.S. ARMY GUIDANCE
General Assistance
U.S. Army Construction Engineering Research Laboratory. P.O. Box 4005, Champaign, IL, 61820. 800-USA-CERL.
U.S. Army Cold Regions Research and Engineering Laboratory (CECRL), Hanover, NH 03755-1290. 603-646-4200, DSN 684-4200.
U.S. Army Environmental Hygiene Agency. Aberdeen Proving Ground, MD, 21010. (301) 671-3651 or DSN 584-3651.
U.S. Army Environmental Office. The Pentagon, Washington, DC, 20310-2600, (703) 693-5032 or DSN 223-5032.
U.S. Army Environmental Center (formerly the U.S. Army Toxic and Hazardous Materials Agency). Aberdeen Proving Ground, MD, 21010.
800-USAEVHL, (301) 671-2427 or DSN 584-2427.
U.S. Army Environmental Policy Institute. Champaign, IL, 61820. (217) 373-3320.
Pollution Prevention
U.S. Army Environmental Center (formerly the U.S. Army Toxic and Hazardous Material Agency). Environmental Compliance Division. (301)
671-2427 or DSN 584-2427.
Recycling
U.S. Army Engineering and Housing Support Center (USAEHSC). Directorate of Public Works. (703) 704-1606/1601.
Defense Logistics Agency. Check local Defense Reutilization and Marketing Organization (DRMO).
C-107
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Air Pollution
U.S. Army Environmental Hygiene Agency. Air Pollution Engineering Division. Air Pollution Source Management (301) 671-3500 or DSN
584-3500; or Ambient Air Quality Management (301) 671-3954 or DSN 584-3954.
U.S. Army Environmental Center (formerly the U.S. Army Toxic and Hazardous Material Agency). Environmental Compliance Division. (301)
671-2427 or DSN 584-2427.
CFCs and Halon
U.S. Army Environmental Office. The Pentagon, Washington, DC 20310-2600, (703) 693-5032 or DSN 223-5032.
U.S. Army Environmental Center (formerly the U.S. Army Toxic and Hazardous Material Agency). Environmental Compliance Division. (301)
671-2427 or DSN 584-2427.
Endangered Threatened Species, Natural Resources
U.S. Army Environmental Center. Natural and Cultural Resource Division (703) 355-7968 or DSN 345-7968.
U.S. Army Engineering Waterways Experiment Station (CEWES), Vicksburg, MS 39180-6199, (601) 634-2512, FTS 542-2513.
Hazardous and Toxic Waste and Material Management
C-108
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U.S. Army Environmental Center (formerly the U.S. Army Toxic and Hazardous Material Agency). Environmental Compliance Division. (301)
671-2427 or DSN 584-2427.
U.S. Army Environmental Hygiene Agency. Waste Disposal Engineering Division. (301) 671-3651 or DSN 584-3651.
Environmental Protection Agency-RCRA/Superfund Hotline. (800) 424-9346.
Environmental Protection Agency-TSCA Hotline. (202) 554-1404
Hazardous Waste Minimization
U.S. Army Environmental Center (formerly the U.S. Army Toxic and Hazardous Agency). Environmental Compliance Division. Army
HAZMIN Program. (301) 671-2427 or DSN 584-2427.
U.S. Army Environmental Hygiene Agency. Waste Disposal Engineering Division, (301) 671-3651 or DSN 584-3651.
Solid Waste Management
U.S. Army Environmental Hygiene Agency. Ground Water and Solid Waste Management. (301) 671-2024.
U.S. Army Environmental Center (formerly the U.S. Army Toxic and Hazardous Material Agency). Environmental Compliance Division. (301)
671-2427 or DSN 584-2427.
General Environmental/Pollution Prevention
National Defense Center for Environmental Excellence. 1415 Scalp Avenue, Johnstown, PA 15904. 814-269-2432.
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Air Force Center for Environmental Excellence, Pollution Prevention Division, Brooks Air Force Base, TX 78235-5318. 210-526-4214,
DSN 240-4214.
Navy Energy and Environmental Support Agency (NEESA). PortHueneme, CA. 805-982-4897.
Annapolis Detachment of the Carderock Division, Naval Surface Warfare Center, Environmental Protection Branch, Craig Alig, Director, 410-
267-3526, DSN 281-3526.
Publications
U.S. Army Environmental Strategy into the 21st Century, 1992.
U.S. Army Engineering and Housing Support Center, Installation Recycling Guide, 1991.
U.S. Army Environmental Hygiene Agency, A Commander's Guide to Infectious Waste Management at Army Health Care Facilities.,
1990.
U.S. Army Environmental Hygiene Agency, A Commander's Guide to Hazardous Waste Minimization at Army Health Care Facilities,
1990.
U.S. Army Corp of Engineers, A Commander's Guide to EnvironmentalManagement, 1990.
U.S. Army Corp of Engineers, Hazardous Waste Management Systems Study., 1991.
U.S. Army Environmental Center (formerly the U.S. Army Toxic and Hazardous Material Agency), The Environmental Update, published
quarterly.
Army Environmental Policy Institute, Army Pollution Prevention Plan Manual: A Guide for Army Installations, 1993.
Environmental Health Engineering Directorate. U.S. Army Center for Health Promotion and Preventive Medicine Pollution Prevention
Opportunity Assessment Protocol, 1994.
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WDCR921/009A.WP5
C-lll
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Appendix D
Sample Pollution Prevention Survey Forms
This appendix includes forms that are examples of interviews used at other POD installations in preparing P2 plans. The forms are examples
and are not to be used verbatim but to spark ideas and assist in performing a PPOA. Similar assessments of your facility should be included in
the appendix to your plan, along with feasibility studies of P2 opportunities that were evaluated.
WDCR828/012.WP5
D-112
4-112
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SAMPLE D-l
Pollution Prevention Survey
(insert base name and location)
Date:
Unit Designation, Shop Name, Building:
Type of Operation:
Process Description: Include process flow diagram showing hazardous material usage, wastes, products, and other releases (e.g., air
emissions).
Wastes Generated:
Waste Disposal:
D-2
4-2
-------
Releases to Air, Land, or Water From Operation:
Current Waste Minimization Practices:
Problems:
Waste Minimization Opportunities (In Shop):
D-3
4-3
-------
WDCR828/034.WP5
D-4
4-4
-------
SAMPLE D-2
Pollution Prevention Survey
Date:
Unit Designation, Shop Name, Building: Paint Shop
Type of Operation: General Painting of Installation
Wastes Generated:
Waste paints, paint thinner (mineral spirits, naphtha, toluene, xylenes), and empty 55-gallon paint drums generated from
painting post structures and lines on the post's roads and runways and from cleaning painting trucks and equipment (20,106 Ibs/year in 1990-
91) (D001.,D007, D008, D018, D019, D035, F003, F005). The majority of the waste is nearly empty 55-gallon paint drums.
Paint-coated gravel from testing and adjusting spray nozzles of the line-painting trucks on a gravel lot behind the paint shop.
This practice was stopped in September 1993.
Building paints are generally water based and generate little to no hazardous wastes.
D-3
4-3
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Waste Disposal:
Paint and paint-related waste, including paint-coated gravel, is put in drums and disposed of as a hazardous waste.
Wastes generated from water-based paints are disposed of as nonhazardous wastes in the post landfill.
Current Waste Minimization Practices:
The paint shop recently switched to ordering traffic paint in returnable 350-gallon Super Drums. The shop used to generate
300 empty drums of waste per year.
A diked concrete pad has been proposed to be constructed at the shop. The contained area will be used to load and clean
the line-painting truck.
D-4
4-4
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Problems:
Drums of hazardous wastes, paint, and solvent products are stored in areas without secondary containment.
Paint used in miscellaneous jobs is ordered often in quantities greater than necessary, and excess paint must be disposed of
as hazardous waste.
Waste Minimization Opportunities (In-Shop):
Construct diked areas for storing drums of wastes, paint, and solvent products.
Revise procedures for changing colors on line-painting truck if possible.
Consolidate paint wastes in as few containers as possible.
Order specialty paints in smaller-size containers to prevent waste.
Rotate stock to prevent exceeding paint shelf life.
WDCR828/038.WP5
D-5
4-5
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SAMPLE D-3
Pollution Prevention Survey
Date:
Unit Designation, Shop Name, Building: Cargo Helicopter Maintenance
Type Of Operation: Between-Flight Servicing, Refueling, and Unscheduled Maintenance of Helicopters
Wastes Generated:
Fuel-soaked absorbent pads from JP-4 and cleanups of hydraulic-fuel spills (13,900 Ibs/year in 1992-93) (D001, D008,
other regulated nonhazardous waste). Spills occur during aircraft maintenance and refueling and when temperature increases cause fuel to
expand and overtop fuel tanks.
Waste Disposal:
Used pads are disposed of in metal drums as hazardous waste.
Current Waste Minimization Practices:
D-5
4-5
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Aircraft fuel tanks are not filled to capacity before being stored in the hangars to prevent overspill from expansion of JP-4.
Problems:
Pads often are not used efficiently.
Shop personnel do not like to use foam soak-up pads, preferring fiber pads or rolls.
Using metal drums to dispose of pads increases disposal weight.
Maintenance personnel use rolls of pads as one-time disposable drop cloths during aircraft servicing.
Waste Minimization Opportunities (In Shop):
Supply the shops with both fiber rolls and individual fiber pads for more-efficient use.
Design fuel-catch pan to attach under unified fuel-control apparatus during maintenance.
Paint hangar floors with nonskid paint.
Use large (95-gallon) plastic overpacks rather than metal drums for disposal containers.
D-6
4-6
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Provide incentives for using pads more efficiently.
WDCR828/036.WP5
D-7
4-7
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SAMPLE D-4
Pollution Prevention Survey
Date:
Unit Designation, Shop Name, Building: Power Plant
Type of Operation: Base-Wide Power and Heat Generation
Wastes Generated:
Waste oil (fuel, lubricating, and hydraulic) from leaks in diesel feed pumps, turbines, and turbine hydraulic system (2,800
Ibs/year in 1992-93) (D001, D018, D019, D029, D039, other regulated nonhazardous waste).
Spill-cleanup pads, rags, and absorbent material from oil leaks (1,600 Ibs/year in 1992-93) (D001, other regulated
nonhazardous waste).
Fuel oil and Citri-clean from parts cleaning (other regulated nonhazardous waste).
D-8
4-8
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Hydrochloric and phosphoric acid (700 Ibs/year in 1992-93) (D002)
1,1,1-trichloroethane from parts cleaning (198 Ibs/year in 1992-93) (F001).
Waste Disposal:
All wastes are collected in 55-gallon drums and disposed of as hazardous waste.
Current Waste Minimization Practices:
In the process of replacing the turbine hydraulic system, which will reduce or eliminate leaks from that source.
Problems:
There was an unsuccessful attempt to use a blend of waste oil and JP-4 as a fuel for three of the boilers. The mixture was
uncontrolled and was fed into the units without pretreatment.
The plant has no stack scrubbers. Pollution control is performed by monitoring emissions for carbon monoxide and oxygen
and adjusting the boilers when necessary.
Boilers are fueled primarily by gas and have a backup supply of arctic diesel. EPA is trying to restrict the burning of diesel to
10 percent.
D-9
4-9
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Additional stack testing (hydrocarbons, NOx, 802) would likely be necessary if a greater percentage of diesel or waste oil
was to be used for fuel.
Feed pumps are 35 years old, leak, and need replacing. Leaking oil contains lead from pump bearings.
Current oil-water separator does not work adequately and therefore is not used.
Sulfuric acid is supplied in 55-gallon drums that require excessive handling and present opportunities for spills.
Waste Minimization Opportunities (In Shop):
Replace leaking flanges in fuel-oil lines.
Construct new oil-water separator and use high-pressure steam/hot water cleaning operation to replace the fuel-oil cleaning
of parts.
Replace the six feed pumps and oil purifiers to reduce leaks. Estimate cost at $70K and $22K per unit, respectively.
Install 500-gallon tanks for sulfuric acid storage to replace the current use of drums.
D-10
4-10
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Use waste oil, diesel, and JP-4 as a fuel mixture in one or more of the boilers. Fuel and oil first would have to be blended
and treated.
WDCR828/037.WP5
D-ll
4-11
-------
SAMPLED-5
Pollution Prevention Survey
Date:
Unit Designation, Shop Name, Building: Hazardous Waste Storage Area
Type of Operation: RCRA and TSCA Regulated Waste Storage Facility
Wastes Generated:
This shop is a RCRA and TSCA permitted facility that collects all hazardous wastes generated on the post as well as waste
from other DOD facilities throughout Alaska.
This shop also is used as a consolidation point for used oil from other nearby DOD facilities (970,000 Ibs over a 2-year
period) (D001, D018, D029, D039, F001, F003, other regulated nonhazardous waste).
D-9
4-9
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Solvent-contaminated soil from the cleanup of a past recurring spill at a waste-solvent drum-storage area near Building 6
(110,000 Ibs as of 9/10/91; the cleanup is still under way) (D018, F005). The storage area had been operated by a tenant organization. They
have improved their storage practices.
Waste Disposal:
Used oil is being stockpiled on the site in railroad tank cars. The majority of the oil is off-specification, nonhazardous
material. Some contains hazardous concentrations of solvents or metals.
Hazardous wastes are shipped through a contractor to the lower 48 states, where they are incinerated or otherwise treated
and/or landfilled.
Current Waste Minimization Practices:
Used to send used oil off the site, where it was mixed with coal and burned in the power plant. Because of improper
handling, the State no longer allows this practice. The oil is being stockpiled at the base in railroad tank cars.
Converting several shops to use Black Gold furnaces that will burn up to 100 gpd of used oil to generate heat.
Accumulation points for hazardous waste are in some instances housed in specialized storage sheds.
Problems:
D-10
4-10
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Waste oils sometimes contain hazardous concentrations of metals, organics, and solvents.
Often, drums of waste paint are received from the paint shop 90 percent empty, and drums of cleanup pads are received
light (dry and unused). A good portion of the disposal costs in these instances is for the weight of the drum.
Large plastic overpacks are difficult to handle and store.
Waste Minimization Opportunities (In Shop):
Better use of cleanup pads and lighter drums would lessen disposal costs.
Burn waste oil and JP-4 as a fuel in the existing base power plant.
Construct an incinerator or a separate power facility for burning waste oil and solid waste.
Install additional Black Gold furnaces for heating buildings using waste oil.
WDCR828/039.WP5
D-ll
4-11
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SAMPLE D-6
Pollution Prevention Survey
Date:
Unit Designation, Shop Name, Building: Transportation Company
Type of Operation: Stripping and Painting of Vehicles
Wastes Generated:
Methyl ethyl ketone (MEK) paint thinner and waste paint from cleaning painting equipment (-4,500 Ibs/year in 1990-91)
(D007, D008, F005).
Plastic paint-stripping media are used to remove old paint from aluminum aircraft parts (soft, Type n media) and steel
ground equipment parts (hard, Type HI media). Spent beads and paint residue are collected and disposed of (27,200 Ibs/year in 1990-91)
(D006, D007, D008).
D-ll
4-11
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Glass beads from stripping corrosion from steel parts. Spent beads and corrosion residue are disposed of (-9,000 Ibs/year
in 1990-91) (other regulated nonhazardous waste).
Spent Turco (cold solvent) paint stripper and rinse water are generated from spot-stripping paint, particularly Boeing
primer, from thin parts that cannot be stripped with plastic media. Turco is hand-applied with brushes. In addition, spent fine organic 606 (hot
solvent) paint stripper and contaminated rinse water are generated from a dip tank stripping process used to remove paint from small parts
(8,300 Ibs/year in 1990-91) (D002, D007, D008, F001, F002, F003, F005).
Used filters and paint-booth paper are generated from two dry paint booths (1,500 Ibs/year in 1990-91) (D007, D008,
other regulated nonhazardous waste).
Waste Disposal:
MEK and waste paints, spent plastic stripping media, spent Turco, and organic 606 paint stripper and rinse water are
collected in drums and disposed of as hazardous waste.
Glass stripping beads and air filters have been disposed of in the past as hazardous waste but recently have tested as
nonhazardous and have been disposed of in the base landfill.
Current Waste Minimization Practices:
D-12
4-12
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Plastic-media stripping process was installed in June 1990 and has greatly reduced the use of Turco stripping and the total
waste generated from parts stripping.
Paint booths recently were switched over from wet to dry filter. This has eliminated a 3,000 gallon/week waste stream of
water.
Problems:
Plastic media break down and create hazardous wastes because of metals from paint residue.
There is no system set up for reusing MEK paint thinner.
Paint shop foreman is concerned about using a still to recycle MEK. He feels that the recycled (off-spec) MEK may be
used inadvertently to mix paints.
Waste Minimization Opportunities (In Shop):
Switch to water-base paints, thereby eliminating the need for MEK. In the long term, use of hazardous paint strippers
would be eliminated, and spent plastic media could be disposed of as nonhazardous waste.
Recycle spent plastic beads.
D-13
4-13
-------
Install a still for recycling spent MEK.
Use CO2 paint stripping.
Use organic-media paint stripping.
WDCR828/040.WP5
D-14
4-14
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SAMPLE D-7
Pollution Prevention Survey
Date:
Unit Designation, Shop Name, Building: Company Motor Pool
Type of Operation: General Motor Pool Maintenance and Repair
Wastes Generated:
Motor oil (3,000 Ibs/yr in 1992-93) and oil filters (5,900 Ibs/yr in 1992-93) from regular vehicle maintenance. Oil is
changed every 6 months or 6,000 miles on standard vehicles and every 400 to 600 operating hours on special vehicles. Approximately 1,300
vehicles are serviced. These quantities include wastes generated at the Heavy Equipment Maintenance Shop (D001, other regulated
nonhazardous waste).
Antifreeze from regular vehicle maintenance (700 Ibs/yr in 1992-93) (other regulated nonhazardous waste).
Waste paint and related materials from painting fleet vehicles in two wet paint booths (1,800 Ibs/year in 1992-93) (F005).
D-13
4-13
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Waste Disposal:
Used oil is being consolidated in a waste POL sump and tanks.
Oil filters, used antifreeze, and waste paint and related materials are disposed of as hazardous waste.
Solvents are disposed of by Safety Kleen.
Current Waste Minimization Practices:
The floor of the garage is swept daily with a dry sweeping machine to eliminate dirt accumulation in the oil-water separators.
Oil filters are crushed before disposal.
Citrus (orange peel) solvent has been replacing PD-680.
A test (litmus) for evaluating antifreeze has been implemented that has extended the life of antifreeze from 2 to 4 years.
Diesel fuel is tested and reused if possible.
A dry-filter, down-draft work area has been installed and is used for bodywork, such as sanding and touch-up painting.
D-14
4-14
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Problems:
Shop supervisor does not like the idea of recycling antifreeze.
Synthetic motor oils are not acceptable to the Army because they may void vehicle warranties.
This shop has been designated as an area to receive two Black Gold furnaces. Shop supervisor foresees a problem with
open flames in his building. Furnaces would have to be located in a separate building if they operate with open flames.
Shop supervisor feels that waste management requires a full-time supervisor and a dedicated staff, which he does not have.
Minimization Opportunities (In Shop):
Institute a program for testing motor oil and antifreeze to increase the time between changes.
Switch from wet to dry paint booth.
WDCR828/041.WP5
D-15
4-15
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SAMPLED-8
Pollution Prevention Survey
Date:
Unit Designation, Shop Name, Building: Transportation Company, Heavy Equipment Maintenance
Type of Operation: Maintenance and Repair of Heavy Snow-Removal Equipment and Other Heavy Vehicles
This shop is operated under the motor pool maintenance department
Wastes Generated:
Motor oil, oil filters, and antifreeze from regular vehicle maintenance. Oil is changed every 4 to 6 months or 200 to 400
hours of vehicle running time; 300 vehicles are serviced, some needing as much as 132 quarts of oil per change. The quantities of used oil and
filters generated at this shop are included in those listed.
PD-680 degreaser from cleaning vehicle parts (2,000 Ib/year in 1992-93) (D001).
D-16
4-16
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Contaminated diesel is generated when trucks are drained before overhaul (other regulated nonhazardous waste).
Waste Disposal:
Used motor oil is being consolidated in 55 gallon drums.
Used oil filters are disposed of in drums as hazardous waste.
Spent PD-680 is disposed of in drums as hazardous waste.
Current Waste Minimization Practices:
Used oil filters are crushed and drained before disposal.
If diesel fuel is not contaminated, it is reused.
D-16
4-16
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Problems:
Synthetic motor oil is not acceptable by the Army because its use may void vehicle warranties.
Waste Minimization Opportunities (In Shop):
Institute a testing program for motor oil to increase the time between changes.
Use high-pressure hot water or detergent wash rather than a degreaser to clean parts. Treat washwater in an oil/water
separator.
Filter PD-680 for reuse (may already be doing this).
WDCR828/042.WP5
D-17
4-17
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SAMPLE D-9
Pollution Prevention Survey
Date:
Unit Designation, Shop Name, Building: Transportation Company, Diesel Maintenance
Type of Operation: Diesel Generator Tear down and Rebuild
Wastes Generated:
Used motor oil and diesel fuel in unknown condition are generated when diesel generators are drained before teardown
(1,000 Ibs/yr in 1992-93) (D001, other regulated nonhazardous waste).
Waste Disposal:
Used motor oil is put in drums and disposed of as waste.
Diesel fuel is reused if possible or disposed of as waste.
D-17
4-17
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Current Waste Minimization Practices:
Diesel fuel is tested for water content and reused if possible.
Problems:
In the past, generator parts were cleaned with tetrachloroethylene (PCE) and then rinsed off down the building floor drains.
The shop received a notice of violation from EPA for this practice. Parts are currently cleaned at Fort Richardson, but this is an unacceptable
practice because of the delays involved. New procedures are being investigated.
There is no Army-approved method for testing motor oil for reuse.
Waste Minimization Opportunities (In Shop):
Institute a testing program for motor oil to determine if it can be reused.
