United States
Environmental Protection
Agency
An Organizational Guide to
Pollution Prevention

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                                       Appendix E
                           Waste Minimization  Techniques
The tables in this appendix lists techniques and practices for waste reduction in operations that are
applied in a wide range of industries. Most of the techniques listed here are source reduction techniques.
   Table E-1.   Waste Minimization Options for Coating Operations
   Table E-2.   Waste Minimization Options for Equipment Cleaning Operations
   Table E-3.   Waste Minimization through Good Operating Practices
   Table E-4.   Waste Minimization Options in Materials Handling, Storage, and Transfer
   Table E-5.   Waste Minimization Options for Parts Cleaning Operations
Source: Jacobs Engineering Group

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Table E-1.  Waste Minimization  Options for  Coating  Operations
        Waste
     Source/Origin
        Waste Reduction Measures
             Remarks
References
  Coating overspray
 Coating material that fails
 to reach the object being
 coated
Maintain 50% overlap between spray pattern
Maintain 6* - 8* distance between spray gun
and the workplace
Maintain a gun speed of about 250 feet/minute
Hold gun perpendicular to the surface
Trigger gun at the beginning and end of each
pass
Proper training of operators
Use robots for spraying
Avoid excessive air pressure for coating
atomization
Recycle overspray
Use electrostatic spray systems
Use air-assisted airless spray guns in place of
air-spray guns
The coated object does not look
 streaked, and wastage of coating
 material is avoided. If the spray
 gun is arched 45°, the overspray
 can be as high as 65%,
                                                                                                       By air pressure adjustment,
                                                                                                        overspray can be reduced to 40%.

                                                                                                       Overspray can be reduced by 40%.
                                                                                                       Increases transfer efficiency.
    1,2
                                                                                                                            2
                                                                                                                            2
                                                                                                                            2

                                                                                                                            3
                                                                                                                            4
                                                                                                                            4
  Stripping wastes
Coating removal from parts
before applying a new coat
  Solvent emissbns
  Equipment cleanup
     wastes
Evaporative losses from
process equipment and
coated parts
Process equipment cleaning
with solvents
  Overall
Avoid adding excess thinner
Use abrasive media stripping
Use bead-blasting for paint stripping
Use cryogenic stripping
Use caustic stripping solutions
Clean coating equipment after each use

Keep solvent soak tanks away from heat sources
Use high-solids formulations
Use powder coatings
Use water-based formulations

Light-to-dark batch sequencing
Produce large batches of similarly coated
objects instead of small batches of differently
coated Hems
Isolate solvent-based paint spray booths from
water-based paint spray booths
Reuse cleaning solution/solvent
Standardize solvent usage

Reexamine the need for coating, as well as
available alternatives
Reduces stripping wastes due to rework.
Solvent usage is eliminated.
Solvent usage is eliminated.
Solvent usage is eliminated.
Solvent usage is eliminated.
                                                                                                       Lower usage of solvents.
                                                                                                       Avoids solvent usage.
                                                                                                       Avoids solvent usage.
     6
     7
     8
     1

     9

   10,11
    4,12

    13
                                                                                                                                                 20

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Table  E-2.  Waste  Minimization  Options  for Equipment  Cleaning  Operations
      Waste
    Source/Origin
        Waste Reduction Measures
          Remarks
References
  Spent solvent- or
  inorganic-based
  cleaning solutbns
Tank cleaning operatbns
• Maximize dedication of process equipment
• Use squeegees to recover cling of product
  prior to rinsing
* Avoid unnecessary cleaning
* Closed storage and transfer systems
* Provide sufficient drain time for liquids
* Lining the equipment to prevent cling
* "Pigging" process lines
« Use high-pressure spray nozzles
* Use countercurrent rinsing
* Use clean-in-place systems
• Clean equipment immediately after use

• Reuse cleanup solvent
• Rework cleanup solvent into useful products
* Segregate wastes by solvent type
• Standardize solvent usage
* Reclaim solvent by distillation
* Schedule production to lower cleaning
  frequency
                                                                                                   Scaling and drying up can be prevented.
                                                                                                   Minimizes leftover material.
                                                                                                   Reduces ding.

                                                                                                   Minimizes solvent consumption.
                                                                                                   Prevents hardening of scale that requires
                                                                                                    more severe cleaning.
                                                                                                                  18
                                                                                                                  19
  Wastewater
  sludges, spent
  acidic solutions
Heat exchanger cleaning
  Use bypass control or pumped recycle to
  maintain turbulence during turndown
  Use smooth heat exchange surfaces
  Use on-stream cleaning techniques
  Use hydroblasting over chemical cleaning
  where possible
Onsite or offsite recycling.

Electroplated or Tefbn® tubes.
"Superscrubber", for example.
                                                                                                                     20
                                                                                                                     21

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Table E-3.   Waste Minimization through Good  Operating  Practices
     Good Operating Practice
               Program Ingredients
               Remarks
                                                                                               References
  Waste minimization assessments
  Environmental audits/reviews
   Loss prevention programs
  Waste Segregation
  Preventive maintenance programs
Form a team of qualified individuals
Establish practical short-term and long-term goals
Allocate resources and budget for the program
Establish assessment targets
Identify and select options to minimize waste
Periodically monitor the program's effectiveness

Assemble pertinent documents
Conduct environmental process reviews
Carry out a site inspection
Report on and follow up on the findings

Establish Spill Prevention, Control, and
Countermeasures (SPCC) plans
Conduct hazard assessment in the design and
operating phases

Prevent mixing of hazardous wastes with
non-hazardous wastes
Isolate hazardous wastes by contaminant
Isolate liquid wastes from solid wastes