D-18
4-18
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Potential alternatives for parts-cleaning technologies are:
High pressure steam or hot water
Alkaline cleaning system
WDCR828/043.WP5
D-19
4-19
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SAMPLED-10
Pollution Prevention Survey
Date:
Unit Designation, Shop Name, Building: Public Works, Operating Engineers
Type of Operation: Hazardous Waste and Materials Response
Wastes Generated:
Various wastes are generated from emergency response cleanup actions at off-post locations. Examples of wastes
generated and sent to the RCRA storage facility in 1992-93 include asphalt cutback (4,600 Ibs), waste oil (9,700 Ibs), and PCB-contaminated
material (1,200 Ibs).
Waste diesel fuel, antifreeze, transmission fluid, etc., from maintenance of shop vehicles.
Waste Disposal:
D-19
4-19
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Nonhazardous waste oil is being stockpiled at the base in railroad tank cars.
Other wastes are placed in drums and disposed of as hazardous waste.
Current Waste Minimization Practices: None
Problems:
Little can be done to minimize waste at the source because most wastes originate off the site and are a result of cleanup
activities.
Waste Minimization Opportunities (In Shop):
Institute a testing program for motor oil and antifreeze to increase the time between changes.
WDCR828/044.WP5
D-20
4-20
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SAMPLED-11
Pollution Prevention Survey
Date:
Unit Designation, Shop Name, Building: Defense Reutilization and Marketing Office (DEMO)
Type of Operation: Hazardous and Nonhazardous Material Collection, Storage, Redistribution, and Sale.
Wastes Generated:
DRMO is a consolidation point for unused products from military installations throughout the state. The wastes are those
that have exceeded their shelf life or are no longer needed by the original purchaser. DRMO tries to find other uses for them. Materials include:
Paints
Sulfuric acid
Cleaners
Adhesives
Petroleum products
D-20
4-20
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Chemical DECON kits
DRMO spent approximately $3.6 million on disposal of materials received from Army installations in 1992.
Waste Disposal:
Where possible, materials are sold or given away for reuse. Remaining materials are disposed of as hazardous waste
through a RCRA-permitted hazardous waste storage area.
Current Waste Minimization Practices:
Try to resell or reuse products.
Problems:
Many items are received without MSDS sheets. They cannot be reused and must be analyzed before disposal.
Waste Minimization Opportunities (In-Shop):
Shops should obtain MSDS sheets with purchases of all chemical products and should keep MSDS sheets with products
even during disposal.
D-21
4-21
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Shops need to rotate stock so that shelf lives are not exceeded, and shops should limit purchases to the amount needed.
Shops should use proper storage to keep materials longer.
WDCR828/045.WP5
D-22
4-22
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July 1998
RG-133
Pollution Prevention
Assessment Manual
A Guide for Large Quantity Generators and
TRI Reporters in Preparing a Source
Reduction and Waste Minimization Plan
Office of Pollution Prevention and Recycling
TEXAS NATURAL RESOURCE CONSERVATION COMMISSION
-------
Barry R. McBee, Chairman
R. B. "Ralph" Marquez, Commissioner
John M. Baker, Commissioner
Jeffrey A. Saitas, Executive Director
Authorization for use or reproduction of any original material contained in this
publication—that is, not obtained from other sources—;'s freely granted. The
commission would appreciate acknowledgment.
Published and distributed
by the
Texas Natural Resource Conservation Commission
PO Box 13087
Austin TX 78711-3087
The TNRCC is an equal opportunity/affirmative action employer. The agency does not allow discrimination on the
basis of race, color, religion, national origin, sex, disability, age, sexual orientation or veteran status. In compliance
with the Americans with Disabilities Act, this document may be requested in alternate formats by contacting the
TNRCC at (512)239-0028, Fax 239-4488, or 1 -800-RELAY-TX (TDD), or by writing P.O. Box 13087, Austin, TX
78711-3087.
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Contents
1. Pollution Prevention Makes Good Business Sense 1
Pollution Prevention in Texas 2
How Does Pollution Prevention Make Sense? 2
It Pays to Reduce Waste 3
Reduce Your Regulatory Burden 4
It's Your Responsibility 5
It's the Law 5
It's the Right Thing to Do 6
It's Our Future 6
2. Complying with the Waste Reduction Policy Act 7
Does the WRPA Affect Me? 7
Groups Affected by the WRPA 7
Groups Not Affected by the WRPA 8
Getting Below Reporting Thresholds 8
What Does the WRPA Require? 8
Prepare a Pollution Prevention Plan 9
Send in an Executive Summary 9
Report Annually 10
How Can I Comply? 10
Table 1. Which Worksheet Do I Use for Each Requirement? 11
Where Do I Send My Summary and Reports? 13
Could I be Exempt? 14
3. Planning, Organizing, and Goal-Setting 15
Develop a Company Environmental Policy 15
Organize a Pollution Prevention Program 15
Create a Pollution Prevention Program Task Force 15
Train Employees: Increase Their Awareness 16
Select a Great Assessment Team 16
in
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Worksheet 1 — Corporate Environmental Policy 18
Worksheet 2 — Program Task Force 20
Worksheet 3 — Pollution Prevention Goals 22
Worksheet 4 — Employee Training Program 24
Worksheet 5 — Assessment Team Make-Up 26
4. Doing Your Pollution Prevention Assessment 28
Identify Waste Streams to Eliminate 29
Table 2. Avenues of Waste 29
Where does Waste Happen? 30
How Much Waste Happens? 30
How is That Waste Managed? 30
Assess the Risk Each Waste Represents 31
Prioritize Your Waste Streams 31
Identify Your Options 32
Source Reduction 32
Waste Minimization 34
Treatment Options 35
Finding More Ideas 35
Analyze Technical Aspects 38
Worksheet 6 — Process and Waste Stream or Release Data 38
Worksheet 7 — Waste Stream/Release Summary 40
Worksheet 8 — Assessment of Risk to Human Health and the Environmehl
Worksheet 9 — Waste Stream Prioritization 44
Worksheet 10 — Source Reduction/Waste Minimization Options
Description 46
Worksheet 11 — Treatment Feasibility 48
Worksheet 12 — Technical Feasibility 50
5. Analyzing the Economic Feasibility of Each Project 52
Analyze Economic Aspects 52
Prioritization 52
Crayons to Computers: How Complex Should Your Analysis Be? 53
Crayon Accounting: Preliminary Screening 53
IV
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Using a Pencil: Identifying Hidden Costs 55
Sharpening the Pencil: Full-Cost Accounting 56
Economic Analysis, Step by Step 57
At the Click of a Mouse: Software for Cost Accounting 60
Set Priorities 60
Worksheet 13 — EMS Environmental Accounting 62
Worksheet 14 — Waste Reduction Project Prioritization 66
6. Implementation 68
Documentation 68
Implementation 69
Evaluate Performance 69
Worksheet 15 — Implementation Schedule 70
Worksheet 16 — Evaluate Performance 72
7. Filing your Supporting Documentation 74
Submit the Executive Summary 74
Submit a Certificate of Completion 74
Worksheet 17 — Executive Summary 76
Worksheet 18 — Certification of Completion 80
Appendix A: Basic Facts About Hazardous Waste and TRI A-l
Appendix B: Small-Quantity Generator/Non-TRI Reporter Executive Summary Form and
Instructions B-l
Appendix C: Example Pollution Prevention Plan C-l
Appendix D: TNRCC Pollution Prevention Rules (30 TAC §335, Subchapter Q) Pollution
Prevention: Source Reduction and Waste Minimization D-l
Appendix E: Additional Resources E-l
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VI
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1. Pollution Prevention Makes Good Business Sense
Pollution prevention does make good business sense—and it's the law in Texas. The Waste
Reduction Policy Act (WRPA) of 1991 requires certain industries and businesses that generate
hazardous waste or release toxics to prepare a source reduction and waste minimization
(SR/WM) plan and a SR/WM annual progress report.
This manual is organized to accomplish two objectives:
• to assist you in preparing a pollution prevention plan as required under the WRPA;
• to aid you in planning, developing, and implementing a successful pollution prevention
program.
For more information on how to determine whether your facility is subject to the pollution
prevention plan reporting requirements, refer to TNRCC document RG-209, "Does the Waste
Reduction Policy Act apply to you?"
Non-TRI Small Quantity Generators can gain benefit from following the assessment instructions
in this manual. However, specific requirements for Non-TRI SQGs are outlined Appendix B, or
can be found in TNRCC publication RG-196, Source Reduction and Waste Minimization
Executive Summary and Certificate of Completeness and Correctness for Non-TRI Small
Quantity Generators.
For help preparing a WRPA annual progress report, order TNRCC publication RG-112, Source
Reduction and Waste Minimization Annual Progress Report: Instruction Manual and Forms for
Large-Quantity Generators and TRI Reporters.
Each chapter in this manual contains worksheets, detailed descriptions explaining the worksheets,
and advice on how to complete a pollution prevention assessment and plan. You may need to
modify the procedures and worksheets to fit your specific needs. Appendix C, "Example Pollution
Prevention Plan," includes one facility's simplified plan.
Chapter 2 presents instructions and approaches for preparing a pollution prevention plan as
required by the WRPA. Chapters 3 through 6 present worksheets that will help you prepare your
plan.
The rules governing Texas source reduction and waste minimization planning are included in
1
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Appendix D of this manual: 30 TAG §335, Subchapter Q.
Pollution Prevention in Texas
Pollution prevention begins with a good approach to waste management. The Texas Solid Waste
Disposal Act encourages using this order of preference for methods of managing hazardous
waste:
1. Source Reduction (most preferred)
2. Reuse or Recycling
3. Treatment to destroy hazardous characteristics
4. Treatment to reduce hazardous characteristics
5. Underground injection
6. Land disposal
Throughout this manual we will refer to this order of preference as the "waste management
hierarchy." This hierarchy applies to nonhazardous waste as well. In this manual, we focus on
the most preferred categories
There are two types of pollution prevention: source reduction and waste minimization. As
illustrated in the waste management hierarchy, source reduction is preferred. Pollution prevention
activities may address any hazardous substance, pollutant, or contaminant. Your facility may
already be incorporating pollution prevention activities into plant operations. A pollution
prevention plan helps you document existing activities as well as develop new projects.
This manual focuses on the most preferred categories: source reduction, reuse or recycling, and
some forms of treatment. In addition to evaluating your hazardous wastes, you should examine
cardboard, paper, typewriter ribbons, aluminum cans, and other nonhazardous wastes. Evaluating
your nonhazardous wastes can mean substantial savings through recycling and reduced disposal
costs.
For more information on specific source reduction and pollution prevention options, see Chapter
4, "Doing Your Pollution Prevention Assessment."
How Does Pollution Prevention Make Sense?
There are many reasons to have a pollution prevention plan that reduces both the amount of waste
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generated and the amount of toxic releases to the environment. Six important reasons are:
• economic incentives — it pays to reduce waste.
• paperwork reduction — you can reduce your regulatory burden.
• reduced liability — it's your responsibility.
• state policy — it's the law.
• increased public awareness — it's the right thing to do.
• improved human health and the environment — it's our future.
It Pays to Reduce Waste
Pollution control and waste management costs. Pollution prevention pays. Texas facilities have
reported big savings from developing pollution prevention plans under the WRPA. An
independent survey of Texas facilities with WRPA pollution prevention plans indicates these
results:
• 80 percent considered the plan to be useful to their facility.
• 77 percent broke even or had a cost savings from pollution prevention projects.
• 48 percent had a net cost savings of more than $40,000 from these projects.
• More than one-third of the respondents are now large-quantity generators (LQGs) but
expect to become conditionally exempt small-quantity generators (CESQGs) over the next
three years.
Companies must look beyond the up-front costs of pollution prevention and examine all costs
associated with managing wastes—including disposal, potential liability, and regulatory costs.
Additional benefits include improved public perception and community relations and reduced
overhead.
Lone Star Success
As a result of going through the WRPA pollution prevention planning process and attending a
Texas Auto Dealers' Association assistance workshop, a West Texas auto dealer has:
• cut paint and related waste by 90 percent—from 4,000 to 400 pounds a year;
• eliminated the use of carburetor cleaner by 400 pounds per year;
• switched to a new parts washer solvent that tests nonhazardous even after use;
• had the new solvent re-refined, for a reduction of 5,500 pounds per year;
• changed from small-quantity generator (SQG) to a CESQG in approximately one year.
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Reduce Your Regulatory Burden
The paperwork required for environmental reporting and record keeping is extensive. Time spent doing pape
business expense, so reducing your paperwork can translate into savings and increased efficiency. A reductic
amount of waste managed can translate into a reduction in paperwork.
How can reducing the amount of hazardous waste reduce paperwork? It's simple: the less waste
you have, the fewer manifests and other paperwork you have to fill out. If your facility reduces
enough to change generator status, your facility can reap even greater benefits. For example, if
your facility is a large-quantity generator (LQG) of hazardous waste (see Appendix A, "Basic
facts about hazardous waste and TRI," for hazardous waste information) and becomes an SQG,
your facility may benefit from increased storage time and fewer pollution prevention requirements
(see Chapter 2 for details on WRPA requirements). If your facility is already an SQG, your
regulatory burden could be further reduced by becoming a CESQG. It pays to be aware of your
generator status and to try to reduce it to a lower level.
Lone Star Success
A military station switched from a parts washing system based on off-site waste management to a
continuous filtration parts washing system. By completing this single pollution prevention project,
the facility expects to save over $20,000 per year and reduce their generator status from an LQG
to an SQG. Benefits of changing from an LQG to an SQG include fewer inspections, increased
storage time, and a reduction in paperwork, which the facility estimates will save another $13,000
annually.
Pollution prevention planning may also help you reduce paperwork if your facility is required to
report on the Toxics Release Inventory (TRI) Form R. For more information on TRI, see
Appendix A, "Basic Facts About Hazardous Waste and TRI." Each reportable chemical requires a separate
Form R. If your facility reduces the levels of reportable chemicals managed or released to below the threshol
may be able to use the Form A. The Form A is significantly shorter and easier to complete than the Form
R.
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Lone Star Success
An East Texas manufacturer found that by going through the required pollution prevention
process they developed a plan that reduced emissions and the facility's regulatory burden.
Because the planning process covers air emissions reported to TRI as well as hazardous waste,
they targeted projects that resulted in reductions in air emissions. They reduced volatile organic
compounds (VOCs) below the thresholds required by two regulatory programs.
The facility estimates that by spending about one month preparing the plan, they will save about
four months of work preparing both Title III and Title V permits. These are significant savings
both in time and money.
You may find that by going through the planning process you find ways to reduce or even eliminate the neec
hazardous waste and TRI. You could also apply these techniques to drop below the threshold for other repor
requirements. As the Lone Star Success case studies show, many facilities in Texas have found that reducing
form, is the best way to reduce paperwork.
It's Your Responsibility
Once you generate a hazardous waste, you are legally responsible for the proper management of
that waste forever. In addition, federal and state laws target generators of hazardous waste as
being at least partially responsible for the cleanup of wastes that leak from disposal sites.
Generators using off-site treatment, storage, or disposal, face financial liability when the facility
operators mismanage waste and when facility owners improperly design the disposal facility itself.
Increases in insurance costs or an inability to obtain insurance will result in higher treatment and
disposal costs or the loss of available treatment or disposal capacity. You can reduce this expense
by reducing the cause of the liability, which is your hazardous waste. Preventing pollution can also
reduce health and safety risks and requirements. By reducing the amount of hazardous waste your
business generates, you can reduce your long-term liability.
It's the Law
Texas state policy regarding pollutants and contaminants is to reduce pollution at its source and
to minimize the impact of pollution, reducing the risk to public health and the environment.
The best solution is to generate as little as possible, reduce the volume or the hazardous
properties of what is generated, and dispose of the remaining waste safely.
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Lone Star Success
A Nuevo Laredo facility worked through its vendors to receive raw materials in returnable
containers wherever possible. The facility now receives 90 percent of all chemical deliverables in
returnable totes. By doing this, the facility has reduced the number of drums disposed of annually
by approximately 250 drums. In addition, before disposal, drums had to be rinsed; by eliminating
disposal, it has reduced its wastewater generation by 45,000 gallons a year.
Purchasing chemicals in returnable totes saves money in several ways. Chemicals can now be
purchased at bulk rates, reducing materials handling. There are also no disposal or cleanup costs
associated with the empty drums. The facility estimates that using returnable totes saves the
company $5,000 a year.
It's the Right Thing to Do
The public today is more informed about environmental issues. People are aware of the potential
effects that hazardous waste and the release of pollution can have on human health and the
environment. Therefore, companies that are environmentally aware and work towards waste
reduction can improve their working relationship with the public, their neighbors, and their
customers.
It's Our Future
The most important reason to promote pollution prevention is to protect our health and our
environment. When we improve and protect the environment, we are ultimately protecting
ourselves, our economy, and our future.
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2. Complying with the Waste Reduction Policy Act
WRPA requires facilities that generate hazardous waste or report on the TRI Form R to prepare a
five-year pollution prevention plan, to submit an executive summary of that plan to the TNRCC,
and to report annually on their progress. All companies that recognize the importance of
protecting human health and the environment should incorporate a pollution prevention plan into
their overall business plan.
This chapter is designed to guide businesses in establishing a pollution prevention plan. Included
are an overview of the requirements for complying with pollution prevention rules (see Appendix
D) as well as methods for preparing a plan. Appendix C, "Example Pollution Prevention Plan,"
demonstrates one Texas facility's method for meeting WRPA requirements.
Does the WRPA Affect Me?
WRPA's reporting requirements apply to thousands of facilities throughout Texas. The following
information will assist you in determining if WRPA applies to you. For more information
regarding WRPA applicability, please refer to RG-209, "Does the Waste Reduction Policy Act
Apply to You?"
One way to get out of reporting to WRPA is to reduce your waste generation. See "Getting
Below Reporting Thresholds" on page 8 for more information.
Groups Affected by the WRPA
The pollution prevention rules apply to the following groups:
• all large-quantity generators (LQGs) of hazardous waste
• all small-quantity generators (SQGs) of hazardous waste
• all persons subject to TRI Form R reporting (SARA Title III)
LQGs, SQGs, and TRI Form R reporters must prepare a five-year plan to keep on site for
inspection. The due date for the plan is based on the previous years' amounts of hazardous waste
generated or TRI chemicals released and transferred (as per the total of Sections 5 and 6 on the
TRI Form R).
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If your facility has more than one EPA, solid waste (5-digit), or TRI identification number, you
should report under each number. If a new facility is built or an old facility expands and the rules
suddenly apply to it, the facility has 90 days to have a plan in place and submit an executive
summary to the TNRCC.
Groups Not Affected by the WRPA
The pollution prevention rules do not apply to the following groups:
• conditionally exempt small-quantity generators (CESQGs) that are also not TRI
Form R reporters
• facilities regulated only by the Railroad Commission of Texas
Getting Below Reporting Thresholds
Several facilities have "reduced out" of WRPA planning and reporting requirements by reducing
their wastes to levels below reporting thresholds. If you are no longer a TRI Form R reporter and
a CESQG, you are no longer subject to WRPA. In other words, if you generate less than 1.102
tons of hazardous waste a year and are not subject to TRI Form R requirements, WRPA does not
apply to you.
What Does the WRPA Require?
To comply with WRPA, you must complete these two steps:
• prepare a pollution prevention plan; and
• send the TNRCC an executive summary of your plan.
Large Quantity Generators and/or TRI Form R reporters must also send the TNRCC an annual progress repc
Under the law, if you fail to prepare the plan, send in the executive summary, or submit an annual progress r
can be considered in violation of the Texas Administrative Code. The penalties for such a violation can be as
$10,000 per violation per day. Failing to meet the reduction goals stated in your facility's plan is not a violal
does not expose you to any penalties.
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Prepare a Pollution Prevention Plan
If WRPA applies to you, you need to prepare a WRPA pollution prevention plan. According to
the rules, this plan should be available to the TNRCC for on-site inspection. All WRPA pollution
prevention plans need to include at least the following elements:
> list of all hazardous wastes generated and quantity in tons (using your facility's most
recently submitted annual waste summary);
*• a description of source reduction/waste minimization projects including:
• a discussion of environmental and human health risks associated with these
projects;
• a description of any media transfer and/or change of waste or release associated with projects:
• a schedule for project implementation and completion;
> facility reduction goals; and
> an executive summary and certificate of completion and correctness (see below).
LQG/TRI facility plans must also include a prioritized list of projects. In this list, include the
following information for each project:
• project explanation;
• economic and technical feasibility;
• consideration of environmental/health risks and benefits;
• discussion of media/contaminant transfer possible due to project
implementation;
• type of proj ect (source reduction or waste minimization);
• implementation schedule; and
• individual project goal.
Send in an Executive Summary
You must submit your pollution prevention plan's executive summary and certificate of
completion and correctness to the TNRCC by the time the plan is due to be completed. All
executive summaries must include:
• facility information (name, address, contacts, IDs, etc.);
• estimated amount of hazardous waste to be generated in the fifth year (based on the reduction goals ii
plan);
• prioritized list of contaminants to be reduced;
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• list of source reduction activities; and
• certificate of completion and correctness, signed by the owner or corporate officer.
LQG/TRI facilities must also include:
• list of all hazardous wastes and reportable TRI releases and volumes;
• discussion of media/contaminant transfer possible due to project
implementation;
• project implementation milestones; and
• implementation schedule for future reduction goals.
Report Annually
Large-quantity generators and/or facilities that report on the TRI Form R must also submit a
WRPA annual progress report July 1 of each year. For a copy of RG-112, Source Reduction and
Waste Minimization Annual Progress Report Manual and Forms, call TNRCC publications at
512/239-0028. You may also download RG-112 from the TNRCC Web site at
http://www.tnrcc.state.tx.us.
How Can I Comply?
One possible method for preparing your plan is through the use of the assessment worksheets
provided in this document. Using the worksheets in this document is advisable if the following are
true at your facility:
• facility contains many reportable hazardous waste and TRI "waste" streams;
• past reporting and record keeping has been sketchy or questionable;
• assessment team/environmental component not familiar with processes and wastes;
• facility is probably a large-quantity generator and/or a TRI reporter; and
• limited reduction projects.