Use equipment data cards on equipment location,
characteristics, and maintenance
Maintain a master preventive maintenance (PM)
schedule
Deferred PM reports on equipment
Maintain equipment history cards
Maintain equipment breakdown reports
Keep vendor maintenance manuals handy
Maintain a manual or computerized repair history file
                                                                                             These programs are conducted to reduce
                                                                                              waste in a facility.
                                           22
These audits are conducted to monitor
 compliance with regulations.
SPCC plans are required by law for oil
  storage facilities.
These measures can result in lower waste
  haulage volumes and easier disposal of
  the hazardous wastes.
These programs are conducted to cut
 production costs and decrease
 equipment downtime, in addition
 to preventing waste releases due
 to equipment failure.
                                                                                                                                       23,24
                                                                                                                                      3,25,26
27,28,29

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Table E-3.  Waste  Minimization through Good  Operating Practices  (continued)
        Good Operating Practice
               Program Ingredients
             Remarks
References
    Training/Awareness-building
    programs
    Effective supervision
    Employee participation
    Production scheduling/planning
    Cost accounting/allocation
Provide training for
- Safe operation of the equipment
- Proper materials handling
- Economic and environmental ramif icatbns of
  hazardous waste generation and disposal
- Detecting releases of hazardous materials
- Emergency procedures
- Use of safety gear

Closer supervision may improve production efficiency
and reduce inadvertent waste generation
Management by objectives (MBO), with goals for
waste reduction

"Quality circles" (free forums between employees
and supervisors) can identify ways to reduce  waste
Solicit employee  suggestions for waste reduction ideas

Maximize batch size
Dedicate equipment to a single product
Alter batch sequencing to minimize cleaning frequency
(light-to-dark batch sequence,  for example)
Schedule production to minimizing cleaning frequency

Cost accounting done for all waste streams leaving
the facilities
Allocate waste treatment and disposal costs to the
operations that generate the waste
These programs are conducted to reduce
 occupational health and safety
 hazards, in addition to reducing
 waste generation due to operator
 or procedural errors.
Increased opportunity for early detection
 of mistakes.
Better coordination among the various
 parts of an overall operation.

Employees who intimately understand the
 operations can identify ways to reduce
 waste.

Altering production schedule can have a
 major impact on waste minimization.
Allocating costs to the waste-producing
 operations will give them an incentive
 to cut their wastes.

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Table E-4.  Waste  Minimization Options in  Materials Handling, Storage, and  Transfer
      Waste/Source
          Waste Reduction Measures
              Remarks
References
  Material/waste tracking and
   inventory control
Avoid over-purchasing
Accept raw material only after inspection
Ensure that inventory quantity does not go to
waste
Ensure that no containers stay in inventory
longer than a specified period
Review material procurement specifications
Return expired material to supplier
Validate shelf-life expiration dates
Test outdated material for effectiveness
Eliminate shelf-life requirements for stable
compounds
Conduct frequent inventory checks
Use computer-assisted plant inventory system
Conduct periodic materials tracking
Proper labeling of all containers
Set up manned stations for dispensing
chemicals and collecting wastes
These procedures are employed to find
 areas where the waste minimization
 efforts are to be concentrated.
  30,31
   Loss prevention programs
Use properly designed tanks and vessels only for
their intended purposes
Install overflow alarms for all tanks and vessels
Maintain physical integrity of all tanks and vessels
Set up written procedures for all loading/unloading
and transfer operations
Install secondary containment areas
Forbid operators to bypass interlocks, alarms, or
significantly alter setpoints without authorization
Isolate equipment or process lines that leak or are
not in service
Use seal-less pumps
Use bellows-seal valves
Document all spillage
Perform overall material balances and estimate
the quantity and dollar value of all losses
Use floating-roof tanks for VOC control
Use conservation vents tin fixed roof tanks
Use vapor recovery systems

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Table  E-4.  Waste Minimization Options in  Materials Handling, Storage,  and Transfer  (continued)

      Waste/Source                             Waste Reduction Measures                                Remarks                      References

  Spills and leaks                      * Store containers in such a way as to albw for
                                        visual inspection for corrosion and leaks
                                      • Stack containers in a way to minimize the chance
                                        of tipping, puncturing, or breaking
                                      • Prevent concrete "sweating* by raising the
                                        drum off storage areas
                                      • Maintain MSDSs to correctly handle spill
                                        situations
                                      * Provide adequate lighting in the storage area
                                      • Maintain a clean, even surface in transportation
                                        areas
                                      • Keep aisles clear of obstruction
                                      » Maintain distance between incompatible chemicals
                                      * Maintain distance between different types of
                                        chemicals to prevent cross-contamination
                                      • Avoid stacking containers against process
                                        equipment
                                      * Follow manufacturers' suggestions on the storage
                                        and handling of all raw materials
                                      * Insulation and inspection of electric circuitry for
                                        corrosion and potential  sparking



  Cling                               * Use large containers instead of small containers
                                        whenever possible
                                      * Use containers with height-to-diameter ratio equal
                                        to one to minimize wetted area
                                      * Empty drums and containers thoroughly before
                                        cleaning or disposal

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Table  E-S.  Waste  Minimization Options  for Parts Cleaning Operations
    Waste
      Source/Origin
        Waste Reduction Measures
              Remarks
References
Spent solvent
Contaminated solvent from
parts cleaning operations
Use water-soluble cutting fluids instead
of oil-based fluids
Use peel coatings in place of protective oils
Use aqueous cleaners
Use aqueous paint stripping solutions
Use cryogenic stripping
Use bead blasting for paint stripping
Use multi-stage countercurrent cleaning
Prevent cross-contamination
Prevent drag-in from other processes
Prompt removal of sludge from the tank
Reduce the number of different solvents
used
This could eliminate the need for solvent
 cleaning.
                                                                                                   A single, larger waste that is more
                                                                                                    amenable to recycling.
                                                                                                                                             8
                                                                                                                                             7
                                                                                                                                             6
Air emissions
Solvent toss from
degreasers and cold tanks
Use roll-type covers, not hinged covers
Increase freeboard height
Install freeboard chillers
Use silhouette entry covers
Proper equipment layout
Avoid rapid insertion and removal of items

Avoid inserting oversized objects into
the tank

Allow for proper drainage before removing
item
Avoid water contamination of solvent
in degreasers
24 to 50% reduction in emissions.
39% reduction in solvent emissions.
                                                                                                   The speed that items are put into the
                                                                                                    tank should be less than 11 feet/min.
                                                                                                   Cross-sectional area of the item should
                                                                                                    be less that 50% of tank area to reduce
                                                                                                    piston effect.
    15
    15
    15
                                                                                                                           16

                                                                                                                           17
Rinse water
Water rinse to remove
solvent carried out with
the parts leaving the
cleaning tank
Reduce solvent dragout by proper design and
operation of rack system

Install air jets to blow parts dry
Use fog nozzles on rinse tanks
Proper design and operation of barrel system
Use countercurrent rinse tanks
Use water sprays on rinse tanks
The dragout can be 0.4 gal/1000 sqft,
 versus 24 gal/1000 sqft for poorly
drained parts.
                                                                                                   More efficient rinsing is achieved.
    15
                                                                                                                           15
                                                                                                                           15
                                                                                                                           15

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                                       Appendix E
                                       References

1,   Kohl, J., J. Pearson, and P. Wright.  Managing and Recycling Solvents In the Furniture Industry.
    North Carolina State University, Raleigh, 1986.

2,   Lenckus, D. "Increasing productivity". Finishing Wood and Wood Products Magazine. Vol. 87, No.
    4, May 1982, pp 44-66.

3.   Campbell,  M.  E., and W. M. Glenn.  Profit from Pollution  Prevention.  The Pollution Probe
    Foundation. Toronto, Canada, 1982.

4.   Kohl, J., P. Moses, and B. Triplett.  Managing and Recycling Solvents:  North Carolina Practices.
    Facilities, and Regulations. North Carolina State University, Raleigh, 1984.

5.   Durney, J. J. "How to improve your paint stripping". Product Finishing. December 1982, pp 52-53.

6.   Higgins, T. E.  Industrial process Modifications to Reduce Generation of Hazardous Waste at POP
    Facitities: Phase I Report. CH2M Hill, Washington, D.C., 1985.

7.   "Cryogenic paint stripping". Product Finish. December 1982.

8.   Mallarnee, W. M. "Paint and varnish removers". Klrk-Qthmer Encyclopedia of Chemical Technology.
    3rd edition, Volume 16, pp 762-767,1981.

9.   Sandberg, J. Final Report on the Internship served at Gage Tool Company.  Minnesota Technical
    Assistance Program, Minnesota Waste Management Board, Minnesota, 1985.

10. Powder Coatings institute.  Information brochure.  Washington, P. C., 1983.

11. Cole, G. E.  "VOC emission reduction and other benefits achieved by major powder coating
    operations". Paper No. 84-38.1 presented at the Air Pollution Control Association. June 25,1984.

12. California State Department of Health Services. Alternative Technology for Recycling and.Treatmjnj
    of Hazardous Waste. 3rd Biennial Report.  Sacramento, 1986.

13. California State Department of Health Services.   Guide to Solvent Waste  Reduction Alternatives.
    October 1986, pp 4-25 to 4-49.

14. Kenson, R. E.  "Recovery and reuse of solvents from VOC air emissions". Environmental Progress.
    August  1985, pp 161-165.

15. Dumey, L. J., editor. Electroplating Engineering Handbook.  4th edition.  Van Nostrand Reinhold,
    New York, 1984.

16. American Society of  Testing Materials.  Handbook of  Vapor Degreasing.  Special Technical
    Publication 310-A., ASTM, Philadelphia, April 1976.

17. Smith, C. Troubleshooting vapor degreasers". Product .Fjnjsjrt.  November  1981.

18. Loucks, C. M.  "Boosting capacities with chemicals*.  Chemical Engineering Deskbook Issue. Vol.
    80, No.  5, pp 79-84, 1973.

19. 3M Corporation. Ideas - A Compendium of 3M Success Stories.  St. Paul, MN.

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20.  Fromm, C. H., S. Budaraju, and S. A. Cordery.  "Minimization of process equipment cleaning waste".
     Conference proceedings of HAZTECH International, Denver, August 13-15,1986, pp 291-307.

21.  Versar, Inc. and Jacobs Engineering Group.  Waste Minimization: Issues and Options. Vol. II. U. S.
     Environmental Protection Agency, Washington, D. C., October 1986.

22.  Fromm, C. H. and M. S. Callahan.  "Waste reduction audit procedure". Conference proceedings of
     the Hazardous Materials Control Research Institute. Atlanta, 1986, pp 427-435.

23.  North  Carolina Pollution  Prevention Pays  Program.  Environmental Auditing.  North Carolina
     Department of Environmental Health. 1985.

24.  Baumer, R. A. Making environmental audits". Chemical Engineering. Vol. 89, No. 22. November 1,
     1982,p 101.

25.  Kletz, T. A. "Minimize your product spillage". Hydrocarbon Processing. Vol. 61, No. 3,1982, p 207.

26.  Sarokin, D. "Reducing hazardous wastes at the source: Case studies of organic chemical plants in
     New Jersey.   Paper presented at Source Reduction of Hazardous Waste Conference, Rutgers
     University, August 22,1985.

27.  Singh, J. B. and R. M. Allen.  "Establishing a preventive maintenance program". Plant Engineering.
     February 27,1986, p 46.

28.  Rimberg, D.  "Minimizing maintenance makes money".  Pollution Engineering.  Vol.  12, No. 3,
     December 1983, p 46.

29.  Parker, N. H.  "Corrective maintenance and performance optimization". Chemical Engineering. Vol.
     91, No. 7, April 16,1984, p93.

30.  Geltenan, E. "Keeping chemical records on track". Chemical Business. Vol. 6, No. 11,1984, p 47.

31.  Hickman, W. E. and W. D. Moore.  "Managing the maintenance dollar". Chemical Engineering. Vol.
     93, No. 7, April 24,1986, p 68.