Using the worksheets may require more time, but the advantages could be considerable, including
identifying more reduction opportunities. Completing the worksheets can also help you set up a
program that focuses on cost-effective reductions.
Lone Star Success
w-
10
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By utilizing the Pollution Prevention Assessment Manual worksheets and the TNRCC pollution
prevention workshops in setting up their pollution prevention plan, a Dallas-area facility reduced
hazardous waste generation by 63 percent from 1994 to 1995, even while increasing production,
and implemented projects resulting in 88.1 tons of waste that were not shipped off-site for
disposal or incineration. This facility also found employee training and education to be a key
element in reducing waste generation
Not all facilities use the worksheets. Appendix C, "Example Pollution Prevention Plan," includes
an example of a well-written, concise plan whose authors chose not to use the worksheets.
The following table describes the information needed for completing a pollution prevention plan
as required by the Waste Reduction Policy Act and the corresponding assessment worksheets
covering the required information.
While all worksheets are invaluable in conducting a thorough pollution prevention assessment and
in finding additional ways to reduce your wastes and costs, no WRPA reporting requirements
exist for using Worksheets 1, 2, 5, 9, 11, and 16.
Table 1. Which Worksheet Do I Use for Each Requirement?
WRPA pollution prevention plan requirements
Initial survey
An initial survey of the facility's activities which will identify those
activities that cause hazardous waste, and/or will identify activities
that result in the release of pollutants or contaminants.
Prioritized list of projects
A. A list of prioritized source reduction projects, based upon
information obtained during the initial survey, which are
economically and technologically feasible.
B. A list of prioritized waste minimization projects, based upon
information obtained during the initial survey, which are
economically and technologically feasible.
Worksheet(s)
Worksheet 6: "Process and Waste
Stream Data"
Worksheet 7: "Waste Stream or
Release Summary"
Worksheet 14: "Waste
Reduction/Release Project
Prioritization"
SQG/
non-TRI
LQG/
TRI
•
•
•
Page
No.
39
41
67
11
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Source reduction projects
A. A discussion of technical and economic considerations in
selecting each project to be undertaken.
B. A discussion of environmental and human health risks considered
in selecting each project to be undertaken.
C. An identification and discussion of cases in which the
implementation of a source reduction activity designed to reduce
risk to human health or the environment may result in the release of
a different pollutant or contaminant or may shift the release to
another medium.
D. An estimate of the type and amount of reduction anticipated.
E. A discussion of source reduction goals for the project, including
incremental goals to aid in evaluating progress.
F. A schedule for the implementation of each source reduction
project.
Waste minimization projects
A. A discussion of technical and economic considerations in
selecting each project to be undertaken.
B. A discussion of environmental and human health risks considered
in selecting each project to be undertaken.
C. An identification and discussion of cases in which the
implementation of a waste minimization activity designed to reduce
risk to human health or the environment may result in the release of
a different pollutant or contaminant or may shift the release to
another medium.
D. An estimate of the type and amount of reduction anticipated.
E. A discussion of waste minimization goals for the project,
including incremental goals to aid in evaluating progress.
F. A schedule for the implementation of each waste minimization
project.
Facility goals
A. An explanation of source reduction and waste minimization goals
for the entire facility.
B. An explanation of incremental goals for the entire facility.
Employee awareness and training programs
An explanation of employee awareness and training programs to aid
in accomplishing source reduction and waste minimization goals.
Worksheet 12: "Technical
Feasibility"
Worksheet 13: "EMS
Environmental Accounting"
Worksheet 8: "Assessment of Risk
to Human Health and the
Environment"
Worksheet 12: "Technical
Feasibility"
Worksheet 10: "Option Description"
Worksheet 3: "Goals"
Worksheet 15:
"Implementation/Installation"
Worksheet 12: "Technical
Feasibility"
Worksheet 13: "EMS
Environmental Accounting"
Worksheet 8: "Assessment of Risk
to Human Health and the
Environment"
Worksheet 12: "Technical
Feasibility"
Worksheet 10: "Option Description"
Worksheet 3: "Goals"
Worksheet 15:
"Implementation/Installation"
Worksheet 3: "Goals"
Worksheet 4: "Employee Training
Program"
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
51
63
43
51
47
23
71
51
63
43
51
47
23
71
23
25
12
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LQG executive summary (also fulfills requirements for
SQG/non-TRI reporter plan)
An executive summary of the plan (included at the end of this
outline) which shall include at a minimum:
A. A description of the facility which shall include:
Name of the facility, address, contact, general description of the
facility, including TNRCC ID numbers.
B. A list of all hazardous wastes generated and a list of all
reportable TRI releases and the volumes of each
C. A prioritized list of pollutants and contaminants to be reduced
and a statement of reduction goals
D. An explanation of environmental and human health risks
considered in determining reduction goals
E. Implementation milestones for individual project development
and an implementation schedule for future reduction goals
F. Identification and description of cases in which the
implementation of source reduction or waste minimization activity
designed to reduce risk to human health or the environment may
result in the release of a different pollutant or contaminant or may
shift the release to another medium
Certification
Certification by the owner of the facility, or, if the facility is owned
by a corporation, by an officer of the corporation that owns the
facility that has the authority to commit the corporation's resources
to implement the plan, that the plan is complete and correct
SQG/non-TRI executive summary form and certificate of
completion
Meets executive summary requirements for SQG/non-TRI facilities
Worksheet 17: "LQG Executive
Summary"
Worksheet 18: "Certification of
Completion"
Worksheet "Appendix B"
'
"
77
81
3
Where Do I Send My Summary and Reports?
Mail your executive summary and the certificate of completion and correctness to:
Industrial Pollution Prevention Team, MC-112
Office of Pollution Prevention and Recycling
TNRCC
POBox 13087
Austin TX 78711-3087
Please mark "SR/WM executive summary" on the envelope.
If you have questions about your submission or about specific WRPA requirements, call 512/239-
3100. Please do not fax your plans, executive summaries or annual progress reports, unless
requested by the TNRCC.
13
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The plan is kept on-site and is confidential. The executive summary and the certificate of
completeness and correctness are required to be submitted to the TNRCC and are available to the
public. To better inform your community of the positive pollution prevention efforts your facility
has undertaken, we suggest the executive summary be placed in your local library for easy public
access.
Could I be Exempt?
Companies may request an exemption from reporting under the WRPA from the TNRCC
executive director, if they meet all the specific requirements. This exemption request must be
resubmitted yearly. The criteria for exemption will be based on the executive director's
assessment of the following:
• the facility has reduced the amount of pollutants and contaminants generated or released
by 90 percent since the base year (1987, or first completed year of operation);
• the potential impact on human health and the environment of any remaining hazardous
waste generated, or pollutant or contaminant released; and
• a demonstration that additional reductions are not economically and technically feasible.
In order to be granted an exemption, the facility must be able to demonstrate these criteria to the
satisfaction of the executive director. The facility should then consider which would take more
time; obtaining an exemption annually, or preparing a plan once. Please note that very few
exemptions have been granted, and nearly all have been cases in which the facility is closing down
or no longer generates hazardous wastes. If you believe you qualify for an exemption, please
contact the TNRCC Office of Pollution Prevention and Recycling's Industrial Pollution
Prevention Team at 512/239-3100.
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3. Planning, Organizing, and Goal-Setting
Your pollution prevention program will affect your entire company—production, financial,
marketing, and others. This chapter presents ideas for bringing representatives from your entire
facility together to develop a company environmental policy and organize a pollution prevention
program.
A key ingredient to your success will be to train your employees in order to increase their
awareness of pollution prevention issues.
Develop a Company Environmental Policy
Your pollution prevention program depends on management support. In order for senior
management to understand what they are supporting, it may be necessary for you to draft a
corporate environmental policy outlining the program's objectives.
Beyond informing your management of the program's objectives, the policy is also senior
management's formal commitment to follow the program. With your senior management's formal
commitment you will likely find it easier to set up pollution prevention procedures. See
Worksheet 1 on page 19 for one example of a corporate environmental policy.
Organize a Pollution Prevention Program
If your company has established its environmental policy, you can use the policy guidelines to help
establish your pollution prevention program. Your program may include educational, incentive,
and waste assessment components.
Create a Pollution Prevention Program Task Force
Program task force members should include people from departments that have significant interest
in the program. In a large company, this task force may include many people, whereas in a small
company only two or three people may be involved.
Your pollution prevention program task force's primary functions will be to:
• establish a WRPA source reduction/waste minimization plan, including
15
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development of measurable goals which are consistent with the policy adopted by
management;
• implement the source reduction/waste minimization plan; and
• monitor plan results versus goals.
In selecting members, remember that the responsibilities will probably also include:
• establishing a waste tracking system;
• prioritizing waste streams for assessments;
• choosing assessment teams;
• supervising waste assessments;
• selecting and justify feasible options;
• obtaining funding and implement options; and
• promoting pollution prevention within the company.
Although group size will vary, the task force should include members of any department
interested in the program. One of the keys to a successful team is a strong leader who is
committed to pollution prevention. Use Worksheet 2 on page 21 to list your task force members
and Worksheet 3 on page 23 to list your goals.
Train Employees: Increase Their Awareness
Your facility employees are your most valuable resource. Training employees and encouraging
pollution prevention awareness stimulates them to find innovative solutions to waste generation
problems. Use Worksheet 4 on page 25 to describe your employee training strategies.
Select a Great Assessment Team
Your assessment team's job is to review and identify ways that your facility can reduce its waste.
The team will vary depending on company size, complexity, and resources. Generally, it is best to
select people in the company that will be affected by the assessment as well as those who can
contribute to the assessment. Personnel from the following areas should be considered when
developing the assessment team:
• site coordination • facilities
• operations • materials control
• engineering • shipping/receiving
• maintenance • environmental control
16
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• scheduling • research and development
• procurement • management
• accounting • quality control
• safety/legal • personnel
List your assessment team members and their duties on Worksheet 5, page 27.
17
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Worksheet 1 — Corporate Environmental Policy
Because a successful hazardous waste reduction program requires corporate commitment, it is
recommended that the policy you draft have these three features:
First, the policy should be signed by a senior officer of your corporation, preferably the chief
executive officer (CEO). The CEO's signature indicates that the policy is fully supported by all of
your company's management.
Second, the policy should contain a clear statement that it is company policy to reduce wastes and
releases of pollutant and contaminants to the environment.
Third, the policy should give you and senior management guidelines for your pollution prevention
program.
18
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Firm_
Site
Date
POLLUTION PREVENTION
ASSESSMENT
Source reduction
Waste minimization
Sheet_of_Page_of_
Project No.
Worksheet
CORPORATE
ENVIRONMENTAL POLICY
EXAMPLE — CORPORATE ENVIRONMENTAL POLICY
(Your company) is committed to continued excellence, leadership, and stewardship in protecting the
environment. Environmental protection is a primary management responsibility, as well as the responsibility of
every employee.
In keeping with this policy, our objective as a company is to reduce waste and achieve minimal adverse impact on
air, water, and land through excellence in environmental control.
Our environmental guidelines include the following:
Environmental protection is a line responsibility and an important measure of employee performance. In
addition, every employee is responsible for environmental protection in the same manner he or she is for
safety.
Reducing or eliminating the generation of waste has been and continues to be a prime consideration in
research, process design, and operations; and is viewed by management like safety, yield, and loss
prevention.
Source reduction/waste minimization (reuse and recycling) of materials has been and will continue to be
given first consideration prior to classification and disposal of waste.
Chief Executive Officer
19
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Worksheet 2 — Program Task Force
Use Worksheet 2 to list your program task force members. Three unique functions you might
need to fill are:
Program manager — The program manager is responsible for the entire program including plan
development and pollution prevention assessments. A pollution prevention assessment is a review
opportunities to reduce, recycle, and minimize waste. Area coordinators and assessment team
coordinators are helpful in making these assessments.
Area coordinators — Does your company have more than one site? If so, break your
responsibilities up into site-specific tasks, and get the help of a coordinator at each site.
Assessment team leaders — Assessment team leaders coordinate activities concerning a specific
pollution prevention project and brings together all aspects of the assessment including waste
audits, option generation, engineering, costs, and financial evaluations.
20
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Firm_
Site
Date
POLLUTION PREVENTION
ASSESSMENT
Source reduction
Waste minimization
Sheet_of_Page_of_
Project No.
Worksheet
PROGRAM TASK FORCE
Function
Name
Location
Phone number
Program manager
Organization Chart
(sketch)
21
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22
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Worksheet 3 — Pollution Prevention Goals
Separate goals should be set for both source reduction and waste minimization efforts at the
facility. Goals should include tools to aid in evaluating progress. The company's plan should also
explain both overall goals and incremental goals for the entire facility.
When setting goals, make sure they are flexible, measurable, motivational, understandable, and
achievable with a reasonable level of effort.
23
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Firm_
Site
Date
POLLUTION PREVENTION
ASSESSMENT
Source reduction
Waste minimization
Sheet_of_Page_of_
Project No.
Worksheet
POLLUTION PREVENTION
GOALS
Pollution prevention goals
24
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Worksheet 4 — Employee Training Program
Training is critical to the success of a company's pollution prevention program. Companies should
set goals to help all employees achieve pollution prevention, regardless of the level of knowledge
or experience in the environmental area.
If your company does not have a program in place, now is a good time to start. Worksheet 4,
"Employee Training Program," includes a checklist of important employee training areas.
25
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Firm_
Site
Date
POLLUTION PREVENTION
ASSESSMENT
Source reduction
Waste minimization
Sheet_of_Page_of_
Project No.
Worksheet
EMPLOYEE TRAINING
PROGRAM
Checklist questions:
1. Do you have a pollution prevention training program in place at this time?
2. Is the training program open to all employees?
3. Do key personal require additional training or in-depth training?
4. Have all employees on the task force completed the training program?
5. Does the training course include information on pollution prevention definitions and laws?
Comments or further explanation of the training program.
yes/no
26
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Worksheet 5 — Assessment Team Make-Up
In a small business, the assessment team may be limited to one or two individuals responsible for
facility operations. Each team should include people with direct responsibility and knowledge of
the particular waste streams or plant areas. A team leader should be chosen who is familiar with
the facility, the people, and the processes. It is also very important for the team leader to want to
reduce and eliminate wastes and releases.
On Worksheet 5, fill in the information on the assessment leader and the team members.
27
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Firm
Site
Date
POLLUTION PREVENTION
ASSESSMENT
D Source reduction
D Waste minimization
Worksheet
5
Function/Department
Assessment team leader
Assessment team
ASSESSMENT TEAM
MAKE-UP
Sheet of Page of
Proiect No.
1 U
TNRCC
Name
Telephone
Duties
28
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4. Doing Your Pollution Prevention Assessment
A pollution prevention assessment is a review of a company's opportunities to reduce, recycle,
and minimize waste. The assessment results can be used for planning and allocating resources for
pollution prevention projects, as well as setting the 'baseline' for measuring future pollution
prevention progress. All facilities generating hazardous waste or releasing or transferring toxic
chemicals can benefit from an assessment. The level of detail and exact approach each facility
takes in performing the assessment depends the size of the company, the number of waste
streams, and many other factors.
This chapter contains information on how to perform an assessment. The worksheets can provide
you assistance. You can use many of these worksheets to document the assessment phase of a
source reduction and waste minimization plan as required under WRPA.
There are four major components to conducting a pollution prevention assessment:
• identifying waste streams to eliminate;
• assessing the risk each waste stream represents;
• prioritizing waste streams to reduce; and
• identifying pollution prevention options.
Remember that visiting your site and talking with the employees is essential for completing the
above components. They have an understanding of the plant's functions and inefficiencies that
will prove valuable. Ask questions.
Before visiting the site, all assessment team members should review the processes so they can
evaluate the various processes and ask pertinent questions.
The inspection should cover a full array of process flows and areas of operation at the plant
including:
• shipping and receiving areas
• raw material storage areas
• waste generation points
• waste storage area
• product/by-product areas
• unit processes
29
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Other suggested activities for the team to undertake during the walk-through are:
• document what you see and take notes;
• carefully observe operations and procedures;
• discuss processes and wastes with shop-level employees;
• check for odors, leaks spills, and drips; and
• review waste materials in department trash bins and cans.
Identify Waste Streams to Eliminate
Table 2, "Avenues of Waste," represents areas where waste streams are generated throughout a
process. Every arrow coming out or below the diagram represents a waste. Your initial goal will
be to identify where wastes occur, how much waste is generated, and what risks the wastes pose,
based on the way it is managed. Worksheets 6, 7, and 8 will assist you in documenting this
information.
Table 2. Avenues of Waste
AVENUES OF WASTE
30
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Where does Waste Happen?
When conducting your site visit, look at the big picture for your facility. What wastes do you
see? You may find opportunities to reduce your wastes in every step of your process. Common
avenues of waste include:
• container leaks and spills;
• materials with an expired shelf life;
• infrequent equipment maintenance; and
• improper product handling.
How Much Waste Happens?
Once your team completes the inspection, take some type of approach to analyze the waste
streams and their processes. One method is the material balance approach. Utilize data from the
process and waste stream worksheets (6 and 7) and information from the site inspection.
According to the material balance approach, the weight of all materials entering the process must
equal the weight of all the materials leaving the process. When the final product comes out
weighing less than the amount of materials that went in, the difference is the amount of waste
generated. Locating the reduction possibilities for this waste is your assessment's goal.
To complete your material balance calculations:
• examine each unit and prepare a process flow diagram for each process
• identify all inputs for each unit process (including raw materials, containers, reused waste
and process water)
• identify all unit process outputs (including products, by-products, wastes to be recycled
and disposed)
• identify waste losses by tracking the process using a flow chart
Obtaining an overall picture of the plant's operation and its weaknesses (if any) will help the
assessor(s) determine the areas with the most potential for pollution prevention.
How is That Waste Managed?
You need to know what you do with that waste now—and what effects that waste management
strategy is having—in order to have an idea what effect a different strategy will have.
31
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Determine whether one waste stream management method would be better than the one currently
used. You may find, for example, that a waste you are currently sending off-site for disposal may
be recycled on-site. Look for ways to move your wastes up the waste management hierarchy as
illustrated in Chapter 1 of this manual.
Use Worksheet 7, "Waste Stream Summary," to describe your waste stream management
methods.
Assess the Risk Each Waste Represents
Answering key questions concerning your facility's wastes will assist you in determining the risk
each waste represents. Remember that risk depends on operational procedures and precautions
taken (or not taken) at a facility.
In assessing risk you should consider the waste's:
• compound (chemical) characteristics;
• health hazards; and
• environmental hazards.
Addressing these considerations will help you better determine the potential for risk. Although
this determination is subject to the individual judgement of your assessment team, it will help
others make their own decision about the level of risk associated with each waste stream.
Worksheet 8 "Assessment of Risk," on page 43 will help you determine your waste streams' risk.
Prioritize Your Waste Streams
Prioritizing your waste streams is important in determining which pollution prevention projects
your facility will implement.
The general approach to prioritizing waste streams involves these steps:
> consider the risk presented by the waste; and
*• consider each of the questions below:
• What is the disposal current cost, and if possible, how high or low will future costs
go?
• Examine the current environmental regulations (federal, state, and local), and
potential future laws. Do these laws inhibit current processes for a waste stream or
32
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are they likely to in the future?
• Are the raw material costs high? Might they increase to an unacceptable level
sometime in the future? Are alternative materials available?
• Does the waste pose a direct, immediate, or perceived threat to the workers, the
public, and the environment?
• Does a waste create problems for processing, handling, storing, and discharging?
• How much volume is generated? Will future capacity issues be a problem?
• How long will a chemical (compound) will be hazardous?
Worksheet 9 on page 45 offers a simple system for prioritizing your waste streams efficiently.
Identify Your Options
Your next step in the assessment process is to identify your pollution prevention options. Use
Worksheet 10, page 47 to outline options your facility has identified.
As noted in Chapter 1, the Texas Solid Waste Disposal Act outlines an order of preference when
considering waste management options. Those options are discussed below:
Source Reduction
The rules governing Texas source reduction and waste minimization planning are covered in 30
TAG §335, Subchapter Q. In general, source reduction includes any activity that reduces or
eliminates the generation of hazardous waste at the source or the release of a pollutant or
contaminant, usually within a process.
Source reduction options include technological and material changes as well as changes in
procedure and organization.
The following are specific source reduction activities your facility may want to consider:
Good Operating Practices
• Separate types of hazardous waste to make them more amenable to recycling
• Separate hazardous waste from nonhazardous waste
• Improve maintenance scheduling, record-keeping, or procedures
• Change production schedule
• Other changes in operating practices
33
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Process Modifications
Institute recirculation within a process
Modify equipment, layout, or piping
Use of a different process catalyst
Institute better controls on operating bulk containers to minimize empty container disposal
Change from small containers to bulk containers to minimize empty container disposal
Other process modifications
Inventory Control
Institute procedures to reduce outdated material
Test outdated material
Eliminate shelf-life for stable materials
Use better labeling procedures
Institute clearinghouse to exchange materials
Other changes in inventory control
Surface Preparation and Finishing
Modify spray systems or equipment
Substitute coating materials used and/or improve application techniques
Change from spray to other system
Other surface preparation and finishing modifications
Spill and Leak Prevention
Improve storage and stacking procedures
Improve procedures for loading, unloading, and transfer operations
Install overflow alarms or automatic shut-off valves
Install vapor recovery systems
Implement inspection or monitoring program of potential spill and leak sources
Other spill and leak prevention activities
Cleaning and Degreasing
Modify stripping/cleaning equipment
Change to mechanical stripping/cleaning devices (from hazardous solvents to other
materials)
Change to aqueous cleaners
Modify containment procedures for cleaning units
Improve draining procedures
Redesign parts racks to reduce drag out
34
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• Modify or install rinse systems
• Improve rinse equipment design and/or operation
Raw Material Modifications
• Increase purity of materials
• Substitute nonhazardous for hazardous raw materials
• Other raw material modifications
Product Modifications
• Change product specifications
• Modify design or composition of product
• Modify packaging
• Other product modifications
Waste Minimization
Waste minimization is defined in Texas as any practice that reduces the environmental or health
hazards associated with hazardous wastes, pollutants, or contaminants. The most common waste
minimization methods are reuse, recycling, and some forms of treatment.