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                                             Appendix  F
                 Government  Technical/Financial Assistance  Programs

The EPA's Office of Solid Waste and Emergency Response has set up a telephone call-in service to answer
questions regarding RCRA and Superfund (CERCLA):

     (800) 424-9346  (outside the District of Columbia)
     (202) 382-3000  (in the District of Columbia)

The following states have programs that offer technical and/or financial assistance in the areas of waste
minimization and treatment.
Alabama
   Hazardous Material Management and Resource
     Recovery Program
   University of Alabama
   P.O. Box 6373
   Tuscaloosa,  AL 35487-6373
   (205) 348-8401

Alaska
   Alaska Health Project
   Waste Reduction Assistance Program
   431 West Seventh Avenue, Suite 101
   Anchorage, AK 99501
   (907)276-2864

Arkansas
   Arkansas Industrial Development Commission
   One State Capitol Mall
   Little  Rock, AR 72201
   (501)371-1370

California
   Alternative Technology Section
   Toxic Substances Control Division
   California State Department of Health Services
   714/744 P Street
   Sacramento, CA 94234-7320
   (916)324-1807

Connecticut
   Connecticut  Hazardous Waste Management Service
   Suite 360
   900 Asylum Avenue
   Hartford, CT 06105
   (203) 244-2007

   Connecticut  Department of Economic Development
   210 Washington Street
   Hartford CT 06106
   (203)566-7196

Georgia
   Hazardous Waste Technical Assistance Program
   Georgia Institute of Technology
   Georgia Technical Research Institute
   Environmental Health and Safety Division
   O'Keefe Building, Room 027
   Atlanta, GA 30332
   (404)894-3806
Georgia  (continued)
   Environmental Protection Division
   Georgia Department of Natural Resources
   Royd Towers East, Suite 1154
   205 Butler Street
   Atlanta, CA 30334
   (404) 656-2833

Illinois
   Hazardous Waste Research and Information Center
   Illinois Department of Energy and Natural Resources
   1808 Woodfield Drive
   Savoy, IL61874
   (217)333-8940

   Illinois Waste Elimination Research Center
   Pritzker Department of Environmental Engineering
   Alumni Building, Room 102
   Illinois  Institute of Technology
   3200 South Federal Street
   Chicago, IL 60616
   (312)567-3535

Indiana
   Environmental Management and Education Program
   Young Graduate House, Room 120
   Purdue University
   West Lafayette, IN 47907
   (317)494-5036

   Indiana Department of Environmental Management
   Office of Technical Assistance
   P.O. Box 6015
   105 South Meridian Street
   Indianapolis, IN 46206-6015
   (317)232-8172

Iowa
   Iowa Department of Natural Resources
   Air Quality and Solid Waste Protection Bureau
   Wallace State Office Building
   900 East Grand Avenue
   Des Moines,  IA 50319-0034
   (515)281-8690

   Center for Industrial Research and Service
   205 Engineering Annex
   Iowa State University
   Ames, IA 50011
   (515) 294-3420

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Kansas
   Bureau of Waste Management
   Department of Health and Environment
   Forbes Field, Building 730
   Topeka, KS 66620
   (913)296-1607

Kentucky
   Division of Waste Management
   Natural Resources and Environmental Protection Cabinet
   18 Reilly Road
   Frankfort, KY 40601
   (502)564-6716

Louisiana
   Department of Environmental Quality
   Office of Solid and Hazardous Waste
   P.O. Box 44307
   Baton Rouge, LA 70804
   (504)342-1354

Maryland
   Maryland Hazardous Waste Facilities Siting Board
   60 West Street, Suite 200A
   Annapolis, MD 21401
   (301)974-3432

   Maryland Environmental Service
   2020 Industrial Drive
   Annapolis, MD 21401
   (301)269-3291
   (800) 492-9188 (in Maryland)

Massachusetts
   Office of Safe Waste Management
   Department of Environmental Management
   100 Cambridge Street, Room 1094
   Boston, MA
   (617)727-3260

   Source Reduction Program
   Massachusetts Department of Environmental Quality
     Engineering
   1  Winter Street
   Boston, MA 02108
   (617)292-5982

Michigan
   Resource Recovery Section
   Department of Natural Resources
   P.O. Box 30028
   Lansing, Ml 48909
   (517)373-0540

Minnesota
   Minnesota Pollution Control Agency
   Solid and Hazardous Waste Division
   520 Lafayette Road
   St. Paul, MN 55155
   (612)296-6300
Minnesota  (continued)
   Minnesota Technical Assistance Program
   W-140 Boynton Health Service
   University of Minnesota
   Minneapolis, MN 55455
   (612) 625-9677
   (800) 247-0015 (in Minnesota)

   Minnesota Waste Management Board
   123 Thorson Center
   7323 Fifty-Eighth Avenue North
   Crystal, MN 55428
   (612)536-0816

Missouri
   State Environmental Improvement and Energy
     Resources Agency
   P.O. Box 744
   Jefferson City, MO 65102
   (314)751-4919

New Jersey
   New Jersey Hazardous Waste Facilities Siting
     Commission
   Room 614
   28 West State Street
   Trenton, NJ 08608
   (609)292-1459
   (609)292-1026

   Hazardous Waste Advisement Program
   Bureau of Regulation and Classification
   New Jersey Department of Environmental Protection
   401 East State Street
   Trenton, NJ 08625

   Risk Reduction Unit
   Office of Science and Research
   New Jersey Department of Environmental Protection
   401 East State Street
   Trenton, NJ 08625

New York
   New York State Environmental Facilities Corporation
   50 Wolf Road
   Albany, NY 12205
   (518) 457-3273

North  Carolina
   Pollution Prevention Pays Program
   Department of Natural Resources and Community
     Development
   P.O. Box 27687
   512 North Salisbury Street
   Raleigh, NC 27611
   (919)733-7015

   Governor's Waste Management Board
   325 North Salisbury Street
   Raleigh, NC 27611
   (919) 733-9020

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North  Caroling (continued)
   Technical Assistance Unit
   Solid and Hazardous Waste Management Branch
   North Carolina Department of Human Resources
   P.O. Box 2091
   306 North Wilmington Street
   Raleigh. NC 27602
   (919)733-2178

Ohio
   Division of Solid and Hazardous Waste Management
   Ohio Environmental Protection Agency
   P.O. Box 1049
   1800 WaterMark Drive
   Columbus, OH 43266-1049
   (614)481-7200

   Ohio Technology Transfer Organization
   Suite 200
   65 East State Street
   Columbus, OH 43266-0330
   (614)466-4286

Oklahoma
   Industrial Waste Elimination Program
   Oklahoma State Department of Health
   P.O. Box 53551
   Oklahoma City, OK 73152
   (405)271-7353

Oregon
   Oregon Hazardous Waste Reduction Program
   Department of Environmental Quality
   811 Southwest Sixth Avenue
   Portland, OR 97204
   (503)229-5913

Pennsylvania
   Pennsylvania Technical Assistance Program
   501 F. Orvis Keller Building
   University Park, PA 16802
   (814)865-0427

   Bureau of Waste Management
   Pennsylvania Department of Environmental Resources
   P.O. Box 2063
   Fulton Building
   3rd and Locust Streets
   Harrisburg, PA17120
   (717)787-6239

   Center of Hazardous Material Research
   320 William Pitt Way
   Pittsburgh, PA 15238
   (412)826-5320

Rhode Island
   Ocean State Cleanup and Recycling Program
   Rhode Island Department of Environmental Management
   9 Hayes Street
   Providence, Rl 02908-5003
   (401)277-3434
   (800) 253-2674 (in Rhode Island)
Rhode Island  (continued)
   Center of Environmental Studies
   Brown University
   P.O. Box 1943
   135 Angell Street
   Providence, RI02912
   (401)863-3449

Tennessee
   Center for Industrial Services
   102 Alumni Hall
   University of Tennessee
   Knoxvilie, TN 37996
   (615) 974-2456

Virginia
   Office of Policy and Planning
   Virginia Department of Waste Management
   11th Floor, Monroe Building
   101 North 14th Street
   Richmond, VA 23219
   (804) 225-2667

Washington
   Hazardous Waste Section
   Mail Stop PV-11
   Washington Department of Ecology
   Olympia, WA 98504-8711
   (206)459-6322

Wisconsin
   Bureau of Solid Waste Management
   Wisconsin Department of Natural Resources
   P.O. Box 7921
   101 South Webster Street
   Madison, WI53707
   (608) 266-2699

Wyoming
   Solid Waste Management Program
   Wyoming Department of Environmental Quality
   Herschler Building, 4th Floor, West Wing
   122 West 25th Street
   Cheyenne, WY 82002
   (307) 777-7752

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                                             Appendix G
                                           Option  Rating
                                      Weighted Sum Method
The Weighted Sum Method is a quantitative method
for screening and ranking waste minimization options.
This  method provides a means ol  quantifying the
important criteria that  affect waste management in a
particular facility. This method involves three steps.

1.  Determine what the important criteria are in terms
    of  the WM  assessment  program  goals  a
    constraints, and the  overall corporate goats an
    constraints. Examples of criteria are the following:

    *  Reduction in waste quantity
    •  Reduction  in  waste  hazard  (e.g.,  toxiclty,
       flammabilrty, reactivity, corrosivity, etc.)
    •  Reduction in waste treatment/disposal costs
    •  Reduction in raw material costs
    •  Reduction in liability and insurance costs
    «  Previous successful use within the company
    »  Previous successful use in Industry
    »  Not detrimental to product quality
    •  Low capital cost
    •  Low operating and maintenance costs
    *  Short implementation period  (and  minimal
       disruption of plant operations)
    •  Ease of implementation

    The weights (on a scale of 0 to 10, for example) are
    determined for each of the criteria in  relation to
    their importance.For example, if reduction in waste
    treatment and disposal costs are very important,
    while previous successful use within the company
    is of minor importance, then the reduction in waste
    costs is given a weight of 10 and the previous use
    within the company is given a weight of 1  or 2.
    Criteria that are not important are  not included (or
    given a weight of 0).

2.  Each option is then rated on each of the criteria.
    Again, a scale of 0 to 10 can be used (0 for low and
    10 for high).

3.  Finally,  the rating  of each option from particular
    criteria is multiplied by the weight of the criteria. An
    option's overall rating is the sum of the products of
    rating times the weight of the criteria.

The options with  the  best overall ratings are then
selected for the technical and economic feasibility
analyses. Worksheet 13 in Appendix A is used to rate
options using the Weighted Sum method.  Table Q-1
presents an example using the Weighted Sum Method
for screening and ranking options.
Tabla  G-1.    Sample   Calculation  using  the
Weighted Sum  Method

ABC Corporation has determined that reduction in waste
treatment costs is the most important criterion, with a weight
factor of 10.  Other significant criteria include reduction in
safety hazard (weight of 8), reduction in liability (weight of 7),
and ease of implementation (weight of 5). Options X, Y, and
Z  are then each assigned  effectiveness  factors.  For
example, option X is expected to reduce waste by nearly
80%, and is given an rating of 8.  tt is given a rating of 6 for
reducing safety  hazards, 4 for reducing  liability,  and
because it is somewhat difficult to implement, 2 for ease of
implementation. The table below shows how the options are
rated  overall,  with effectiveness  factors  estimated  for
options Y and Z.
Patinas for each cotton
Rating Criteria
Reduce treatment costs
Reduce safety hazards
Reduce liability
Ease of implementation
Sum of weight times ratings
Weight
10
8
7
5
X Y Z
863
638
445
228
166 122 169
From this screening, option Z rates the highest with a score
of 169. Option X's score is 166 and option Y's score is 122.
In this case, option Z and option X should both be selected
for further evaluation because both of their scores are high
and relatively close to each other.