For WRPA plan and annual progress report purposes, examples of waste minimization may
include reuse, recycling, neutralization, and detoxification. The federal Environmental Protection
Agency (EPA) definition of waste minimization differs from the Texas definition. In federal
programs, waste minimization is defined as source reduction plus recycling.
The goal of recycling is to recover or reclaim unused material. Generated material can be
recovered either on-site or off-site, depending on the quantity of waste generated, the capital and
operating costs, and availability of in-house expertise.
An alternative to on-site recycling is the use of waste exchanges, which aid in the transfer of
wastes from the generator to another company. Companies interested in waste exchanges can list
and request wastes through the TNRCC RENEW (Resource Exchange Network for Eliminating
Waste) program. The RENEW program helps bring together waste generators and potential
users. For more information on RENEW, contact the TNRCC's Office of Pollution Prevention
and Recycling at 512/239-3100 or visit the RENEW Web page at
http://www.tnrcc.state.tx.us/admin/topdoc/pd/002.
Like source reduction, examining waste minimization options may require outside research. Each
35
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facility's processes and waste streams are unique; a large amount of knowledge may be required to
make an informed decision regarding recycling options.
Treatment Options
Treatment of waste ranks third, below source reduction and recycling, in the state hierarchy of
waste management. If no source reduction, reuse, or recycling option is viable, treatment must be
considered as an option before land injection or disposal.
If the business does not meet each of these requirements and treats hazardous wastes on-site, it
must obtain a RCRA hazardous waste treatment permit. A business may not dispose of its
hazardous waste on-site unless it has obtained a RCRA treatment, storage, or disposal facility
(TSDF) permit. Obtaining a permit is a complex, costly, and time-consuming process. The
process is described in Title 40 of the Code of Federal Regulations (40 CFR 270) and in 30 TAG
Chapters 305 and 335.
If a business has determined that its wastes are not hazardous as defined by the EPA or the state,
it should still take steps to ensure that it is complying with all applicable federal and state
requirements for disposal of nonhazardous waste. It should make all reasonable efforts to ensure
that nonhazardous waste are handled in a way that prevents uncontrolled release to the
environment and the potential future liabilities associated with such releases. A waste can be
classified as nonhazardous and still contain some hazardous chemicals and have the potential to
cause harm to human health or the environment if improperly treated, stored, or disposed.
By answering the questions on Worksheet 11, page 49, you can determine which treatment
options are feasible.
Finding More Ideas
When you are looking for ways to cut waste, don't forget one resource that is always
available—the people who work in your facility every day. Your engineers and operators might
come up with the most practical solutions.
If you look to the outside, consider these sources of information:
• State and local environmental agencies — The TNRCC's Office of Pollution
Prevention and Recycling offers many programs to help businesses and industries
including technical guidance documents, site visits, and workshops. See Appendix F for
36
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more information about available TNRCC resources.
• Equipment vendors — Equipment vendors and other service companies are excellent
sources for identifying equipment-oriented options. Vendors are eager to assist companies
in implementing projects and, in some cases, set up bench-scale test programs.
• Trade associations — Trade associations generally provide assistance and information
about environmental regulations and techniques for complying with these regulations.
• Pollution prevention case studies — The University of Texas at El Paso hosts and
maintains a Web site containing TNRCC pollution prevention case studies at
http://p2.utep.edu/p2/casestudies/p2main.cfm.
• Gulf Coast Hazardous Substance Research Center — The Center at Lamar University
coordinates the activities of a consortium of eight universities to concentrate in the areas
of source reduction, waste minimization, and alternate technology development. For more
information, call 409/880-8768 or refer to the GCHSRC Web site at
http://www.gchsrc.lamar.edu.
• Published literature — Technical magazines, trade journals, government reports, and
research briefs often contain useful pollution prevention information. See Appendix F for
information regarding TNRCC and EPA guidance documents.
• The Environmental Protection Agency (EPA) — The EPA provides many pollution
prevention services, including clearinghouses, databases, bulletin boards, periodicals and
directories, and hot lines. An overview of EPA offerings can be obtained by ordering the
Pollution Prevention Directory (EPA742/B-94-005) from EPA's Pollution Prevention
Information Clearinghouse (PPIC) at 202/260-1023.
The Web sites of the TNRCC (http://www.tnrcc.state.tx.us) and the EPA (http://www.epa.gov)
also have useful information. For a list of helpful publications and the EPA, see Appendix F.
Many of these publications are tailored to a specific industry—perhaps yours!
Once your initial assessment is complete, you should have a list of pollution prevention options.
You can then evaluate potential projects and select the most promising of them based economic
and technical considerations.
37
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Analyze Technical Aspects
The next step in your pollution prevention assessment is to conduct a technical evaluation of your
options. The technical evaluation examines each option considered, regardless of whether it could
be part of current operational procedures. Process changes may need to be tested or researched.
First, define the problem. Many of the solutions to waste generation are very simple. For example,
the problem is not how to consolidate partially empty drums into a single drum for waste disposal,
but rather answer the question: "Why weren't the drums completely emptied?"
Employees who are familiar with the process and equipment can often contribute valuable ideas to
help in the technical feasibility. By listening to employee suggestions and adding engineering
skills, simple, common sense solutions to the problem may become evident.
Because performing a technical feasibility evaluation requires comprehensive knowledge of source
reduction techniques, vendors, relevant manufacturing processes, company resources, and facility
limitations, a consultant may be necessary. For equipment-related options or process changes, the
assessment team may wish to arrange visits to see other businesses.
By selecting up-to-date equipment that prevents pollution and is efficient, waste can be prevented
before it becomes a problem. Since there may be several types of equipment from which to
choose, making the best choice is not always an easy task. Equipment vendors can also be of use
and may install equipment on a trial basis. If using a vendor, it is advisable to seek a second
opinion and to work with more than one vendor.
There are many important considerations involved performing technical evaluations; some key
ones are listed on Worksheet 12, "Technical Feasibility."
Chapter 5, "Analyzing the Feasibility of Each Project," will assist you in determining the
economic feasibility of your options.
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Worksheet 6 — Process and Waste Stream or Release Data
One of the keys to a successful pollution prevention program is a good-cradle-to-grave tracking
system. The pollution prevention battle is almost won when a company knows the type and
location of their chemicals, waste streams, or releases.
Identify each process or waste stream separately. Use a separate worksheet for each waste stream
or release. This worksheet lists several important documents that provide valuable facility
information.
Beside each of the listed documents, check whether the document is available or not and if it is
current. There is also a space to include the location of the document.
39
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Firm_
Site
Date
POLLUTION PREVENTION
ASSESSMENT
Source reduction
Waste minimization
Sheet_of_Page_of_
Project No.
Worksheet
PROCESS AND WASTE
STREAM DATA
Document
Process flow diagram
Material balance
Flow/amount measurements
Stream number
Stream analvses
Stream number
Input materials to process
Shipping/receiving inventory
Process description
Operating manuals
Equipment list
Equipment specification
Piping and instrument diagrams
Hazardous waste manifest
Work flow diagrams
Material safetv data sheets
Production schedules
Emission inventories
Environmental audit reports
Batch sheets
Permit/permit applications
Notice of registration
Available ?
Current ?
Location
40
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Worksheet 7 — Waste Stream/Release Summary
The "Waste Stream/Release Summary" worksheet summarizes the most important information
gathered from the documents identified in Worksheet 6. This worksheet will help the assessment
team prioritize the waste streams or releases and processes at the facility.
This worksheet can also provide the company with documented proof of pollution prevention
assessment efforts for each waste stream or release. It is important to report quantities
consistently using the same unit of measure. For WRPA reporting purposes, please report your
wastes and releases in tons.
• Process/operation — Briefly describe the type of process or operation (e.g. batch,
continuous, semi-batch, etc.)
• Waste/release name — Include the identification number and name of the waste.
• Source/origin — Determine and write down the point of waste generation or release.
• Component/attribute of concern — Include a list of all chemicals and amounts found in
each waste stream or release. Also include a list of all hazardous characteristics found in
the waste streams.
• Amount of waste generated or toxics released — Record the amount of waste or toxics
released or generated for a period of time (e.g., tons per year).
• Consumption rate (input) — Determine the annual consumption rate by identifying
amount of input materials required, in a given year, for production in a process (optional;
for throughput calculation).
• Production rate (output) — Determine the annual production rate by identifying the
amount of product produced in a given year (optional; for throughput calculation).
• Cost of disposal — Calculate the cost of disposal by including unit and overall cost.
• Method of management — Identify the method of management for each waste stream.
These are a few examples of management or disposal methods:
• disposed in a landfill • incineration
• on-site recycling • air releases
• combustion with heat recovery • distillation
• dewatering • deep-well injection
• discharges to surface water • transfers to POTW
41
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Firm_
Site
Date
POLLUTION PREVENTION
ASSESSMENT
Source reduction
Waste minimization
Sheet_of_Page_of_
Project No.
Worksheet
7
WASTE STREAM SUMMARY
1
INRCC
Descriptions
1. Process/operation
2. Waste name
3. Source/origin
4. Component/attribute of concern
5. Amount of waste generated
*6. Consumption rate (input)
*7. Production rate (output)
8. Disposal (waste)
9. Method of management
10. Possible alternate management methods
42
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Worksheet 8 — Assessment of Risk to Human Health and the Environment
Depending on the recorded information for each of the questions, estimate the "Level of Risk" for
each issue.
You can find information that will help you describe compound characteristics and health hazards
in the NIOSH Pocket Guide to Chemical Hazards. This guide is available through the U.S.
Department of Health and Human Services, Public Health Service, Centers for Disease Control,
National Institute for Occupational Safety and Health. Another useful source is Dangerous
Properties of Industrial Materials by N. Irving Sax and Richard J. Lewis, Sr.. You should also
review the MSDSs required by law to accompany all chemicals. If you do not have your MSDSs
readily available, the EPA maintains a Web site containing both chemical substance fact sheets and
MSDSs at http://tis.eh.doe.gov.
The third category, environmental hazards, addresses ways in which the environment is or could
be exposed to compounds in the waste stream, and the potential risks associated with this
exposure. In assessing environmental hazards, consider the exposure pathway. For example, what
is the proximity of your waste stream to waterways, schools, parks, and residents? Record this
information as it will help you evaluate your facility's overall risk.
Another important issue to consider is the health of wildlife and plants near your facility. It is
important that you designate someone to observe and be aware of the health of wildlife and plants
near the facility at all times. This will be especially important if a decline or increase in population
is noted.
43
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Firm_
Site
Date
POLLUTION PREVENTION
ASSESSMENT
Source reduction
Waste minimization
Sheet_of_Page_of_
Project No.
Worksheet
8
ASSESSMENT OF RISK
1
Questions:
1. Compound (or chemical) characteristics:
a. Chemical name:
b. Exposure limits:
c. IDLH (immediately dangerous to life or health) level:
d. Chemical and physical properties:
-
2. Health hazards:
a. Route of health hazard (inhalation, skin absorption, ingestion, eye contact):
b. Symptoms:
c. Target organs:
d. Level of toxicitv:
e. Known carcinogen?:
Level of risk: high,
medium or low
la.
Ib.
Ic.
Id.
2a.
2b.
2c.
2d.
2e.
44
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3. Environmental hazards:
a. Type of exposure (air, land, or water): 3a.
3b.
b. Exposure routes (incinerator, surface containers, underground tanks,
underground injection wells, etc.): 3c.
c. Observation of wildlife and plant health near the facility: 3d.
_d. Proximity (miles, feet) to the following:
School Day care center
Residents Church
Park Restaurants
Other 3e.
e. Proximity (miles, feet) to waterways (ponds, wells, springs, rivers, etc.):
f. Provide brief schematic of facility and the surrounding area.
45
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Worksheet 9 — Waste Stream Prioritization
All waste streams and processes should be reviewed for pollution prevention opportunities.
However, this is not always possible. It is often necessary to prioritize the waste streams and
releases.
The questions listed on the worksheet should be assessed in the following ways:
• Relative weight (W) should be assessed on a plant wide basis, according to each of the
eight criteria listed on Worksheet 8. The relative weight should be between 1 and 10 (1 =
not important, 10 = most important). The weight will depend on company goals, pollution
prevention goals, and other factors. Since the weight reflects company policy, the relative
weights will remain constant on all the waste stream/release sheets.
• Rating (R) represents a waste stream's rank and will vary from one waste stream/release
to the next. The rank for each criteria will reflect the need for waste reduction. The rating,
similar to the relative weight (W), should also be done on a scale of 1 to 10.
The relative weights (W) should be multiplied by each rating (R) to fill in column (R x W). Then
add the (R x W) columns to calculate the sum of priority ratings. Comparing the waste stream
sheets with one another will enable the team to give each stream a priority rank.
46
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Firm_
Site
Date
POLLUTION PREVENTION
ASSESSMENT
Source reduction
Waste minimization
Sheet_of_Page_of_
Project No.
Worksheet
WASTE STREAM
PRIORITIZATION
Waste stream ID:
Priority rating criteria
1. Cost of disposal
2. Environmental regulations
3. Raw material cost
4. Threat to workers, public, and
environment
5. Processing problems
6. Amount of waste generated
7. Residual lifetime
8. Other areas of concern
Sum of priority ratings
Priority rank
Relative
weight (W)
PI ant- wide
Rating
(R)
Waste stream
SUM (R x W)
Rx W
47
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48
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Worksheet 10 — Source Reduction/Waste Minimization Options Description
The first section of Worksheet 10 provides space to record the possible source reduction or
recycling option, and a short description of this option. Estimating the amount of waste reduction
is a WRPA requirement. The estimated waste reduction should specify the amount reduced and
the time involved.
The second section includes an area to indicate the type of option described; whether it involves
source reduction or recycling. This section is also necessary to meet the WRPA planning
requirements.
In the last section, record the names of the person responsible for the option proposal and the
reviewer. Finally, record the decision to approve study of the option and the reason for accepting
or rejecting the option proposal. This explanation is extremely important and should be as explicit
as possible.
Note: This worksheet could be utilized as an employee suggestion form.
49
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Firm
Site
Date
Worksheet
10
Option name:
POLLUTION PREVENTION
ASSESSMENT
D Source reduction
D Waste minimization
Sheet of Page of
Proiect No.
^^^^m
^^g ^^^^g
1 ^^88
MM
TNRCC
1 11IIUU
1
50
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Briefly describe the option:_
Waste stream(s) affected:
Input material(s) affected:.
_Product(s) affected:
Estimated waste reduction:
Indicate type:
Source reduction
Recycling/reuse
On-site
Off-site
Equipment-related change
Personnel/procedure-related change
Material reused for its original purpose
Materials-related change
Material recycled
Material sold
Other
Other
Originally proposed by: Date:
Reviewed by: Date:
Approved for study: yes no, By:
Reason(s) for acceptance or rejection:
51
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Worksheet 11 — Treatment Feasibility
The questions on Worksheet 11 will help you evaluate treatment feasibility. The last part of this
worksheet includes space for final comments about the technical feasibility of the treatment
options under consideration and should help in justifying or explaining the treatment option
selection. Comments may include especially detrimental or beneficial results of the option.
Note: Some forms of treatment may not count toward waste minimization. However, they are still
preferred by the TNRCC over injection and land disposal.
52
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Firm_
Site
Date
POLLUTION PREVENTION
ASSESSMENT
Source reduction
Waste minimization
Sheet_of_Page_of_
Project No.
Worksheet
TREATMENT FEASIBILITY
1
Option:,
Questions:
1. What is the hest available method to treat the waste?
a. Treatment to destroy the hazard
b. Treatment to reduce the hazard
c. Neutralization
d. Bioremediation
e. Vitrification
2. What tvne of containment system will he used for treatment?
3. Will the containment system meet RCRA regulations?
4. How long will waste he stored hefnre treatment?
Comments:
53
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Worksheet 12 — Technical Feasibility
Worksheet 12 provides a list of questions to help evaluate each source reduction option's
technical feasibility. For question 15, it is important to note that concentration is not source
reduction. Reduction in water usage may have the ultimate effect of increasing pollutant
concentrations in the waste water. Therefore, any reduction in water usage without a
corresponding reduction in pollutants should be handled cautiously.
The last part of this worksheet includes space for final comments about the technical feasibility of
the source reduction option under consideration. This should help in justifying or explaining the
source reduction option selection. Comments may include detrimental or beneficial option results.
54
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Firm_
Site
Date
POLLUTION PREVENTION
ASSESSMENT
Source reduction
Waste minimization
Sheet_of_Page_of_
Project No.
Worksheet
12
TECHNICAL FEASIBILITY
1
Option:.
Questions:
Is space available or will new construction be required?
9.
Are utilities available or must these be installed ?
Is the new equipment or technique compatible with current operating procedures, work flow, and
production rates ?
Will product quality be maintained ?
How soon can the system be implemented ?
Will installation stop production ? How long?
Will training be required for the new system?
Does the system alleviate or create human health and environmental problems?
Is the system safe?
10.
Are there any regulatory barriers? Are permits necessary?
11.
Does the vendor provide acceptable service?
12.
Did production, maintenance, and purchasing groups contribute to the technical evaluation?
13.
Is additional labor required?
14.
Is new design required for the system? Can the design be done in-house?
15.
Does a similar system currently exist?
16.
18.
Could water use reductions result in a more concentrated wastewater?
17. Could the system result in the release of a different pollutant or contaminant, or shift the release to
another medium ? If so, describe.
What is the approximate time estimate of the project completion?
19.
What impact does failure of the system have on production, and is a backup system required?
55
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5. Analyzing the Economic Feasibility of Each Project
In the previous chapter, pollution prevention options were selected for closer review and
examined for their technical feasibility. Each source reduction, recycling, or treatment option
should now be examined in more detail using the economic feasibility analysis.
Analyze Economic Aspects
Economic feasibility studies have two benefits:
• Efficiency — identify areas to reduce waste and save money; and
• Evaluation — compare options identified in the technical feasibility study.
By examining economic feasibility, companies save money while reducing waste. This is possible
because waste is, by definition, inefficient use of raw materials. Isolating the costs associated with
wastes allows a company to make an informed decision when implementing their plan.
The core elements of evaluating the economic feasibility of a pollution prevention option are:
• Waste cost evaluation: What is it costing you to generate waste?
• Project cost evaluation: What are the pollution prevention option's costs and potential
savings?
• Comparison: Does the option cost or save money?
Pages 52 through 60 provide detailed information for conducting your economic analysis. Use
Worksheet 13 to show the results of your analysis.
Prioritization
Once you have calculated the total cost of doing business under the current system, you can
compare that cost to the cost of implementing the options you have identified in your technical
evaluation. By going through a detailed economic feasibility study you can identify which option
will save you the most money.
The final step in the feasibility analysis is ranking waste reduction projects. After completing
Worksheet 14, "Waste Reduction Project Prioritization," all projects should have a priority rank.
56
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This will enable the task force to choose the order of pollution prevention projects to be
undertaken.
Crayons to Computers: How Complex Should Your Analysis Be?
WRPA requires an analysis of project's economic feasibility but does not specify how detailed
your analysis must be. Your analysis depends on a variety of factors such as the number of
projects you have, how much capital is needed, internal company policies, etc.
The level of analysis depends on one's needs. For example, some people never reconcile their
personal checking accounts. They have a rough idea of how much they spend, and keep a small
buffer in the account. They may never bounce a check, but aren't always sure where the money
goes. Other people may use software to identify exactly how much money they spend and where
they spend it. These people are able to spot waste in their spending habits and manage their
money more efficiently.
Likewise, with WRPA, your economic analysis may be minimal, ensuring only that the project
doesn't cost too much. This is particularly effective on simple projects. However, a simple cost
comparison could overlook some of the hidden costs, such as labor, liability and regulatory
compliance. To get the most benefit from your plan you may wish to sharpen your pencil and do a
full cost accounting of your projects.
Crayon Accounting: Preliminary Screening
If you have several options, you might want to start your economic feasibility analysis by
comparing the costs of the different projects to identify some of the better projects and to
eliminate some of the impractical options. A simple analysis is particularly good at identifying the
"low-hanging fruit," or options that are easy and inexpensive to implement.
For example, Joe's Paint Shop generates hazardous waste as a result of paint booth operations.
Ed, the shop manager, worked with the employees to develop four options:
57
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1
2
3
4
Option
Rotating filters
Substitute filters for
baffled Styrofoam
elements
Switching to water
based paints
Automated paint gun
washing system
Saves Money by:
Filters last twice as long because ones in
low-use area are switched out with ones in
high-use areas.
Lasts four times longer between
replacements and can be washed off for
reuse.
Water-based paints to meet our needs are
more expensive.
Saves on labor, solvent usage. Reduces gun
clogging.
Savings
$5.00/filter
or
$100/year
$5.00/filter
or
$200/year
?
$900/year
Costs
minimal
$10/filter
or
$100/year
2.00/gal
$800
(once)
Even a simple look at the options showed Ed three things:
• Option 1 saves money; the only costs are for a worker to take a few minutes to rotate the
filter. The shop adopted this option immediately.
• Option 2 costs more initially, but the savings are realized quickly, so they adopted this
option as well.
• Options 3 and 4 looked promising, but Ed decided to do a more detailed analysis before
adopting them.
For options 1 and 2 no further work is needed. Ed wrote "By substituting filters for baffled
Styrofoam elements, we will save $100 a year. Rotating the filters to extend their life span will
save another $100 a year." This met the requirements for an economic feasibility analysis in his
plan and executive summary.
Of course, an analysis like the one above only tells part of the story. More detailed accounting of
option 3 would reveal savings. For instance, under the current system, the shop has to dispose of
the protective clothing as hazardous waste. By switching to option 3 they could reduce disposal
costs, and the clothing would last longer.
The next few sections cover how to use economic analysis to identify ways to save even more
money by reducing waste.