-------
                                          Appendix H
                               Economic  Evaluation Example
The following example presents a profitability analysis
for a relatively large hypothetical waste minimization
project. This project represents the installation of a
package unit that improves plant  production while
reducing raw material consumption and disposal costs.
The analysis was done on a personal computer using a
standard spreadsheet program. The salient data used
in this evaluation are summarized below.

Capital  Costs

*  The delivered price of the equipment is quoted by
   the vendor at $170,000.  This includes taxes and
   insurance.

*  Materials costs (piping, wiring, and concrete) are
   estimated at $35,000.

•  Installation labor is estimated at $25,000.

*  Internal engineering staff costs  are estimated at
   $7,000. Outside consultant and contractor costs
   are estimated at $15,000.

•  Miscellaneous  environmental permitting costs are
   estimated at $15,000.

*  Working capital (including chemical inventories, and
   materials and supplies) Is estimated at $5,000.

•  Start-up costs  are estimated by  the vendor at
   $3,000.

*  A contingency of $20,000 for unforeseen costs
   and/or overruns is included.

*  Planning, design, and installation are expected to
   take one year.

Financing

•  The  project  will be  financed 60% by retained
   earnings and 40% by a bank loan.

*  The bank loan will be repaid over 5 years of equal
   installments of principal, plus interest at an annual
   percentage rate of  13%.  Interest accrued during
   installation will be added into the total capital costs.

*  All capital costs, except working capital and interest
   accrued during construction, will be depreciated
   over  7  years using the double-declining  balance
   method, switching to the straight-line method when
   the charges by this method become greater.
* The marginal income tax rate is 34%.

• Escalation of all costs is assumed to be 5% per year
  for the life of the project.

» The firm's cost of capital is 15%.

Operating  Costs and Revenues

* The WM project is  estimated to decrease raw
  materials consumption by 300 units per year at a
  cost of $50 per unit. The project will not result in an
  increased production. However, it will  produce a
  marketable by-product to  be recovered at a rate of
  200 units per year and a price of $25 per unit.

* The project will reduce the quantity of hazardous
  waste disposed by 200 tons per year. The following
  items make the total unit disposal costs:

                            Costs per ton of waste
     Offsite disposal fees            $500
     State generator taxes              10
     Transportation costs               25
     Other costs                    	25
      TOTAL DISPOSAL COSTS    $560

* Incremental operating labor costs are estimated on
  the basis that the project is expected to require one
  hour of operator's time per eight-hour shift.  There
  are three shifts  per day and the plant operates 350
  days  per year.  The wage rate for operators is
  $12.50 per hour.

- Operating supplies expenses are estimated at 30%
  of operating labor costs.

* Maintenance labor costs are estimated at 2% of the
  sum of the capital costs for equipment, materials,
  and installation.  Maintenance supplies costs are
  estimated at 1% of these costs.

• Incremental supervision costs are estimated at 30%
  of the  combined  costs  of  operating  and
  maintenance labor.

• The following overhead costs  are estimated as a
  percentage  of  the  sum of operating  and
  maintenance labor and supervision costs.

     Labor burden and benefit       28%
     Plant overhead                25%
     Headquarter overhead         20%

-------
•  Escalation of all costs is assumed to be 5% per year
   for the life of the project.

*  The project life is expected to be 8 years.

*  The salvage value of the project is expected to be
   zero after eight years.

Results

The four-page  printout In  Figures H-1  through H-4
presents the WM  project  profitability  spreadsheet
program.  Figure H-1 represents the input section of
the program.  Each of the  numbers in the first three
columns represents an input variable in  the program.
The righthand side of Figure H-1 is a summary of the
capital requirement.  This includes a calculation of the
interest accrued during construction and  the financing
structure of the project.

Figure H-2 is a  table of the revenues and operating
cost Hems for each of the eight years of the project's
operating life.  These costs  are escalated by 5% each
year for the life of the project.

Figure H-3  presents the annual  cash flows for the
project. The calculation of depreciation  charges and
the payment of interest and repayment of  loan principal
is also  shown here.  The calculation of the internal rate
of return (IRR) and the net present value {NPV) are
based  on the annual cash flows.  Since  the project is
leveraged (financed partly by a bank loan), the equity
portion of the  investment is used as the initial cash
flow. The NPV and the IRR are calculated on this basis.
The IRR calculated this way is referred to  as the "return
on equity".  The program is structured to present the
NPV and IRR after each year of the project's operating
life.  In the example, after six years, the IRR is 19.92%
and the NPV is $27,227.

Figure  H-4 is a cash flow table based entirely on equity
financing.  Therefore, there are no interest payments
or deb principal repayments. The NPV and the IRR in
this case are based on the entire capital  investment in
the project.  The IRR calculated this way is referred to
as the  "return on investment".

The results of the profitability analysis for this project
are summarized below:

    Method of Financing        PR         APV

    60% equity/40% debt      26.47%      $84,844
    100% equity             23.09%      $81,625

The IRR values are greater than the  15% cost of
capital, and the NPVs  are positive.  Therefore, the
project is attractive, and should be  implemented.