58
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Using a Pencil: Identifying Hidden Costs
Many facilities are not aware of how much they spend on hazardous waste. These costs are
usually counted as overhead. By identifying the hidden costs, the company can identify
opportunities for savings.
In the following example, an auto shop office manager attributed the environmental costs to the
process area. By doing this, she was able to identify inefficiencies and convince some mechanics
to switch to nonhazardous solvents.
Two bays at an automobile repair shop use parts washers. Bay 1 has switched to nonhazardous
parts washer, while auto bay 2 uses a hazardous solvent to clean parts. The solvent is picked up
by a company and recycled off site. Sally, the office manager, would like to switch bay 2 to a
nonhazardous solvent, but the repair technicians claim the soap washers slow down work. The
owner agreed with the bay 1 mechanics because he saw that they were repairing vehicles quicker
than bay 2.
Sally looked at some of the true costs of using a hazardous solvent:
Bay 1 costs
Hazardous solvent costs
costs to pick up waste solvent
Total costs
$3.00/gal) x (l,500gal/yr) =
(4 drums/year) x $450/drum
$4,500/yr
= $l,800/yr
$6,300/yr
Even though the soap costs more per gallon, the mechanics use less. Over a year, they purchase
over a thousand gallons less soap than hazardous solvents.
Bay 2 costs
Soap solvents
pick up costs
Total costs
($5.00/gal)x (300gal/yr) =
$l,500/yr
$0.00/yr
$l,500/yr
Bay 2 cost the service station at least $4,800 more than bay 1! Once the owner realized how
much it cost to use the hazardous solvents, it didn't take long for Bay 2 to switch.
59
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In the previous example, Bay 1 was viewed as more profitable, when in fact they were simply
shifting the cost of handling the waste out of the area. Both bays were paying Bay 1's waste
expenses.
Sharpening the Pencil: Full-Cost Accounting
Of course, the only way to be reasonably sure of a project's economic feasibility is to look at all
of the costs of doing business under the current system. Once you have determined that cost, you
can look at all the costs and savings from implementing your project. You can then compare the
old way to the new way and make an informed decision.
Worksheet 13 is a tool for doing full cost accounting. The worksheet will guide you through six
basic steps to save money by reducing waste:
• draw an input/output 'picture' of each step or process in your business;
• figure how much the raw materials cost for each process;
• calculate your costs to dispose of the waste for each process;
• determine how much you spend to comply with laws for waste you generate;
• add up all of the costs of managing waste; and
• look for ways to reuse or recycle materials, lower costs, and save money.
Dr
eac
do
C
STEP 1
^
STEPS 2 & 3
^
STEP 4
^
STEPS 5 & 6
iwing a picture for How many costs and Identifying the details Money you can save
h step of what you how much total cost in the "pictures"
Process mannine) (Identify the cost of waste) (The cost of compliance) (Cost savings from waste
rr & reduction)
After you have completed these steps, you will:
notice hidden overhead costs;
see things you do in your business that cause waste;
locate areas where you can reduce your waste;
determine operational efficiency;
measure what it may be costing you to dispose of reusable or recyclable things;
find places where you can reduce your costs, save money, and be a cleaner
business.
Economic Analysis, Step by Step
60
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Conducting an economic analysis of your facility's processes may appear to be an involved and
complicated process. By following the steps below and working through Worksheet 13 on pages
63 through 64, you may not only find the process much simpler than you imagined, you may find
the benefits you gain are well worth the effort.
Step 1: Draw a Picture of What You Do
Track the inputs (supplies) used and outputs (wastes) created during each step or process. For
example, imagine that one process in your business involves cleaning the presses with petroleum-
based solvent. You may have many processes in your operation, but for the example, we will look
only at one process. On the next page, there is an example of how the worksheet is used to track
the inputs and outputs for the press cleaning step. Once the inputs and outputs are identified in
Step 1, how the outputs are disposed of is recorded in the far right corner of Step 1.
Step 2: Determine Traditional Input (Supply) Costs per Process per Year
Determine your annual costs for each of the inputs in this process. This includes the cost of labor
and materials. In Step 2 of the example, notice that there is a total cost for doing this one process
throughout the year (A). Your calculations will vary depending on the process.
Note: You will have to calculate the costs for each process in your operation separately and will
need a separate worksheet for each process. Make copies of the blank worksheet to enter costs
for other processes.
Step 3: Determine Traditional Output (Disposal) Costs per Process per Year
Determine your annual costs for each output (disposal) connected with this process. The example
in Step 3 demonstrates the amount spent on each type of disposal method for this process and
then adds them all up for a total cost to dispose of all wastes from this process (B).
Step 4: Identify Hidden Costs per Year
In this step you may identify some of the costs for this process that may be hidden in your
overhead or other accounts such as permit fees and training costs. These additional costs must be
paid by you, but usually do not add value to your final product. Finding the exact dollar amount is
not as important as identifying the various compliance costs linked to the process. In the example,
the costs were estimated and totaled for the year (C).
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Step 5: Sum Total Costs per Year
Add up the cost of materials going into the process (A), the cost of disposal of excess materials
(B), and any hidden costs (C). In the example worksheet, we calculated the total cost for cleaning
the presses. By knowing what each process (press cleaning, for example) costs your business, you
can start to manage your costs more effectively and save money.
Now that you have done the example for Steps 1 through 5, you can use this information to find
ways to save money. Step 6 is to compare the cost of doing business as it is now with alternatives
designed to reduce your waste at the source and save you money. After reading the example, use
the back of the worksheet to identify areas in your business where you can save money.
Step 6: Compare Costs Using a Waste Reduction Option
After determining the cost of materials that are being used, and the cost to dispose of the left over
materials, as well as any hidden costs, you now want to see if you can reduce, reuse or recycle any
of those left over materials. Based on their technical feasibility study, the company decided to a
solvent recycling unit. It reduces raw materials and labor needed to do clean up (see the example
below). Other processes may need different waste reduction options.
The table below makes several assumptions about solvent distillation units based on information
gathered from vendors. Your unit may perform differently than the estimates here. It is important
to figure out how much solvent your unit recovers, because other numbers are based on it (see
below). Even with a solvent recovery unit, some new solvent must be purchased. Usually
machines recover between 50 and 70 percent of the original solvent, so additional solvent that will
need to be purchased will range from 30 to 50 percent of the initial amount.
62
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Waste reduction option table
(Option — installing a two-gallon solvent distillation unit )
A. Amount of solvent you use in a year for this process (number of times you do
process x amount used each time):
B. Annual costs to use this much solvent for this process ($.53/half pint =
$8.48/gallon):
C. Annual disposal costs to dispose of this much solvent as hazardous waste
(Step 3, from the front of Form 1):
D. Minimum average amount (percent) of solvent recovered with a two-gallon
solvent distillation unit:
E. Amount of solvent recovered per year for this process (A x .65) with 65 percent
recovery rate:
F. Additional solvent purchases required for this process, above the amount of
solvent recovered with a solvent distillation unit (A-E):
G. Average amount (gallons) of still bottom sludge disposed of per year with a two-
gallon solvent distillation unit:
New cost to purchase solvent for this process (B x .35). Sixty-five percent recovery
rate means you only need to buy 35 percent as much new solvent:
Cost to dispose of 1 10 gallons of still bottom sludge per year for this process
(contact your local hazardous waste hauler):
117
gallons
$922.16
$231.25
0.65
76.05
gallons
40.95
gallons
110
gallons
$347.26
$185.00
The information from the front of the worksheet (Steps 1 through 5) was used. It appears in the
"Before" column of the second worksheet. Next, the new information from the waste reduction
option table (previous page) was written in the "After" column. Finally, the current operating
costs are compared to the costs of using the new waste reduction option (see Worksheet 13).
At the bottom of back side of the worksheet, there is a comparison calculation which will tell you
how long it will take until you break even on any equipment you had to purchase in the waste
reduction option. This is called the "payback period" and it shows you two things:
• how long it takes to break even on the equipment purchased; and
• how quickly you can start to save money.
63
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At the Click of a Mouse: Software for Cost Accounting
Many companies determine their environmental costs with one of many software packages
available on the market. The TNRCC has developed a software package, the Cost Analysis
Module (CAM). As with the worksheets, you are not required to use the software, but some
facilities may find it a useful tool.
The CAM software package allows you to document and compare the costs associated with two
or more industrial processes The cost comparison shows itemized costs as well as total cost of
one process compared to another. CAM will also analyze the net present value of the cost to
adopt one process or another. Finally, it can provide you with the amount of time it takes to
recover any capital expenditures. Finally, you can generate a graphic of the actual savings
generated over a ten year period. To order CAM, please contact the TNRCC Office of Pollution
Prevention and Recycling at (512)239-3100.
Other sources of cost accounting information include Web sites such as the EPA's Enviro$en$e
Web page at http://es.epa.gov.
The level of analysis is up to you. The purpose is to ensure that the options you choose will not
cause undue financial strain on your company. Whether this can most efficiently be determined
with a simple analysis or a complex cost accounting system is up to you and your facility.
Set Priorities
Now that the technical and economic feasibility of each project has been evaluated, you can use
Worksheet 14, "Waste Reduction Project Prioritization," to help prioritize and select the best
possible project options. The prioritized list may represent the order of implementation or the
order of importance. The most important projects may not be implemented in the order of
importance. You may want to pick projects that are easy to implement, or "low hanging fruit".
Many small easy successes can help lay a solid foundation for large scale projects. Showing the
rationale for the rank order of projects in the plan helps all plan users understand the nature of the
plan.
64
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65
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Worksheet 13 — EMS Environmental Accounting
Step 1: Draw a Picture of What You Do
• Track the inputs (supplies) and outputs (waste costs) created during the process.
• Each input should correspond to one or more outputs.
• This step does not include the final product or service.
• Outputs may require you to control pollution, or to dispose of waste.
• Indicate how you dispose of them.
Step 2: Determine Traditional Input (Supply) Costs per Process per Year
• Determine your annual input costs for each individual input of this process.
Step 3: Determine Traditional Output (Disposal) Costs per Process per Year
• Determine your annual output costs for each output from this process. When
disposal is involved, determine how many times you pay for disposal in a year.
Step 4: Identify Hidden Costs per Year
• Identify some of the hidden costs for this process.*
*Some hidden costs result from compliance requirements your business has triggered. You must
pay these associated costs, but usually do not add value to your final product. These regulatory
and compliance costs are frequently found in overhead. When they are hidden in overhead, they
are not seen as part of your business processes.
Step 5: Sum Total Costs per Year
• Add the cost of materials going into the process, the cost of disposal of excess
materials and controlling pollution, and any hidden costs.
Step 6: Compare Costs Using a Waste Reduction Option
• Determine the cost of materials that are being lost through disposal.
• Choose a waste reduction option from the options you have identified in your
technical feasibility study.
• Compare your current costs to the cost of using an alternative method that reduces
waste.
• Determine the payback period of any new equipment purchased.
66
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Worksheet 13
67
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69
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Worksheet 14 — Waste Reduction Project Prioritization
Worksheet 14 includes space for three projects. Make more copies for additional projects.
Questions 1 through 4 require an actual number to be placed in the "Total" column, then after
comparing the totals for each project, the projects should receive a ranking in order of their
desirability for that criteria. For example, on question number 1, if project 1 reported savings of
$2 million a year (from Worksheet 13), and project 2 reported $1 million a year, then their
ranking would be 2 and 1, respectively. Project 2 would receive the highest ranking (1) because
savings are greatest, thus more would be gained by this project.
Example
Priority rating criteria:
1. Savings (difference in old vs. new)
7. Processing problems
Priority rank
Project: 1
Total
$2 mill/yr
Rank
2
2
Rank
total
4
2
Project: 2
Total
$1 mill/yr
Rank
1
1
Rank
total
2
1
Since they are not quantifiable, you are not required to total questions 5 through 7. However,
they can still be ranked by comparing the projects to one another. For example, since there are
fewer problems associated with this project than project 2, Project 1 above received a 2 for
processing problems.
At the bottom of the worksheet, record the sum of the rank column for each project next to
"Rank Total." Based on this total, prioritize the projects. The project with the lowest rank total
will have the first priority; that with the highest total will have the last priority.
70
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Firm_
Site
Date
POLLUTION PREVENTION
ASSESSMENT
Source reduction
Waste minimization
Sheet_of_Page_of_
Project No.
Worksheet
14
WASTE REDUCTION
PROJECT PRIORITIZATION
Priority rating criteria:
1. Savings (difference in old vs. new)
2. Payback period
3. Projection of potential waste
reduction
4. Risk to workers, public, and the
environment
5. Environmental regulations
6. Processing problems
Priority rank
Project:
Total
Rank
Rank
total
Project:
Total
Rank
Rank
total
Project:
Total Rank
Rank total
71
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6. Implementation
Oral and written reports are the products of the pollution prevention assessment and feasibility
analysis. These reports will be used to justify the project to management and to obtain funding.
Pollution prevention options that involve operational, procedural, or material changes will likely
be implemented without detailed documentation or presentations. You will likely be asked to
include extensive documentation for projects involving equipment modifications, the installation
of new equipment, or major capital expenditures.
This chapter covers what you may include in your written documentation and oral presentations.
In addition, the chapter covers scheduling project implementation and evaluating its effectiveness
after it is implemented.
Documentation
A good final report can be an important tool for convincing your management to fund your
pollution prevention project.
Of primary concern to your management will be:
• What will this project do? (increase production, decrease costs, keep the plant in
compliance with the law, reduce liability exposure, reduce exposure of the public and
environment to risk, etc.).
• What is the project? (location, equipment, personnel, infrastructure, timing of
implementation).
• What will the project cost? (initial capital and net operating cost).
• Is the project profitable?
Carefully describe what the project will do for your plant and the company. If the project's main
impact is to keep the plant in compliance with the law, you should consider including references
to significant statutes and penalties. Any reduction of environmental risk should specifically be
included. Any financial benefits that the project may bring should also be highlighted.
72
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Implementation
Once your management has approved your pollution prevention project, implementation can
begin. Implementation will generally follow the procedures established by your firm for any new
procedure, process modification, or equipment change. Implementing a major pollution
prevention project typically involves several steps described below:
• Prepare the final project design.
• Arrange for construction or procure materials.
• Install new equipment.
• Train operators and maintenance staff.
• Run bench-scale testing.
• Start operation.
• Begin monitoring performance and evaluating results.
Use Worksheet 15, "Implementation Schedule," to outline your implementation procedures.
Evaluate Performance
Evaluating your project's performance is essential to ensuring support for future activities. The
easiest way to evaluate the performance of your waste reduction project is to measure the
economic benefits obtained and reductions in waste generated.
Measurements before the implementation should be recorded on the worksheet as baseline
measurements; and as actual for measurements made after implementation (projected would be
used for the measurements you anticipate when you design the project). You will likely generate a
minimum of three measurement sets; baseline, actual, and projected. Worksheet 16, "Performance
Evaluation," provides a format to document your project's results.
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Worksheet 15 — Implementation Schedule
Record your start and completion dates. Plan ahead and target start dates and completion dates
for all phases; they can be changed later if necessary. Also, make sure to receive guarantees from
the vendor or equipment dealer regarding the equipment you purchase. Your vendor should allow
you time to bench-scale test the equipment. If not, find another vendor.
74
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Firm_
Site
Date
POLLUTION PREVENTION
ASSESSMENT
Source reduction
Waste minimization
Sheet_of_Page_of_
Project No.
Worksheet
15
IMPLEMENTATION SCHEDULE
1
THRCC
Implementation schedule
Prepare a detailed design.
Prepare a construction bid package and equipment specification.
Select construction staff and purchase materials.
Install new equipment.
Train personnel.
Start operation.
Start performance monitoring and evaluation.
Start date
Completion date
75
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76
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Worksheet 16 — Evaluate Performance
Worksheet 16 provides you with a method of calculating your project's effectiveness. Keep in
mind that waste generation, while directly dependent on production, may not be directly related
to production.
This method divides the weight of the material used (or waste generated) by the amount of
finished goods manufactured by your process (e.g., gallons of product, number of cans, etc.). The
calculation is labeled weight/unit product.
Although this method of measuring waste reduction does take into consideration your production
rate there are still other factors that could cause you problems. For example, periodic plant
maintenance can cause one time increases in your hazardous waste generation which could cause
problems in evaluating data. In general, you should distinguish between production-related wastes
and maintenance-related or clean-up wastes.
77
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Firm_
Site
Date
POLLUTION PREVENTION
ASSESSMENT
Source reduction
Waste minimization
Sheet_of_Page_of_
Project No.
Worksheet
16
PERFORMANCE EVALUATION
Option description
Priority Rating Criteria:
1. Future Cost of disposal
2. Future Raw material cost
3. Current amount of waste
generated or toxic release
4. Projection of potential waste
reduction
5. Risk to workers, public, and
the environment
6. Environmental regulations
7. Processing problems
Priority Rank
Project:
Total
Rank
Rank Total
Project:
Total
Rank
Rank Total
Project:
Total Rank
Rank Total
78
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7. Filing your Supporting Documentation
Although your plan remains at your facility and is confidential, you must submit your Executive
Summary and Certification of Completion to the TNRCC's Office of Pollution Prevention and
Recycling.
Submit the Executive Summary
Table 1, "Which Worksheet Do I Use for Each Requirement?" lists the planning elements your
Executive Summary must cover. Completing Worksheet 17 on page 77 is one way to provide all
of the required information.
Regardless of format, your facility's Executive Summary should be written by the person most
involved and most familiar with the pollution prevention plan—probably the task force leader.
This worksheet contains all the Texas Administrative Code requirements found in 30 TAG
§335.474.
Submit a Certificate of Completion
As soon as your facility's plan is complete, present it to the chief financial officer, the plant
manager, and the task force leader for their review. The owner of the facility should sign a
certification of completion—a note that certifies that a plan that meets the requirements of the law
has been prepared. Send this certificate to the TNRCC at the address shown on page 13.
If a corporation owns the facility, then an officer of that corporation who has the authority to
commit the corporation's resources to implement the plan should sign. By signing the
certification of completion, the owner or officer is certifying that the plan meets the specified
requirements and is complete and correct.
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Worksheet 17 — Executive Summary
It is very important that the bold portions of the form be correct — if these items are reported
incorrectly, your submission may not be properly credited to your facility. Please take extra time
to ensure that these are correct. For all identification numbers, if not applicable, please use N/A.
Also, if there is more than one identification number for your facility, please include all
identification numbers.
• Facility name: Include the facility name you use to report TRI and hazardous waste
• Name, address of contact: Please provide the name, title, address and phone number of
the individual who should receive information from the TNRCC about pollution
prevention. Note: If this is at a different address than the facility itself, please state this and
include the actual facility mailing address.
• Plan date: date of actual submittal
• EPA ID: begins with TX; on manifests
• SW ID: on Notice of Registration or Annual Waste Summary
• TRI ID: on form R if facility is TRI reporter
• TNRCC air acct: old Texas Air Control Board account number; on air permits
• NPDES permit: EPA wastewater permit number
• UI well codes: underground injection well identification codes
• Primary SIC code: Standard Industrial Classification code
• Facility description: describe general facility operations
81
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Firm_
Site
Date
POLLUTION PREVENTION
ASSESSMENT
D Source reduction
D Waste minimization
Sheet_of_Page_of_
Project No.
Worksheet
17
EXECUTIVE SUMMARY
1
Executive summary - part 1
Provide facility information.
1. Name of the facility:
2. Contact person:
Mailing address:
city, state, zip:
Contact phone:
Contact fax:
3. Plan year:
Plan date due (circle one):
4. EPA ID number (12 digit):
5. TNRCC Solid Waste number: (5-digit; formerly TWC NOR #):
6. Toxic Release Inventory (TRI) ID number (if applicable):
7. TNRCC air account number (formerly TACB#; if applicable):
8. NPDES permit number (if applicable):
9. Underground Injection Well code(s) number (if applicable):
10. SIC code(s) (circle primary code):
11. General description of facility and activities:
82
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83
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Executive Summary — part 2
List all hazardous wastes generated amount for 19
The data should be taken from your Annual Waste Summary form.
Description of waste/TX waste code number: Amount generated in tons
Executive summary — part 3
List all reportable TRI chemicals, CAS numbers and the amount released or transferred for 19
The data should be taken from your TRI Form R — Sections 5 and 6 only.
TRI chemicals and CAS number: Amount released or transferred in tons
Executive summary — part 4
4. Provide a prioritized list of pollutants and contaminants to be reduced during 5-year period:
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Executive summary — part 5
5. State the source reduction and waste minimization goals for the facility:
Executive summary — part 6
6. Explain the environmental and human health risks considered in determining reduction goals:
Executive summary — part 7
7. What are the implementation milestones for individual project development?
Executive summary — part 8
8. What is the implementation schedule for future reduction goals?
Executive summary — part 9
9. Identify cases in which the implementation of source reduction or waste minimization activity designed
to reduce risk to human health or the environment, may result in the release of a different pollutant or
contaminant or may shift the release to another medium.
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I Worksheet 18 — Certification of Completion |
The person who signs the Certification of Completion should have the authority to commit the
corporation's resources to implement the plan.
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Firm_
Site_
Date
POLLUTION PREVENTION
ASSESSMENT
Source reduction
Waste minimization
Sheet_of_Page_of_
Project No.
Worksheet
18
EXECUTIVE SUMMARY
I
Certificate of Completion
This document certifies that the pollution prevention plan has been completed and meets the specified
requirements of the Waste Reduction Policy Act of 1991, the Solid Waste Disposal Act and 30 TAC
§§335.471-335.480 and that the information provided herein is true, correct, and complete.
This document also certifies that the person whose signature appears below has the authority to commit the
corporate resources necessary to implement this plan.
Position (check one):
Signature
Date
n Facility Owner
n Corporate Officer
n Other
87
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Appendix A
Basic Facts About Hazardous Waste and TRI
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Basic facts about hazardous waste and TRI
What is hazardous waste?
Hazardous wastes are a subset of solid wastes. Basically, a solid waste is a liquid, solid, semisolid,
or gaseous material that is either no longer wanted or no longer fit for its intended purpose (see
Federal 40 CFR Part 261 for exemptions).