-------
Waste Minimization
Profitability Program


Capital Cost Factors

Capital Cost
Equipment
Materials
Installation
Plant Engineering
Contractor/Engineering
Permitting Costs
Contingency
Working Capital
Start-up Costs

% Equity
%Debt
Interest Rate on Debt, %
Debt Repayment, years

Depreciation period
Income Tax Rate, %

Escalation Rates, %

Cost of Capital (for NPV)







$170,000
$35,000
$25,000
$7,000
$15,000
$15,000
$20,000
$5,000
$3,000

60%
40%
13.00%
5

7
34,00%

S.0%

15.00%




























started 5/22*7
last changed 8/1/87

WPUT




Operating Cost/Revenue Factors

Increased Production
Increased Rate, units/year
Price, $/unit

Marketable By-products
Rate, units/year
Price, $/unit

Decreased Raw Materials
Decreased Rate, units/year
Price, $/unit

Decreased Waste Disposal
Reduced Waste, tons/year
Offsrte Fees, $/ton
State Taxes, $/ton
Transportation! $/ton
Other Disposal Costs, $/ton
Total Disposal Costs, $Aon





0
$100


200
$40


300
$50


200
$500
$10
J25
$25
$560





































Operating Labor
Operator hours/shift
Shifts/day
Operating days/year
Wage rate, $/man-hour

Operating Supplies
(% of Operating Labor)

Maintenance Costs
(% of Capital Costs)
Labor
Materials

Other Labor Costs
(% of O&M Labor)
Supervision
(% of O&M Labor + Sue
Plant Overhead
Home Office Overhead
Labor Burden








1
3
350
$13.50

30%




2.00%
1.00%



30.0%
ervision
25.0%
20.0%
28.0%
































CAPITAL REQUIREMENT

Construction Year

Capital Expenditures
Equipment
Materials
Installation
Plant Engineering
Contractor/Engineering
Permitting Costs
Contingency
Start-up Costs
Depreciable Capital
Working Capital
Subtotal
Interest on Debt
Total Capital Requirement

Equity Investment
Debt Principal
Interest on Debt
Total Financing







1


$170,000
$35,000
$25,000
$7,000
$15,000
$15,000
$20,000
$3,000
$290,000
$5,000
$295,000
$14,230
$309,230

$185,538
'$10i,462
$14,230
$309,230


Figure H-1. Input Information and Capital Investment

-------
REVENUE AND COST FA<

Operating Year Number
Escalation Factor

INCREASED REVENUES
Increased Production
Marketable By-products
Annual Revenue

OPERATING COST/SAW
Raw Materials
Disposal Costs
Maintenance Labor
Maintenance Supplies
Operating Labor
Operating Supplies
Supervision
Labor Burden
Plant Overhead
Home Office Overhead
Total Operating Costs
JTORS


1,000






4GS













1
1.050


$0
$8.400
$8.400


$15.750
$117.600
($4.830)
($2.415)
($14,884)
($4.465)
($5.914)
($7.176)
($6.407)
($5.126)
$82.133


2
1.103


$0
$8.824
$8.824


$16.545
$123,536
($5.074)
($2.537)
($15.635)
($4.691)
($6.213)
($7.538)
($6.731)
($5.384)
$86.278


3
1.158


$0
$9,264
$9,264


$17.370
$129.696
($5.327)
($2,663)
($16,415)
($4.925)
($6.523)
($7.914)
($7,066)
($5.653)
$90.580


4
1.216


$0
$9,728
$9,728


$18,240
$136.192
($5.594)
($2.797)
($17,237)
($5,171)
($6.849)
($8,310)
($7.420)
($5.936)
$95,118


5
1.277


$0
$10.216
$10.216


$19.155
$143,024
($5.874)
($2.937)
($18.101)
($5.430)
($7,193)
($8,727)
($7,792)
($6.234)
$99.891


6
1.341


$0
$10^728
$10,728


$20,115
$150,192
($6,169)
($3.084)
($19,009)
($5.703)
($7.553)
($9.165)
($8,183)
($6.546)
$104,895


7
1.408


$0
$11.264
$11.264


$21.120
$157,696
($6,477)
($3,238)
($19,958)
($5.987)
($7.931)
($9.622)
($8,592}
($6,873)
$110,138


8
1.478


$0
$11.824
$11,824


$22,170
$165,536
($6.799)
($3,399)
($20.951)
($6.285)
($8.325)
($10,101)
($9,019)
($7215)
$115,612
Figure H-2. Revenues and Operating Costs

-------
RETURN ON EQUITY/RET

Construction Year
Operating Year

Book Value
Depreciation (by straight-!
Depreciation (by doubleDI
Depreciation

Debt Balance
Interest Payment
Principal Repayment

CASHFLOWS

Construction Year
Operating Year

Revenues
+ Operating Savings
Net Revenues
- Depreciation
- Interest on Debt
Taxable Income
- Income Tax
Profit after Tax
+ Depreciation
- Debt Repayment
After-Tax Cash Row

Cash Flow for ROE
Net Present Value
Return on Equity
26.47%
URN ON ASSETS

1


$290,000
ne)
!)


$123,692





1














($185,538)
($185,538)




1

$207.143
$41,429
$82,857
$82,857

$123.692
$16.080
$24,738




1

$8,400
$82,133
$90.533
$82.857
$16,080
($8,404)
($2,857)
($5,547)
$82.857
$24,738
$52,572

$52,572
($139,823)
#NUM!




2

$147,959
$41,429
$59,184
$59.184

$98.954
$12.864
$24,738




2

$8,824
$86,278
$95,102
$59,184
$12,864
$23,054
$7,838
$15,216
$59,184
$24.738
$49.662

$49,662
($102,272)
-32.19%




3

$105,685
$41,429
$42.274
$42.274

$74,216
$9,648
$24,738




3

$9,264
$90,580
$99,844
$42.274
$9.648
$47,922
$16,293
$31.629
$42.274
$24.738
$49,165

$49,165
($69,945)
-9.62%




4

$64,256
$41,429
$30,196
$41,429

$49,478
$6,432
$24,738




4

$9,728
$95,118
$104,846
$41.429
$6.432
$56,985
$19,375
$37,610
$41,429
$24,738
$54,301

$54,301
($38,898)
4.24%




5

$22,827
$41,429
$18,359
$41,429

$24.740
$3,216
$24,738




5

$10,216
$99,891
$110,107
$41,429
$3,216
$65,462
$22,257
$43,205
$41,429
$24,738
$59,896