Federal (40 CFR Part 261) and Texas (TAG, Chapter 335) regulations define a solid waste as
hazardous if it has one or more of the following characteristics:
Ignitability — ignitable hazardous wastes burn under certain conditions.
Corrosivity — corrosive hazardous wastes include those that are acidic and those which can
rapidly eat away (corrode) steel.
Reactivity — reactive hazardous wastes react violently under normal conditions, such as coming
into contact with water.
Toxicity — toxic hazardous wastes are harmful or deadly when swallowed, inhaled or absorbed
through the skin.
Solid waste is also considered hazardous if it is listed on one of three lists developed by the
United States Environmental Protection Agency (EPA):
• Nonspecific source wastes (40 CFR 261.31)— general wastes, commonly produced by
manufacturing and industrial processes (for example, spent halogenated solvents, dioxin
wastes).
• Specific source wastes (40 CFR 261.32)— wastes from specifically identified industries
such as wood processing, petroleum refining, and organic chemical manufacturing (for
example, sludge, still bottoms, wastewater).
• Commercial chemical products (40 CFR 261.33 (e) and (f))— specific commercial
chemical products, or manufacturing intermediates (for example, chloroform, creosote,
sulfuric acid, DDT).
While many wastes have dangerous properties, not all are defined as hazardous. For instance,
radioactive and infectious wastes are considered dangerous, but they are not defined as hazardous
waste and therefore, are regulated differently than hazardous wastes.
For WRPA reporting purposes, facilities that generate 13.2 tons or more of hazardous waste per
year are considered large-quantity generators (LQGs) of hazardous waste. Facilities generating
less than 13.2 tons per year are small-quantity generators (SQGs). For more information on
WRPA applicability, please refer to TNRCC document RG-209, "Does the Waste Reduction
Policy Act Apply to You?"
Waste minimization is a policy mandated by the U.S. Congress in the 1984 Hazardous and Solid
Waste Amendments to the Resource Conservation and Recovery Act (RCRA). This and other
RCRA provisions have led to significant increases in the cost of waste management.
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Generating hazardous waste in Texas
Lone Star Success
Facilities are making efforts to reduce their wastes. From 1993 to 1994, Texas facilities reduced
hazardous waste generation by 19 percent and in 1994 facilities reporting to WRPA reported a
source reduction of more than 40 million tons of hazardous waste.
Data from WRPA reporters also demonstrates the benefits of pollution prevention planning.
Facilities that have gone through the pollution prevention planning process reported a 20 percent
reduction in hazardous waste generation from 1993 to 1994. Facilities that have not completed a
pollution prevention plan showed a 3 percent increase during the same period.
What is the Toxics Release Inventory?
The federal Pollution Prevention Act of 1990 requires facilities reporting under the Toxics
Release Inventory (TRI) provisions of section 313 of SARA Title III to provide information on
pollution prevention and recycling activities with each annual filing. Texas has a similar law, the
Waste Reduction Policy Act (WRPA or Senate Bill 1099), found in the Texas Health and Safety
Code Chapter 361, Subchapter Q, which requires hazardous waste and TRI reporting facilities to
have in place a source reduction and waste minimization plan.
The following are types of TRI releases and transfers:
• any release into the air, whether it is fugitive or stack emission;
• any on-site discharge to a water body or receiving stream (including storm water runoff);
• injection of liquid wastes into on-site underground injection wells;
• any on-site land disposal, including landfills and surface impoundments;
• transfers off-site of wastewater to publicly-owned treatment work;
• transfers off-site to facilities for treatment, storage, or disposal;
• transfers off-site for recycling; and
• transfers off-site to be burned for energy recovery.
It is important to study both hazardous waste generation and TRI releases/disposal when planning
for pollution prevention.
Who must report under TRI?
At this time, a facility must report if it meets all three of the following criteria:
• has 10 or more full time employees;
• conducts manufacturing operations, and is included in the Standard Industrial
Classification (SIC) codes 20 through 39 (primarily manufacturing firms); and
• produces, imports, processes, or uses amounts above a set threshold of any of the
650 chemicals on the TRI list.
The thresholds for determining which of the TRI listed chemicals must be reported are:
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Manufacture, process or import more than 25,000 pounds/year per chemical; or
Otherwise use more than 10,000 pounds/year per chemical.
In Texas, about 1200 facilities report under TRI.
Note: In May 1997, the U.S. Environmental Protection Agency (EPA) expanded the types of
companies that report to TRI to include seven new industry groups.
The new industry groups are:
• metal mining • chemical and allied products-wholesale
• coal mining • petroleum bulk stations-wholesale
• electric utilities • solvent recovery services.
• commercial hazardous waste
treatment
TRI information from the seven new industry groups will be included in the data for reporting
year 1998.
How does Texas rank for TRI releases?
Texas ranks first in the nation for toxic releases and disposals reported by manufacturers for 1995, the most i
which there is data available. However, Texas ranks second in the nation for reductions of releases/disposal
from 1988 to 1995 and ranks first in the nation for reductions of toxic air emissions from 1988 to 1995.
These reductions are especially noteworthy because they coincide with a 24 percent increase in gross state p
the same time period by the manufacturing sector in Texas, according to data compiled by the State Comptrc
For more information about TRI program, please contact the TRI coordinator at the TNRCC,
512/239-3100, or EPA's EPCRA hot line at 1-800-535-0202. You may also visit the TNRCC
TRI Web page at http://www.tnrcc.state.tx.us/exec/oppr/tri/tri.html.
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Appendix B
Small-Quantity Generator/Non-TRI Reporter Executive
Summary Form and Instructions
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Small-quantity generater/non-TRI reporter Executive Summary form and
instructions
Instructions for completing the SQG/non-TRI reporter Executive Summary form
This form is only for SQGs that are not TRI reporters. If a facility is also a TRI reporter, see 30
TAG 335.474 for "LQG-type" plan and Executive Summary requirements.
Following are detailed instructions on filling out the Executive Summary form presented on the
following pages. Please type or neatly print the required information on the form or a clear copy
of the form. You are not required to use the Executive Summary form; however, the same
information should be provided to the TNRCC Office of Pollution Prevention and Recycling, MC-
112.
• Date plan due — Enter the date that your plan is due. If you are unsure of your due date,
please refer to Appendix B, "Does the Waste Reduction Policy Act Apply to You?"
• Executive Summary date — Enter the date that the Executive Summary form is sent to
the TNRCC.
• EPA ID (RCRA)— Enter the 12 character identification code.
• TNRCC SW reg.— Enter the 5 digit solid waste registration number (on your Notice of
Registration) issued by TNRCC.
• Facility name — Enter the name of the facility as it is identified in other reports
submitted to the TNRCC, such as a plant site name or other appropriate facility
designation.
• Mailing address — Enter the mailing address of the facility contact person for this
report. The address can be either street or PO box. Please include state and zip code.
Use the nine-digit zip code (xxxxx-xxxx) when it is known.
• Facility description — Provide a brief description of what is made, processed, and/or
manufactured at the facility.
• Facility contact person — Enter the name of the person who can answer questions about
the facility's plan and Executive Summary from the public and the TNRCC.
• Contact phone — Enter area code and telephone number for the facility contact person.
• SIC code — Enter the 4-digit Standard Industrial Classification (SIC) code that best
describes the principal product or service at the facility.
• Number of employees — Enter the estimated number of full-time employees working for
your entire company in a year. This information is optional, but allows us to better track
the quality of our service.
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Estimated amount of hazardous waste generated the fifth year, in tons — Enter the
estimated amount of hazardous waste you expect to generate in the fifth year, in tons.
This amount is based on your facility's reduction goals.
For example: If your plan due date was 1/1/96, then you need to enter the estimated
amount of hazardous waste you would generate by the year 2001. Your facility reduction
goal and the projects described in your pollution prevention plan should help you estimate
the amount of hazardous waste you would generate by the year 2001.
List of hazardous waste to be reduced and the corresponding source reduction
activities — Enter a prioritized list of hazardous waste generated (from your Annual
Waste Summary waste codes beginning with "9" or ending with "H") that you expect to
reduce in the projects you outlined in your plan. For each hazardous waste, place a check
mark in the appropriate box to identify the source reduction activity you plan to use to
reduce the waste. Table 2 provides a list of examples of source reduction activities.
For example: Suppose one of the projects in your plan is to reduce paint waste generated
in the painting operation through raw material modification. On the form, you need to
enter paint waste as the waste to be reduced and place a check mark under the column
raw material modification to identify the corresponding source reduction activity.
Certificate of completeness and correctness — On the lower part of the form, the
facility owner or corporate officer certifies that the plan has been completed and meets the
specified requirements of the rules and the information provided is true, correct, and
complete.
Check box located in the Certificate of completeness and correctness section of the
Form: Enter "X" if this form is submitted to amend information already submitted.
Optional information for SQG Executive Summary report — On the back of the
form, you will also find the SQG optional information section. If you wish, you can
provide additional information on a separate page. However, there is no requirement that
you complete the optional section of this form.
Revisions to the Executive Summary form — If the information you provide on your
Executive Summary form does not change, you are not required to submit a new
Executive Summary form each year. However, if you update your plan, then you need to
send in a revision to your Executive Summary form within 30 days with any changes from
the prior year.
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SOURCE REDUCTION / WASTE MINIMIZATION EXECUTIVE SUMMARY AND CERTIFICATE OF COMPLETENESS AND CORRECTNESS FOR SMALL-QUANTITY GENERATORS"
Date plan due
Facility name
Facility contact person
Contact phone
Facility description
EPA ID
Mailing address
l
Estimated amount of hazardous waste generated the fifth year, in tons
From your plan, list hazardous waste to be reduced
Hazardous waste (in order of priority)
Source reduction activities you plan to
box.
Good operating
practices
Q
Q
Q
Q
Q
Q
Inventory control Spill ar
prevent
Q
Q
Q
Q
Q
Q
Executive Summary date
TNRCCSWID
SIC code
Number of employees
use to reduce generation of each hazardous waste listed. Place a check mark in
d leak Raw material
ion modification
Q Q
Q Q
Q Q
Q Q
Q Q
Q Q
Process
modification
Q
Q
Q
Q
Q
Q
Cleaning and
decreasing
Q
Q
Q
Q
Q
Q
Surface preparations and P
finishing
Q
Q
Q
Q
Q
Q
the appropriate
roduct modification
Q
Q
Q
Q
Q
Q
Certificate of completeness and correctness
Certificate of completeness: I certify that the source reduction and waste minimization plan has been completed and meets the specified requirements of 30 TAC§§335.471-335.480, and that the
information provided herein is true, correct and complete. I also certify that I am the person who has the authority to commit the corporate or company resources necessary to implement the plan.
Facility owner or corporate officer Date If this is a revision of a previously submitted report, check this box G
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Please complete this form and return to:
Office of Pollution Prevention and Recycling, MC-112
Texas Natural Resource Conservation Commission
PO Box 13087
Austin, TX 78711-3087
If you have questions, please call (512) 239-3100
Optional information for SQG Executive Summary report
If you wish to provide a discussion on any of the sections listed below, please attach separate sheets as needed.
4a. A discussion of the person's previous effort at the facility to reduce hazardous waste or the release of pollutants or contaminants through
source reduction or waste minimization;
4b. A discussion of the effect changes in environmental regulations have had on the achievement of the source reduction and waste minimization
goals;
4c. The effect that events the person could not control have had on the achievement of the source reduction and waste minimization goals; and
4d. A discussion of the operational decisions the person has made that have affected the achievement of the source reduction and waste
minimization goals.
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Appendix C
Example Pollution Prevention Plan
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Example pollution prevention plan
source reduction and waste minimization plan for BJ Services Company
U.S.A., Tomball Research and Technology Center
A) Activities that generate hazardous waste
• spent solvents from laboratory (fuel blended)
• paint solvents (recycled)
• parts washing solvent (recycled)
• waste drilling mud (landfilled)
• contaminated floor dry (landfilled)
• immersion cleaner liquid (recycled)
B) Prioritized list of source reduction and waste minimization projects
I. Parts washing solvent
a. Reduce amount of waste solvent currently generated by changing procedure used to determine solvent
change out (SR).
b. Begin trials with other nonhazardous solvents to select, if possible, a suitable replacement solvent (SR).
II. Laboratory solvent
a. Improve procedures in waste segregation to minimize hazardous waste generation (SR).
b. Begin trials with other nonhazardous solvents to select, if possible, a suitable replacement solvent (SR).
C) Discussion of projects
ItL The hazardous waste generated by parts washers in the manufacturing/rebuild shop can be decreased in
two ways. One is by decreasing the number of times the solvent is changed out. Technically this would
present little difference in the quality of washed parts since the parts are washed until clean. The increase in
time spent washing parts would be negligible. Economically, the cost of the service would be about the
same. Environmental risk would decrease from present practice because the amount of solvent recycled and
handled would decrease. Human health risks would be the same since workers would still be exposed to the
hazardous solvent.
Ilx The second project would involve finding an effective nonhazardous solvent to replace the hazardous
solvent presently being used. The new solvent would have to be as effective as the hazardous solvent and
comparable in cost. The trials could be performed at minimal cost with one parts washer and fluids to be
tested supplied by vendors. The environment would be greatly benefited by the use of a nonhazardous
solvent and the risks to human health would decrease.
2a. The hazardous waste stream from the laboratory can be minimized in two ways. One would be to
ensure that waste is segregated properly and only hazardous waste goes into the hazardous waste stream.
2b. Since a constituent of this hazardous waste stream is solvent used in laboratory operations, the second
project would involve finding effective nonhazardous solvents to replace the hazardous solvents presently
being used. The new solvent would have to be as effective as the hazardous solvent and comparable in cost.
The trials could be performed at minimal cost with the procedures in place now and be substituting fluids
to be tested which will be supplied by vendors. The environment would be greatly benefited by the use of a
nonhazardous solvent and the risks to human health would decrease.
D) Reduction anticipated
la. Changing the parts washing solvent change out schedule in the manufacturing/rebuild shop will result
in an estimated source reduction of 6 tons of hazardous waste per year.
Ib. Replacing the current parts washing solvent with a nonhazardous solvent will result in an estimated
source reduction of 11 tons of hazardous waste per year.
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2a. Improving procedures for the research and development laboratory hazardous waste segregation will
result in an estimated source reduction of hazardous waste of 0.5 ton per year.
2b. Replacing the current solvents in the laboratory with nonhazardous solvents will result in an estimated
source reduction of 0.5 ton of hazardous waste per year.
E) Implementation schedule
la. January 1995 — Select a change out schedule for the parts washer solvent in the
Manufacturing/rebuild shop that will enable employees to effectively clean parts yet reduce the number of
change outs per month to reduce the amount of hazardous waste generated. March 1995 — Start trials of
other solvents for parts washing with the goal of selecting an alternative by December 1997.
2a. January, 1998 — Examine research and development hazardous waste segregation procedures with
goal of placing improved procedures in place by December 1998.
2b. January, 1999 — Start trials of alternate solvents for use in laboratory with goal of making a
determination by December 1999.
F) Facility goals
The goal for the entire facility is to reduce hazardous waste reported on the Annual Waste Summary to 10
tons by 1999.
December 1997 — Reduce manufacturing/rebuild hazardous waste by 40 percent.
December 1999 — Reduce research and development hazardous waste by 10 percent.
G) Employee awareness and training
1. The BJ environmental management guide has under the introduction tab Section IB some of the Valdez
Principles including ones directed at waste minimization.
2. The Tomball Facility has a waste minimization program in place to minimize waste, including hazardous
waste.
3. The manager of each department that generates hazardous waste, as well as the employees directly
associated with hazardous waste generation are give additional instruction on minimization and reduction.
I) Pollutant shift to another medium
1. The solvent used in the manufacturing/rebuild shop will be reduced in volume initially and possibly
replaced with a nonhazardous solution.
2. Improving laboratory procedures will reduce the volume of waste generated. Replacing the solvents used
with nonhazardous solvents will further reduce the volume of hazardous waste.
Plan Executive Summary
Facility: Tomball Research and Development Center
11211FM2920
Tomball, Texas 77375
Contact: David H. Burkett
Date: December 1994
Description: The facility is the site of various support groups for BJ Services Co., U.S.A. including
engineering, instrumentation, and manufacturing/rebuild for oil field service equipment.
Also located at the facility is a research laboratory for oil field service chemicals, and
several administrative departments.
TACB account: HG-1053-L
Solid waste registration: 36611
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EPA ID: TXD000838995
Hazardous waste generated: (1993 volumes)
Waste Quantity
0194203H-Spent solvents from laboratory 2.1 tons
029421 IH-Paint solvents 0.0 tons
0501203H-Parts washing solvent 17.8 tons
000130IH-Waste drilling mud 0.3 tons
0002409H-Contaminated floor dry 0.1 tons
900250-Immersion cleaner fluid 0.4 tons
Pollutant reduction list
1. Parts washing solvent
2. Spent solvents from laboratory
Reduction goal
The goal is to reduce the hazardous waste reported on the annual waste summary for the Tomball facility
to 10 tons by 1999.
Environmental and human health risks considered
The hazardous solvents used at the Tomball facility may be detrimental to the environment and human
health. Therefore, the reduction in use is a reduction in risk to human health and the environment.
Project milestones
January 1995 Select a change out schedule for the parts washer solvent to reduce volume
generated and monitor for two months to determine effectiveness.
March 1995 Begin trials for possible alternate parts washer solvent with goal of selecting an
alternative by December 1997.
January 1998 Examine Research and Development hazardous waste segregation procedures with
goal of placing improved procedures by December 1998.
January 1999 Begin trials of alternative solvents for use in laboratory with goal of making a
determination by December 1999.
Future reduction goals
Future reduction goals will be established in 1999 after evaluation of the effectiveness of the
aforementioned goals and examination of other reduction opportunities.
Pollutants changed or shifted
1. The solvent used in the manufacturing/rebuild shop will be reduced in volume initially and possibly
replaced with a nonhazardous solution.
2. Improving laboratory procedures will reduce the volume of waste generated. Replacing the solvents
used with nonhazardous solvents will further reduce the volume of hazardous waste.
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Appendix D
TNRCC Pollution Prevention Rules (30 TAG §335,
Subchapter Q) Pollution Prevention: Source Reduction and
Waste Minimization
-------
TNRCC Pollution Prevention Rules (30 TAC Chapter 335, Subchapter Q)
Pollution Prevention: Source Reduction and Waste Minimization
§335.471. Definitions.
The words and terms used in this subchapter have the meanings given in the Waste Reduction Policy Act of
1991, Senate Bill 1099, or the regulations promulgated thereunder. The following words and terms, when
used in this subchapter, shall have the following meanings, unless the context clearly indicates otherwise.
Further, the following words and terms, as defined herein, shall only have application to this subchapter.
Acute hazardous waste — Hazardous waste listed by the Administrator of the United States
Environmental Protection Agency (EPA) under the federal Solid Waste Disposal Act, as amended by the
Resource Conservation and Recovery Act of 1976 (42 U.S.C. §6901 et seq.), because the waste meets the
criteria for listing hazardous waste identified in 40 Code of Federal Regulations, §261.1 l(a)(2).
Board — The Texas Air Control Board.
Commission — The Texas Water Commission.
Committee — The waste reduction advisory committee established by the Texas Solid Waste Disposal
Act, Health and Safety Code Annotated, §361.0215.
Conditionally exempt small-quantity generator — A generator that does not accumulate more than
1,000 kilograms of hazardous waste at any one time on his facility and that generates less than 100
kilograms of hazardous waste in any given month.
Environment — Water, air, and land and the interrelationship that exists among and between water, air,
land, and all living things.
Facility — All buildings, equipment, structures, and other stationary items located on a single site or on
contiguous or adjacent sites that are owned or operated by a person who is subject to this subchapter or by
a person who controls, is controlled by, or is under common control with a person subject to this
subchapter.
Generator and generator of hazardous waste — Have the meaning assigned by the Texas Solid Waste
Disposal Act, Health and Safety Code Annotated, §361.131.
Large-quantity generator — A generator that generates, through ongoing processes and operations at a
facility:
(A) more than 1,000 kilograms of hazardous waste in a month; or
(B) more than one kilogram of acute hazardous waste in a month.
Media and medium — Air, water, and land into which waste is emitted, released, discharged, or disposed.
Pollutant or contaminant — Includes any element, substance, compound, disease-causing agent, or
mixture that after release into the environment and on exposure, ingestion, inhalation, or assimilation into
any organism, either directly from the environment or indirectly by ingestion through food chains, will or
may reasonably be anticipated to cause death, disease, behavioral abnormalities, cancer, genetic mutation,
physiological malfunctions, including malfunctions in reproduction, or physical deformations in the
organism or its offspring. The term does not include petroleum, crude oil, or any fraction of crude oil that is
not otherwise specifically listed or designated as a hazardous substance under §101(14)(A)-(F) of the
environmental response law, nor does it include natural gas, natural gas liquids, liquefied natural gas,
synthetic gas of pipeline quality, or mixtures of natural gas and synthetic gas.
Release — Any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping,
leaching, dumping, or disposing into the environment. The term does not include:
(A) a release that results in an exposure to a person solely within a workplace, concerning a claim
that the person may assert against the person's employer;
(B) an emission from the engine exhaust of a motor vehicle, rolling stock, aircraft, vessel, or
pipeline pumping station engine;
(C) a release of source, by-product, or special nuclear material from a nuclear incident, as those
terms are defined by the Atomic Energy Act of 1954, as amended (42 U.S.C. §2011 et seq.), if the
release is subject to requirements concerning financial protection established by the Nuclear
D-l
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Regulatory Commission under §170 of that Act;
(D) for the purposes of §104 of the federal Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (42 U.S.C. §9601 et seq.), or other response action, a
release of source, by-product, or special nuclear material from a processing site designated under
the Uranium Mill Tailings Radiation Control Act of 1978 (42 United States Code, §§7912 and
7942) §102(a)(l) or §302(a); and
(E) the normal application of fertilizer.
Small quantity generator — A generator that generates through ongoing processes and operation at a
facility:
(A) equal to or less than to 1,000 kilograms but more than or equal to 100 kilograms of hazardous
waste in a month; or
(B) equal to or less than one kilogram of acute hazardous waste in a month.
Source reduction — Has the meaning assigned by the federal Pollution Prevention Act of 1990, Pub.L.
101-508, §6603, 104 Stat. 1388.
Tons — 2,000 pounds, also referred to as short tons.
Toxics Release Inventory (TRI)— A program which includes those chemicals on the list in Committee
Print Number 99-169 of the United States Senate Committee on Environment and Public Works, titled
"Toxic Chemicals Subject to the Emergency Planning and Community Right-To-Know Act of 1986
(EPCRA, 42 United States Code Annotated, §11023), 313" including any revised version of the list as may
be made by the Administrator of the EPA
Waste minimization — A practice that reduces the environmental or health hazards associated with
hazardous wastes, pollutants, or contaminants. Examples may include reuse, recycling, neutralization, and
detoxification.
§335.472. Pollutants and Contaminants.
The following pollutants and contaminants are subject to source reduction and waste minimization
planning.
(1) all hazardous wastes generated;
(2) all chemicals which exceed threshold reporting requirements pursuant to Emergency Planning
and Community Right-to-Know Act of 1986, §313.
§335.473. Applicability.
This subchapter applies to facilities which are required to develop a source reduction and waste
minimization plan pursuant to the Waste Reduction Policy Act of 1991, Senate Bill 1099, or the
regulations promulgated thereunder, including:
(1) all large quantity generators of hazardous waste;
(2) all generators other than large quantity generators and conditionally exempt small quantity
generators as defined by Health and Safety Code, §361.431(3);
(3) persons subject to §313, Title III, Superfund Amendments and Reauthorization Act of 1986
(Emergency Planning and Community Right-to-Know Act (EPCRA), 42 United States Code,
§ 11023). These TRI covered facilities would be required to develop source reduction and waste
minimization plans for only the TRI listed chemicals that exceed threshold quantities established
under EPCRA.
§335.474. Source Reduction and Waste Minimization Plans.
All persons identified under §335.473 of this title (relating to Applicability) shall prepare a five year (or
more) source reduction and waste minimization plan which may be updated annually as appropriate
according to the schedule listed in §335.475 (relating to Implementation Dates). Plans shall be updated as
necessary to assure that there never exists a time period for which a plan is not in effect. Prior to
completion of the plan and each succeeding plan, a new five-year (or more) plan shall be prepared. Plans
prepared under paragraphs (l)-(3) of this section shall contain a separate component addressing source
reduction activities and a separate component addressing waste minimization activities.
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(1) With the exception of small quantity generators which are subject to paragraph (3) of this
section, the plan shall include, at a minimum:
(A) an initial survey that identifies:
(I) for facilities described in §335.473(1), activities that generate
hazardous waste; and
(II) for facilities described in §335.473(3), activities that result in the
release of pollutants or contaminants designated under §335.472 of this
title (relating to Pollutants and Contaminants);
(B) based on the initial survey, a prioritized list of economically and
technologically feasible source reduction and waste minimization projects;
(C) an explanation of source reduction or waste minimization projects to be
undertaken, with a discussion of technical and economic considerations, and
environmental and human health risks considered in selecting each project to be
undertaken;
(D) an estimate of the type and amount of reduction anticipated;
(E) a schedule for the implementation of each source reduction and waste
minimization project;
(F) source reduction and waste minimization goals for the entire facility, including
incremental goals to aid in evaluating progress;
(G) an explanation of employee awareness and training programs to aid in
accomplishing source reduction and waste minimization goals;
(H) certification by the owner of the facility, or, if the facility is owned by a
corporation, by an officer of the corporation that owns the facility who has the
authority to commit the corporation's resources to implement the plan, that the
plan is complete and correct;
(I) identification of cases in which the implementation of a source reduction or
waste minimization activity designed to reduce risk to human health or the
environment may result in the release of a different pollutant or contaminant or
may shift the release to another medium; and
(J) an executive summary of the plan which shall include at a minimum:
(I) a description of the facility which shall include:
(I) name of the facility;
(II) address;
(III) contact;
(IV) a general description of the facility; and
(V) Texas Air Control Board account number (TACB), Texas
Water Commission (TWC) solid waste notice of registration
number, TWC Wastewater permit number, United States
Environmental Protection Agency (EPA) identification number
(Resource Conservation and Recovery Act (RCRA) number),
National Pollutant Discharge Elimination System (NPDES)
permit number, and underground injection well code identification
number.
(ii) a list of all hazardous wastes generated and the volume of each;
(iii) a list of all reportable TRI releases and the volume of each;
(iv) a prioritized list of pollutants and contaminants to be reduced;
(v) a statement of reduction goals;
(vi) an explanation of environmental and human health risks considered in
determining reduction goals;
(vii) implementation milestones for individual project development;
(viii) an implementation schedule for future reduction goals; and
(ix) identification and description of cases in which the implementation of
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source reduction or waste minimization activity designed to reduce risk to
human health or the environment may result in the release of a different
pollutant or contaminant or may shift the release to another medium.
Included in this description shall be a discussion of the change in charac-
teristic of the normal waste stream or release and how it will be managed
in that affected medium.
(2) The source reduction and waste minimization plan may also include:
(A) a discussion of the person's previous efforts at the facility to reduce risk to
human health and the environment or to reduce the generation of hazardous waste
or the release of pollutants or contaminants;
(B) a discussion of the effect changes in environmental regulations have had on the
achievement of the source reduction and waste minimization goals;
(C) the effect that events the person could not control have had on the achievement
of the source reduction and waste minimization goals;
(D) a description of projects that have reduced the generation of hazardous waste
or the release of pollutants or contaminants; and
(E) a discussion of the operational decisions made at the facility that have affected
the achievement of the source reduction or waste minimization goals or other risk
reduction efforts.
(3) The plans of small quantity generators shall include, at a minimum:
(A) a description of the facility which shall include:
(I) name of the facility;
(ii) address;
(iii) contact;
(iv) general description of the facility; and
(v) TACB account number, TWC Solid Waste Notice of Registration
number, TWC Wastewater Permit Number, EPA Identification number
(RCRA number), NPDES permit number, and underground injection well
code identification number.
(B) a list of all hazardous wastes generated and the volume of each;
(C) a list of all reportable TRI releases and the volume of each;
(D) a prioritized list of pollutants and contaminants to be reduced;
(E) a statement of reduction goals;
(F) information on environmental and human health risks, such as Material Safety
Data Sheets or other available documentation, considered in determining reduction
goals;
(G) implementation milestones for individual project development;
(H) an implementation schedule for future reduction goals; and
(I) identification and description of cases in which the implementation of a source
reduction or waste minimization activity designed to reduce risk to human health
or the environment may result in the release of a different pollutant or contaminant
or may shift the release to another medium. Included in this description shall be a
discussion of the change in characteristic of the normal waste stream or release
and how it will be managed in that affected medium.
(J) certification by the owner of the facility, or, if the facility is owned by a
corporation, by an officer of the corporation that owns the facility who has the
authority to commit the corporation's resources to implement the plan, that the
plan is complete and correct.
(K) an executive summary of the plan which shall include at a minimum:
(I) a description of the facility which shall include:
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(I) name of facility;
(II) address;
(III) contact;
(IV) EPA ID, TNRCC solid waste notice of registration
number;
(V) primary SIC code.
(ii) a projection of the amount of hazardous waste that the facility
will generate (based on what is reported as hazardous waste under
30 TAG 335.9 ) at the end of the five year period that the plan is
in place.
(iii) prioritized list of pollutants and contaminants to be reduced.
(iv) a list of source reduction activities associated with reductions of
pollutants identified under 335.474(3)(D).
(4) The executive summary may include:
(A) a discussion of the person's previous effort at the facility to reduce
hazardous waste or the release of pollutants or contaminants through
source reduction or waste minimization;
(B) a discussion of the effect changes in environmental regulations have had
on the achievement of the source reduction and waste minimization goals;
(C) the effect that events the person could not control have had on the
achievement of the source reduction and waste minimization goals; and
(D) a discussion of the operational decisions the person has made that have
affected the achievement of the source reduction and waste minimization
goals.
§335.475. Implementation Dates.
All facilities subject to this subchapter shall develop a source reduction and waste minimization plan. The
implementation year shall be determined by the prior year's reported volumes of hazardous waste generated
and/or total TRI releases. A facility once subject to this subchapter shall remain subject until it no longer
meets the requirements of §335.473 of this title (relating to Applicability) or are exempted under §335.477
of this title (relating to Exemptions). Volumes for calculations will be based on total hazardous waste
generated and/or total TRI releases. The executive summary shall be submitted to the commission and the
board on the date the plan is required to be in place. Plan implementation will be according to the following
schedule:
(1) The source reduction and waste minimization plan shall be in place, available for review, and
shall be implemented no later than July 1, 1993 for:
(A) hazardous waste generators reporting 5,000 tons or more; or
(B) TRI facilities reporting 100 tons or more.
(2) The source reduction and waste minimization plan shall be in place, available for review, and
shall be implemented no later than January 1, 1994 for:
(A) hazardous waste generators reporting less than 5,000 tons but more than or
equal to 500 tons; or
(B) TRI facilities reporting less than 100 tons but more than or equal to 10 tons.
(3) The source reduction and waste minimization plan shall be in place, available for review, and
shall be implemented no later than January 1, 1995 for:
(A) hazardous waste generators reporting less than 500 tons but more than or
equal to 15 tons; or
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(B) TRI facilities reporting less than 10 tons but more than or equal to 5 tons.
(4) The source reduction and waste minimization plan shall be in place, available for review, and
shall be implemented no later than January 1, 1996 for:
(A) hazardous waste generators reporting less than 15 tons but more than or equal
to 5 tons; or
(B) TRI facilities reporting less than 5 tons but more than or equal to 1 ton.
(5) The source reduction and waste minimization plan shall be in place, available for review, and
shall be implemented no later than January 1, 1997 for:
(A) hazardous waste generators reporting less than 5 tons but greater than 1.102
tons (1,000 kilograms); or
(B) TRI facilities reporting less than 1 ton.
(6) After the effective date of this subchapter, any facility which becomes subject to the
requirement to have a source reduction and waste minimization plan, either within 90 days prior to
or at any time following the dates referenced in paragraph (l)-(5) of this section, shall have 90
days to have the plan in place and available for review.
§335.476. Reports and Record keeping.
All persons required to develop a source reduction and waste minimization plan for a facility under this
subchapter shall submit to the commission and the board, concurrent with implementation of the plan under
§335.475 of this title (relating to Implementation Dates), an initial executive summary of such plan and a
copy of the certification of completeness and correctness in §335.474(1)(H) of this title (relating to Source
Reduction and Waste Minimization Plans). Within 30 days of any revision of such plan, a revised
executive summary including a copy of a new certificate of completeness and correctness shall be
submitted. All owners and operators required to develop a plan under §335.473(1) and (3) (related to
Applicability) shall also submit an annual report as defined below under paragraphs (1), (2), and (3) of this
section according to the schedule outlined in paragraph (4) of this section. Persons required to develop a
source reduction and waste minimization plan for a facility under §335.473(2) (related to Applicability)
may meet the annual reporting requirements by submitting their annual waste summary required under 30
TAC 335.9 and by submitting their hazardous waste reduction goals as required under §335.474(K)(ii).
(1) The report shall detail the facility's progress in implementing the source reduction and waste
minimization plan and include:
(A) an assessment of the progress toward the achievement of the facility source
reduction goal and the facility waste minimization goal;
(B) a statement to include, for facilities described in §335.473(1) of this title
(relating to Applicability), the amount of hazardous waste generated and, for
facilities described in §335.473(3), the amount of the release of reportable
pollutants or contaminants designated under the Texas Solid Waste Disposal Act,
the Texas Health and Safety Code Annotated, §361.433© in the year preceding
the report, and a comparison of those amounts with the amounts generated or
released using 1987 as the base year.
(C) any modification to the plan.
(2) The report may include:
(A) a discussion of the person's previous effort at the facility to reduce hazardous
waste or the release of pollutants or contaminants through source reduction or
waste minimization;
(B) a discussion of the effect changes in environmental regulations have had on the
achievement of the source reduction and waste minimization goals;
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(C) the effect that events the person could not control have had on the achievement
of the source reduction and waste minimization goals; and
(D) a discussion of the operational decisions the person has made that have
affected the achievement of the source reduction and waste minimization goals.
(3) The report shall contain a separate component addressing source reduction activities and a
separate component addressing waste minimization activities.
(4) The report and the executive summary of the plan shall be submitted according to the following
schedule and annually thereafter.
(A) For all facilities meeting the specifications of §335.475(1) of this title (relating
to Implementation Dates), the first report will be due on or before March 1, 1994.
The report will cover calendar year 1993. Subsequent annual reports will be
submitted on or before July 1 of each year.
(B) For all facilities meeting the specifications of §335.475(2), the first report will
be due on or before July 1, 1995. The report will cover calendar year 1994.
(C) For all facilities meeting the specifications of §335.475(3), the first report will
be due on or before July 1, 1996. The report will cover calendar year 1995.
(D) For all facilities meeting the specifications of §335.475(4), the first report will
be due on or before July 1, 1997. The report will cover calendar year 1996.
(E) For all facilities meeting the specifications of §335.475(5), the first report will
be due on or before July 1, 1998. The report will cover calendar year 1997.
(5) Base line data from the calendar year 1987 shall be used in developing each of the first reports
referred to in paragraph (4) of this section.
(6) The report shall be submitted on forms furnished or approved by the executive directors of the
commission and the board and shall contain at a minimum the information specified in paragraph
(1) of this section. Upon written request by the facility, the executive directors may authorize a
modification in the reporting period.
§335.477. Exemptions.
(a) This subchapter does not apply to:
(1) conditionally exempt small-quantity generators; and
(2) facilities regulated by the Railroad Commission of Texas under the Natural
Resources Code, §§91.101 or §141.012.
(b) Owners and operators of facilities listed in §335.473 of this title (relating to Applicability),
may apply on a case-by-case basis, to the executive directors of the commission and the board for
an exemption from this subchapter. The executive directors of the commission and board may
grant an exemption if the applicant demonstrates that sufficient reductions have been achieved. If
an exemption is granted, it is valid only for the following year, but can be renewed, on an annual
basis, by filing a new application. The executive directors' decision will be based upon the
following standards and criteria for determining practical economic and technical completion of the
plan:
(1) the facility has reduced the amount of pollutants and contaminants being
generated or released by 90 percent since the base year;
(2) potential impact on human health and the environment of any remaining
hazardous waste generated, or pollutant or contaminant released; and
(3) a demonstration that additional reductions are not economically and technically
feasible.
§335.478. Administrative Completeness.
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The commission or the board may review a source reduction and waste minimization plan or annual report
to determine whether the plan or report complies with this subchapter.
§335.479. Enforcement.
Failure to have a source reduction and waste minimization plan in accordance with this subchapter or
failure to submit a source reduction and waste minimization annual report in accordance with this
subchapter is a violation.
§335.480. Confidentiality.
(a) A source reduction and waste minimization plan shall be maintained at each facility
owned or operated by a person and/or generator who is subject to this subchapter and shall
be available to commission or board personnel for inspection. The source reduction and
waste minimization plan is not a public record for the purposes of Chapter 424, Acts of
the 63rd Legislature, Regular Session, 1973 (Texas Civil Statues, Article 6252-17a).
(b) The executive summary of the plan and the annual report are public records. On
request, the person and/or generator shall make available to the public a copy of the
executive summary of the plan or annual report.
(C) If an owner or operator of a facility for which a source reduction and waste
minimization plan has been prepared shows to the satisfaction of the commission or board
that an executive summary of the plan, annual report, or portion of a summary or report
prepared under this subchapter would divulge a trade secret if made public, the
commission or board shall classify as confidential the summary, report, or portion of the
summary or report.
(d) To the extent that a plan, executive summary, annual report, or portion of a plan,
summary, or annual report would otherwise qualify as a trade secret, an action by the
commission or board or an employee of the commission or board does not affect its status
as a trade secret.
(e) Information classified by the commission or board as confidential under this section is
not a public record for purposes of Chapter 424, Acts of the 63rd Legislature, 1973
(Texas Civil Statutes, Article 6252-17a), and may not be used in a public hearing or
disclosed to a person outside the commission or board unless a court decides that the
information is necessary for the determination of an issue being decided at the public
hearing.
Amendments to §335.476
Date Adopted: June 14, 1995
Date Filed with the Secretary of State: June 20, 1995
Date Effective: July 11, 1995
Amendments to §335.474 and §335.476
Date Adopted: November 29, 1995
Date Files with the Secretary of State: December 4, 1995
Date Effective: December 25, 1995
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Appendix E
Additional Resources
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Additional Resources
TNRCC publications
To order the following documents, call TNRCC publications at (512) 239-0028. These publications are
also available via the Internet at http://www.tnrcc.state.tx.us.
• SR/WM Annual Progress Report Manual and Forms (RG-112) : Assists LQGs and TRI facilities
in completing annual reporting required under WRPA.
• SR/WMExecutive Summary and Certificate of Completeness and Correctness for SQGS (RG-
196): Provides information on how SQGs (who are not TRI reporters) fulfill their requirements
under WRPA.
• Does the Waste Reduction Policy Act Apply to You? (RG-209): Assists facilities in determining
WRPA applicability and requirements.
Industrial Pollution Prevention Team
Call (512) 239-3100 for help with WRPA requirements and ask to speak with someone on the Industrial
Pollution Prevention team. We can clarify requirements and assist you in preparing your WRPA plan,
Executive Summary or Annual Progress Report.
Engineering and Technical Services
OPPR staff provides information on innovative technology and serves as a clearinghouse for ideas on
pollution prevention technology. On request, staff will go on location for non-regulatory, pollution
prevention site visits, which provide industrial facilities a "safe" opportunity to address challenging
environmental problems with cost-effective, "real world" solutions.
Results and information from past site visits are available in TNRCC document AS-40, Pollution
Prevention Ideas from Texas Industries, through TNRCC Publications 512/239-0028 or via the Internet at
http://p2.utep.edu/p2/casestudies/p2main.cfm. Hosted by the University of Texas at El Paso, this site also
offers pollution prevention resource information.
You may also write to us at:
Office of Pollution Prevention and Recycling/TNRCC
IPP/TRI, MC-112
PO Box 13087
Austin TX 78711-3087
EPA pollution prevention guides
Numerous industry-specific and general pollution prevention guides are available through the EPA's Center
for Environmental Research Information (CERI). Listed below are some technical guides, which can be
ordered directly from CERI (phone: 513-569-7562, FAX: 513-569-7566). CERI also offers many
additional topics and information, and a publication list can also be ordered from the above numbers.
EPA's Pollution Prevention Information Clearinghouse (PPIC) also has many publications available. A
complete listing of their publications can be ordered by contacting PPIC (phone: 202-260-1023, fax: 202-
260-0178).
E-l
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EPA industry-specific pollution prevention guides:
The list below contains pollution prevention guides available as of August 1997. For updated information,
please contact EPA's CERI number listed above.
Title
Auto Repair
Automotive Refmishing
Commercial Printing
Dye Manufacturing
Fabricated Metal
Fiberglass and Composite Plastics
Marine Maintenance and Repair
Mechanical Equipment Repair
Metal Fabricated Products
Metal Finishing
Metal Casting and Heat Treating
Municipal Pretreatment Programs
Non-Agricultural Pesticide Users
Paint Manufacturing
Pesticide Formulations
Pharmaceutical
Photo Processing
Printed Circuit Board Manufacturing
Research and Education
Selected Hospital Wastes
Wood Furniture Manufacturing
EPA general pollution prevention guides:
Solvent Waste Reduction Alternatives
Facility Pollution Prevention Guide
Organic Coating Removal
Alternatives to Chlorinated Solvents for Cleaning and Decreasing
Cleaning and Degreasing Process Changes
Alternative Metal Finishes
On-Site Solvent Recovery
Mercury Usage and Alternatives in Electrical and Electronics Industries
Evaluating the Potential for Safe Substitutes
Demonstration of Alternative Cleaning Systems
Pollution Prevention Possibilities for Small and Medium Sized Facilities
EPA Number
EPA/625/7-91/013
EPA/625/7-91/016
EPA/625/7-90/008
EPA/741/B-92/001
EPA/625/7-90/006
EPA/625/7-91/014
EPA/625/7-91/015
EPA/625/R-92/008
EPA/560/8-92/001 A
EPA/625/R-92/011
EPA/625/R-92/009
EPA/625/R-93/006
EPA/625/R-93/009
EPA/625/7-90/005
EPA/625/7-90/004
EPA/625/7-91/017
EPA/625/7-91/012
EPA/625/7-90/007
EPA/625/7-90/010
EPA/625/7-90/009
EPA/560/8-92/001C
EPA/625/4-
EPA/600/R-
EPA/625/R-
EPA/625/R-
EPA/625/R-
EPA/625/R-
EPA/600/R-
EPA/600/R-
EPA/600/R-
EPA/600/R-
EPA/600/R-
89/021
92/088
93/015
93/016
93/017
94/007
94/026
94/047
94/178
95/120
95/070
E-2
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2000 Green Zia Examiner Work Book
Examiner Work Book
for the New Mexico Environment Department's Green
Zia Environmental Excellence Program
Page Iof32
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2000 Green Zia Examiner Work Book
Words of Welcome
It is a pleasure to welcome you to the 2000 Board of Examiners for the New Mexico Environment
Department's Green Zia Environmental Excellence program. As a Green Zia Examiner, you play a crucial
role in enhancing New Mexico's competitiveness, performance, and environmental excellence. As a New
Mexico Green Zia program member, much is expected of you. The validity and prestige of the Green Zia
program rest upon the integrity, thoroughness, commitment, and energy of its Examiners. As volunteers,
you are the nucleus of the Program, and we truly value your efforts.
We approach the next century looking forward to new challenges and excitement in the New Mexico Green
Zia program. In 2000 we have significantly revised the Criteria for Environmental Excellence in content and
format based upon feedback received from 1999 participants. The focus of the program has changed from
striving for environmental excellence to continuously improving an organization's approach, deployment and
results in the area of pollution prevention. The Criteria have been re-written in question format to better
facilitate applicant response and every effort has been made to eliminate redundant requirements between
Categories. As a member of the 2000 Board of Examiners, you have the opportunity to help New Mexico
organizations take the next step in understanding and implementing the concepts of environmental
excellence.
This Handbook is a resource document provided to help you in your job. It is designed to provide you with
tools to streamline the examination process and to produce a high-quality, value-added feedback report.
Thank you for lending your support to this important effort. We hope you derive great satisfaction from
taking part in this exciting and challenging adventure. We look forward to working with each of you in our
mutual quest to improve New Mexico's environment for all of its citizens.
New Mexico Environment Department
Green Zia Program Administrators
Panel of Judges
Staff
Page 2 of 32
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2000 Green Zia Examiner Work Book
SUGGESTED PROCESS FOR SCOREBOOK COMPLETION
The following is an elaboration of the Suggested Process for Evaluating Green Zia Applications presented during Examiner
Training.
Step 1: Plan
A. With your Senior Examiner's assistance, complete the following action planning tables:
Team Information:
Name
Address
Eve Phone
Day Phone
Email
Fax
Categories to
Champion
Examination Plan
Task/Step
Develop Examination
Plan
Coordinate Consensus
Meeting
Conduct Independent
Review and Scoring
Compile Category
Feedback
Send Compiled Category
Feedback to Team
Conduct Consensus
Meeting
Compile Feedback,
Scoring and Executive
Summary Materials.
Send completed
materials to Green Zia
Administrator
Site Visit Availability
Owner(s)
Examination Team
Sr. Examiner
Individual Team Members
Category Champions
Category Champions
Examination Team
Sr. Examiner
Sr. Examiner
Examination Team
Due Date
C.O.B. May3, 2000
No later than 6/1 5/00
July 2000
Venue(s)
Examiner Training
Applicants' Facilities
Page 3 of 32
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2000 Green Zia Examiner Work Book
Step 2: Prepare
A. Check conflict of interest. Read the eligibility determination form and Organizational Overview with particular attention to the
applicant's organization chart, customers, competitors, and suppliers. Notify the Green Zia Program Administrator immediately
if you identify any situation, including business, personal, or financial relationships, that could be perceived as affecting your
ability to review the applicant fairly and objectively.
B. Assemble your supplies. To complete an evaluation you will need the following:
• Green Zia Program Information and Critieria - 2000
• Application Report
• 2000 Green Zia Work Book (this document)
• Calculator
• Writing implements/marking tools
• Watch or clock
Reserve large chunks of time to evaluate the application, which typically takes a total of 20-40 hours. Keep track of your time to
record the total hours and report to your Senior Examiner at the end of the Consensus Meeting.
C. Mark the organization chart and glossary of the application for easy reference.
D. Review the appropriate Criteria (Commitment or Achievement/Excellence). You will need a working knowledge of all sections
(e.g., Criteria, Scoring System, Core Values, and Glossary) in order to properly evaluate an applicant.
E. Read the entire application report from cover to cover, including the eligibility determination form, the Organizational Overview,
and the applicant's response to the Criteria Items.
F. Reread the Organizational Overview and eligibility determination form, noting (with highlighters or margin notes) the points that
are particularly relevant and important to the proper evaluation of the applicant and any emerging key themes. The applicant's
responses throughout the application and your evaluation should reflect the key business factors (KBFs) identified by the
applicant in its Organizational Overview.
G. Prepare the Key Business Factors Worksheet (referring to your highlighting or notes) by listing the key business factors for the
applicant. Use the headings and order presented in the Green Zia Program Information and Criteria 2000 handbook, pg. 14.
Step 3: Evaluate
A. Read the Criteria requirements for the Item being reviewed, noting if the Item requests the applicant to discuss an approach
and its deployment, or the results of approaches discussed in other parts of the application.
B. Review the applicant's KBFs. These key factors should already be included on the Key Business Factors Worksheet.
C. Read the applicant's response to the same Item. Make notes by highlighting key information and writing margin notes. Assess
what is written and reasonably supported in the application. If the applicant provides cross-references, or if you find relevant
information elsewhere in the application report, consider that information in your assessment of the Item. However, do not
make assumptions, positive or negative, that cannot be supported by the information presented in the application report.
D. Synthesize from your notes the most important observations into 5-8 comments about the applicant's approach/deployment or
results for the Item, using the 3-part comment writing guidelines presented during Examiner Training and noted in the Comment
Guidelines section of this document.
E. Record the comments as strengths or opportunities for improvement (OFIs) in the space provided on the Item Worksheet for
that Item.
1. Each of the 5-8 comments should typically consist of 1-3 complete, declarative, and nonprescriptive sentences that use
specific examples from the application. Ensure that they relate to the major Item requirements. Link them to the applicant's
KBFs, as appropriate.
2. Answer the "so what" question, indicating the significance of the comment in relation to the evaluation and/or effectiveness
of the applicant's performance excellence system.
3. Record an OFI on any Area to Consider to which the applicant has not responded.
4. Ensure that all comments are well written and follow the Comment Guidelines presented during Examiner Training and
noted in the Comment Guidelines section of this document.
5. Preface all comments on strengths with a (+ or ++) sign. Use a (- or — ) sign to indicate OFIs. Double ++ and — indicate
particularly important observations that have a major impact on the applicant's score for the Item and/or particular
significance to the applicant's performance management system. Designate comments concerning important missing
information with a (- or —). For both strengths and OFIs on each Item, use a, b, c, (1), (2), (3), to indicate the
corresponding Area to Consider found in the Item.
Page 4 of 32
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2000 Green Zia Examiner Work Book
H. Record site visit issues in the space provided on the Item Worksheet. These are major/important issues that should be verified
or clarified on site. Issues for on-site verification include the applicant's approach, the extent of deployment of the approach,
and the results presented. For example, if a strength comment discusses the existence of a systematic process, the team
would want to verify that the process exists and operates as presented in the written application.
Issues for on-site clarification include information that is unclear or not provided that is central to the Item requirements and
relevant and important to the applicant's business which may have prevented the Consensus Team from fully and fairly
evaluating the applicant. For example, if the Item requires the applicant to present comparison data, but those data are not
provided, a site visit issue would be to clarify if the applicant has comparison data and, if so, if it is used and what the data
show about the applicant's reported results relative to other organizations.
Step 4: Score
A. Review your comments, the relative importance of the pluses and minuses, and the Item requirements.
B. Read the description of the scoring ranges in the appropriate Scoring Guidelines (Commitment or Achievement/Excellence) to
assign a percentage score for the Item. The Scoring Guidelines are divided into two parts: Approach/Deployment Items, and
Results Items. Note that Approach/Deployment Item scoring ranges are determined by the strength of the applicant's approach,
deployment, improvement, and integration. Results scoring ranges are determined by levels, trends, comparisons, and
relevance to improving the organization's performance.
C. Determine the scoring range (0%, 10-20%, 30-40%, 50-60%, 70-80%, 90-100%) which best reflects the comments written
about the applicant's level of performance on this Item. Score each Item independently. Do not let your impression of the
applicant on other Items influence your evaluation of this Item. Applicants will typically be stronger in some Items than others.
D. Determine an appropriate score within the scoring range. For the independent review, use only multiples of 10% (i.e., 10%,
20%, not 15%, 28%). Enter your percent score in the space provided at the bottom of each Item Scoresheet.
For the consensus review, if using the average, first round percent scores to the nearest whole number. Next, round
the point scores to the nearest whole number.
The comments and the score for an Item should be consistent, both in terms of the number of comments distributed between
the strengths and the OFIs, and the weight and substance of the comments themselves. For example, the 5-8 comments for an
Item scored at 20% would appear predominantly in the OFI section of the Item Worksheet.
E. Reread the comments to ensure that they are consistent with the score and the language of the scoring range. Alter
language/score, as necessary.
F. Repeat the Evaluate and Score steps for each Item and Category of the appropriate Criteria (Achievement or
Achievement/Excellence)
G. Send Item Worksheets to the designated Category Champion for Compilation
Step 5: Finalize (Consensus Meeting)
A. Review all Compiled Item Worksheets to ensure that:
1. comments are consistent within and among Items (an aspect of the application cannot be a strength in one Item and an
OFI in the same or another Item); and
2. comments cover the major points and objectives of the appropriate Criteria, reflect the core values, and focus on what is
important to the applicant as determined by the KBFs.
B. Consense on Strength and OFI comments
C. Consense on Scoring for each Item
1. Record each examiner's individual score in the appropriate column on the Achievement/Excellence Scoresheet, or record
the team's consensus around the Commitment applicant's response (with a check in the appropriate column).
2. Record the % Consensus Score in the appropriate column of the Achievement/Excellence Scoresheet or record any team
comments in the appropriate column in the Commitment Scoresheet
3. Compute and record the Item score in the appropriate column of the Achievement/Excellence Scoresheet
4. Compute and record the Category score in the appropriate column of the Achievement/Excellence Scoresheet
5. Compute and record a Grand Total by summing the Category point scores.
6. Verify scores and calculations.
D. Compile a list of consensed site visit issues, by item.
Step 6: Compile and Return to the Green Zia Program Office (Senior Examiners)
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2000 Green Zia Examiner Work Book
A. Assemble a paper and/or electronic copy of the Team's Work Products with the pages in the following order:
1. Cover Sheet
2. Executive Summary
3. Compiled and edited feedback for all Items/Categories
4. Appropriate Score Summary Worksheet (Commitment or Achievement/Excellence)
B. Assemble the compiled list of site visit issues from the team's consensus
C. Send the entire package to the Green Zia Program Administrator's Office:
Patricia Gallagher
Pollution Prevention/Green Zia Program Coordinator
New Mexico Environment Department
Office of the Secretary
PO Box 26110
Santa Fe, NM 87502
505-827-0677 (phone)
505-827-2836 (fax)
pat_gallagher@nmenv.state.nm.us
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2000 Green Zia Examiner Work Book
COMMENT GUIDELINES
Guidelines for Individual Comments
1. Comment on what is central to the Criteria Item and relevant and important to the applicant based on the key business/school
factors. Respond to the basic objectives of the Item. Comment only on the requirements of the Criteria without going beyond.
2. Include examples of processes, programs, deployment and/or results that support the comment
3. Answer the "so what" question; indicate the significance of the comment in relation to the evaluation and/or effectiveness of
the applicant's performance excellence system.
4. Use one to three clear, simple, grammatically correct, and complete sentences. Use notations (a, b, c and +, ++, -, —). Use
vocabulary and phraseology from the Criteria, core values, and Scoring Guidelines.
5. Use a polite, professional, and positive tone.
6. Avoid jargon and acronyms, unless used by the applicant.
7. Use the applicant's terminology without "parroting" the application.
8. State observations; be non-judgmental — avoid "good," "bad," and "inadequate"; be nonprescriptive — refrain from using
"could," "should," and "would."
9. Avoid critiquing the style/organization of the application; comment on the approach, deployment, or results of the performance
management system.
10. Identify the strengths (using specific examples from the application) or the OFIs (using specific omissions or problems in the
application report). If something "is not clear," give examples of what additional information is needed.
11. If you are commenting on information from a figure or if you refer to a figure, provide the figure number, particularly on results
Items.
Guidelines for Item Worksheets
1. Comment on each Item — usually 5-8 comments per Item.
2. Comments drive the numerical score:
• Balance of strengths and OFIs should reflect score.
• Comments on low scoring Items should focus on basic information.
• Comments on higher scoring Items should focus on finer points.
3. Ensure that strengths do not conflict with OFIs in the same or another Item.
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2000 Green Zia Examiner Work Book
Key Business Factors Worksheet
To begin the scoring process, review the Applicant's Organizational Overview and the eligibility determination form.
List the key business factors for this applicant using the headings and the order presented in the Program Information
and Application Criteria, 2000 Hand Book.
Basic Description of the Enterprise
• Products and Services
• Market
• Employees/Facilities
Division
Total
Employee Count
Facilities
• Other
Customer Requirements
• Customers
• Stakeholders
Supplier and Partnering Relationships
Competitive Factors
Regulatory Environment
Critical Success Factors
Other
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2000 Green Zia Examiner Work Book
Linkages Chart: "X" Illustrates Potential Linkages Between Category Items
Item
Number
1.1
1.2
2.1
2.2
2.3
3.1
3.2
3.3
4.1
4.2
5.1
5.2
5.3
6.1
6.2
7.1
7.2
7.3
1.1
X
X
X
X
X
X
1.2
X
X
X
X
2.1
X
X
X
X
X
X
X
X
2.2
X
X
X
X
X
2.3
X
X
X
X
X
3.1
X
X
X
X
3.2
X
X
X
X
X
X
3.3
X
X
X
X
X
4.1
X
X
X
X
X
X
X
X
X
X
4.2
X
X
X
X
X
X
X
X
5.1
X
X
X
X
5.2
X
X
X
X
X
X
X
X
X
X
5.3
X
X
X
X
X
6.1
X
X
X
X
X
6.2
X
X
X
X
X
X
X
X
7.1
X
X
X
X
X
X
7.2
X
X
X
X
X
X
X
X
X
X
7.3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
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2000 Green Zia Examiner Work Book
Item 1.1 Organizational Leadership (75 pts) (Approach-Deployment)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
Page 11 of 32
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2000 Green Zia Examiner Work Book
Item 1.2 Community Leadership (50 pts) (Approach-Deployment)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
Page 12 of 32
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2000 Green Zia Examiner Work Book
Item 2.1 Strategic Planning for Environmental Improvement
(Approach-Deployment)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
(50 pts)
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
Page 13 of 32
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2000 Green Zia Examiner Work Book
Item 2.2 Action Planning (50 pts) (Approach-Deployment)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
Page 14 of 32
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2000 Green Zia Examiner Work Book
Item 2.3 Integration and Implementation (50 pts) (Approach-Deployment)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
Page 15 of 32
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2000 Green Zia Examiner Work Book
Item 3.1 Customer Involvement (25 pts) (Approach-Deployment)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
Page 16 of 32
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2000 Green Zia Examiner Work Book
Item 3.2 Supplier Involvement (25 pts) (Approach-Deployment)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
Page 17 of 32
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2000 Green Zia Examiner Work Book
Item 3.3 Others Involvement (25 pts) (Approach-Deployment)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
Page 18 of 32
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2000 Green Zia Examiner Work Book
Item 4.1 Information Collection and Management
Deployment
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
(60 pts) (Approach-
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
Page 19 of 32
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2000 Green Zia Examiner Work Book
Item 4.2 Analysis and Decision-Making (40 pts) (Approach-Deployment)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
Page 20 of 32
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2000 Green Zia Examiner Work Book
Item 5.1 Employee Education and Skill Development (50 pts) (Approach-
Deployment)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
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2000 Green Zia Examiner Work Book
Item 5.2 Employee Involvement (55 pts) (Approach-Deployment
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
Page 22 of 32
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2000 Green Zia Examiner Work Book
Item 5.3 Employee Satisfaction, Value and Well-being
Deployment)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
(2Opts) (Approach-
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
Page 23 of 32
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2000 Green Zia Examiner Work Book
Item 6.1 Process Characterization and Control (50 pts) (Approach-Deployment)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
Page 24 of 32
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2000 Green Zia Examiner Work Book
Item 6.2 Process Improvement (50 pts) (Approach-Deployment)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
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2000 Green Zia Examiner Work Book
Item 7.1 Environmental Results (100pts)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
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2000 Green Zia Examiner Work Book
Item 7.2 Customer, Supplier, Employee and Other Results (150 pts)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
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2000 Green Zia Examiner Work Book
Item 7.3 Financial Results (75 pts)
Prepare one Item Worksheet for each Item of the 2000 Green Zia Criteria
#
Area
(+) Strengths
#
Area
(-) Opportunities for Improvement
Site Visit Issues
Item Number:
Percent Score
Page 28 of 32
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2000 Green Zia Examiner Work Book
SCORING GUIDELINES: Approach and Deployment
SCORE
APPROACH/DEPLOYMENT
0%
no systematic approach evident; anecdotal information
10%
to
20%
beginning of a systematic approach to the basic purposes of the Item
major gaps exist in deployment that would inhibit progress in achieving the basic purposes
of the Item
early stages of a transition from reacting to problems to a general improvement orientation
30%
to
40%
a sound, systematic approach, responsive to the basic purposes of the Item
approach is deployed, although some areas or work units are in early stages of
deployment
beginning of a systematic approach to evaluation and improvement of basic Item processes
50%
to
60%
a sound, systematic approach, responsive to the overall purposes of the Item
approach is well-deployed, although deployment may vary in some areas or work units
a fact-based, systematic evaluation and improvement process is in place for basic Item
processes
approach is aligned with basic organizational needs identified in the other Criteria
Categories
70%
to
80%
a sound, systematic approach, responsive to the multiple requirements of the Item
approach is well-deployed, with no significant gaps
a fact-based, systematic evaluation and improvement process and organizational
learning/ sharing are key management tools; clear evidence of refinement and improved
integration as a result of organizational-level analysis and sharing
approach is well-integrated with organizational needs identified in the other Criteria
Categories
90%
to
100%
a sound, systematic approach, fully responsive to all the requirements of the Item
approach is fully deployed without significant weaknesses or gaps in any areas or work
units
a very strong, fact-based, systematic evaluation and improvement process and extensive
organizational learning/sharing are key management tools; strong refinement and
integration, backed by excellent organizational-level analysis and sharing
approach is fully integrated with organizational needs identified in the other Criteria
Categories
Page 29 of 32
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2000 Green Zia Examiner Work Book
SCORING GUIDELINES: Results
SCORE
RESULTS
0%
no results or poor results in areas reported
10%
to
20%
• some improvements and/or early good performance levels in a few areas
• results not reported for many to most areas of importance to your organization's key
business requirements
30%
to
40%
improvements and/or good performance levels in many areas of importance to your
organization's key business requirements
early stages of developing trends and obtaining comparative information
results reported for many to most areas of importance to your organization's key business
requirements
50%
to
60%
improvement trends and/or good performance levels reported for most areas of
importance to your organization's key business requirements
no pattern of adverse trends and no poor performance levels in areas of importance to
your organization's key business requirements
some trends and/or current performance levels - evaluated against relevant comparisons
and/or benchmarks - show areas of strength and/or good to very good relative
performance levels
business results address most key customer, market, and process requirements
70%
to
80%
current performance is good to excellent in areas of importance to your organization's key
business requirements
most improvement trends and/or current performance levels are sustained
many to most trends and/or current performance levels - evaluated against relevant
comparisons and/or benchmarks - show areas of leadership and very good relative
performance levels
business results address most key customer, market, process, and action plan
requirements
90%
to
100%
current performance is excellent in most areas of importance to your organization's key
business requirements
excellent improvement trends and/or sustained excellent performance levels in most areas
evidence of industry and benchmark leadership demonstrated in many areas
business results fully address key customer, market, process, and action plan
requirements
Page 30 of 32
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2000 Green Zia Examiner Work Book
Green Zia Achievement/Excellence Scoring Sheet
Category H tern
1.0 Leadership
1.1 Organizational
Leadership
1.2 Community
Leadership
2.0 Planning for
Continuous
Environmental
Improvement
2. 1 Strategic Planning for
Continuous
Environmental
Improvement
2.2 Action Planning
2.2 Integration And
Implementation
3.0 Customer, Market and
Others' Involvement
3.1 Customer Involvement
3.2 Supplier Involvement
3.3 Other's Involvement
4.0 Information and
Analysis
4. 1 Information Collection
and Management
4.2 Analysis and Decision
making
5.0 Employee Participation
5.1 Employee Education
and Skill Development
5.2 Employee Involvement
5.3 Employee Satisfaction,
Value and Well-being
6.0 Process Management
6. 1 Process
Characterization and
Control
6.2 Process Improvement
7.0 Results
7. 1 Environmental Results
7.2 Customer, Supplier,
Employee and Other
Results
7.3 Financial Results
Total
Points
Avail
125
75
50
150
50
50
50
75
25
25
25
100
60
40
125
50
55
20
100
50
50
325
100
150
75
Individual Percent Score
Consensus
% Scores
Item
Score
Category
Score
TOTAL SCORE
Page 31 of 32
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2000 Green Zia Examiner Work Book
Green Zia Commitment Level Scoring Matrix
Category
V*
Examiner Comments/Notes
Category 1: Leadership
The applicant explains how management commitment to continuous environmental improvement is:
• Communicated to employees
• Demonstrated within the organization
• Communicated to communities
• Demonstrated in the community
Category 2: Planning for Continuous Environmental Improvement
The applicant describes how:
• Long and short term goals and objectives are identified
• Long and short term goals and objectives are developed
• Long and short term goals are implemented
• Goals and objectives relate to overall business objectives
Category 3: Customer, Supplier, and Others Involvement
The applicant describes how the organization:
• Involves customers and suppliers and others in the development
of the company's continuous environmental improvement
program
• Involved in other organizations' continuous environmental
improvement program
Category 4: Information and Analysis
The applicant describes how the organization:
• Collect information to make environmental improvement
decisions
• Use information to make environmental improvement decisions
Category 5: Employee Involvement
The applicant describes how:
• Prepare and involve employees in development and
implementation of continuous environmental improvement
approaches.
• Involve employees in development and implementation of
continuous environmental improvement approaches.
• Employee value and well-being is considered in developing
continuous environmental improvement approach
Category 6: Process Management
The applicant describes how the organization:
• Identifies processes with environmental impacts
• Analyzes process to address environmental impacts
• Manages processes to address environmental impacts
Category 7: Results
The applicant is developing methods to report environmental performance levels or trends in:
• Environmental results
• Customer, Supplier, and Employee and Other results
• Financial results
Total checks
*Place a check mark in the 2n column of Categories 1-6 where the applicant shows a beginning systematic approach to the primary purposes of
the item, and of Category 7 where the applicant shows early signs of reporting key results data.
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