$59,896
($9,119)
12.95%




6

$0
$41,429
$6,522
$22,827

$2
$0
$2




6

$10,728
$104,895
$115,623
$22,827
$0
$92,796
$31.551
$61.245
$22,827
$2
$84,070

$84,070
$27,227
19.92%




7

$0
$0
$0
$0

$0
$0
$0




7

$11,264
$110,138
$121,402
$0
$0
$121,402
$41,277
$80,125
$0
$0
$80.125

$80,125
$57.349
23.85%




8

$0
$0
$0
$0

$0
$0
$0




8

$11,824
$115,612
$127J436
$0
$0
$127,436
$43,328
$84,108
$0
$0
$84,108

$84,108
$84,844
26.47%

Figure H-3. Cash Rows for Return on Equity

-------
HE lum ON MVBS1MEN

Construction Year
Operating Year

Book Value
Depreciation (by straight-)
Depreciation (by double C
Depreciation

CASHFLOWS

Construction Year
Operating Year

Revenues
+ Operating Savings
Net Revenues
- Depreciation
Taxable Income
- Income Tax
Profit after Tax
+ Depreciation
After-Tax Cash Flow

Cash Flow for ROI
Net Present Value
Return on Investment
23.09%


1


$290,000
ne)
B)




1












($295.000)
($295,000)





1

$207,143
$41.429
$82.857
$82.857




1

$8,400
$82.133
$90,533
$82,857
$7.676
$2.610
$5,066
$82.857
$87,923

$87,923
($218.545)
#NUMI




2

$147.959
$41,429
$59.184
$59.184




2

$8,824
$86,278
$95.102
$59.184
$35.918
$12.212
$23.706
$59.184
$82.890

$82.890
($155.868)
-30.04%




3

$105.685
$41,429
$42,274
$42.274




3

$9.264
$90,580
$99,844
$42,274
$57,570
$19.574
$37.996
$42,274
$80,270

$80,270
($103.090)
-7.76%




4

$64.256
$41.429
$30.196
$41.429




4

$9.728
$95.118
$104,846
$41,429
$63,417
$21.562
$41.855
$41.429
$83.284

$83,284
($55.472)
5.26%




5

$22.827
$41.429
$18,359
$41.429




5

$10.216
$99.891
$110.107
$41,429
$68,678
$23.351
$45.327
$41.429
$86.756

$86,756
($12.339)
13.21%




6

$0
$41,429
$6,522
$22.827




6

$10.728
$104.895
$115,623
$22.827
$92.796
$31,551
$61.245
$22.827
$84.072

$84.072
$24,008
17.99%




7

$0
$0
$0
$0




7

$11,264
$110,138
$121.402
$0
$121,402
$41,277
$80.125
$0
$80.125

$80.125
$54.130
20.97%




8

$0
$0
$0
$0




8

$11.824
$115.612
$127,436
$0
$127.436
$43,328
$84.108
$0
$84.108

$84.108
$81.625
23.09%

Figure H-4. Cash Flows for Return on Investment

-------
Please Note:
This is the first page of this Sample P2 Plan.
     APPENDIX  C


LEVEL I  EXAMPLE PPOA

-------
 PROCESS DEFINITION

 SNL/NM Oroanization:  7813-5
                                            Page _J	of  2

              Process Name: Asbestos  Brakes  &  Clutch Removal
   DATA FORM
          DESCRIPTION OF
     PROCESS/OPERATIONS
               Area I,II,III,IV,V & Remote Area
 Process Location SNL-Albuguerque NM/SNL-Livermore CA./TTR-Las Vaeas NV./KTF-Kauat
 (include site, TA, building, room, as appropriate)

 Describe the general operations or activities of the organization performing the process. Continue on
 the back of this sheet, if necessary.

 The Crane and Hoist  section  is responsible for performing annual

 Repairs, and Preventative Maintenance on Cranes and Hoists.
Describe the particular process that generates wastes and/or other pollutants, or uses hazardous
materials.  Describe how the hazardous materials are used, and how the wastes or pollutants are
generated.  (See Chapter 2 of the PWA Guidance Manual for guidelines on defining a process.)
Continue on the back of this sheet, if necessary.

Asbestos Brakes and  Clutches are generated  waste In this process.

Asbestos Brakes and  Clutches becomes a  generated waste when the Asbestos

and Clutches areremoved and replaced with  Non-Asbestos Brakes  and Clutches,
Date: 7/22/93
PWA#:
Prepared by (MinNet Rep): Bernard. Alexander  Phone:  4-1365
Process Contact: Bernard Alexander         Phone:  4-1361
(to be completed fay WMSC)

-------
PROCESS D


SNUNM Organization:  7B13-5
                                                                                                                                                                                   Pane _|  ol
                                      Process Name:  Asbestos  Brakes & Clutch  Removal
    DATA FORM
                                        PROCESS
                                  FLOW  DIAGRAM
                                                                                                                        Re»ote Areas

                                                                                                        Process location: SHL-Atsuqaerque
                                                                                                                                                               ,
                                                                                                                                                             CA*
  StaHO. . flow |Seal rfoves shall be s"!f'fifi*itftl*f:!F3(.^,
                                                                                                       If •vlGeneciile KAF8 Form 483 Asbestos Containing Materials WasJel
                                                                                                         
-------
 PROCESS DEFINITION

 SNL/NM Organization: 7813-5
                 Sheet 1 of 2                  Page	__ lm: of  2

              Process Name: Asbestos Brakes  and Clutches Removal
   DATA FORM
 CALENDAR YEAR 1992 WASTE
     MINIMIZATION ACTIVITIES
               Area  I,II,III,IV,V, & Remote Areas
 Process Location: SNL-Albuqgerque NM/SNL-Livermore CA./TTR-Las Vegas HV. /KTF-Kauai
 (include site, TA, building, room, as appropriate)

 Have waste minimization (WM) activities been undertaken in CY92? E Yes  O No

 If No, briefly discuss factors that have prevented waste minimization activities:	
 If Yes, short name of WM activity (e.g., Increase Input Purity, Improve Rinse Process) (use other sheets
 if more than one activity taken):  Removing and disposing of a hazardous material.	
Type of WM activity (check best one that applies):

Source Reduction
09 Good Operating Practice
D Inventory Control
O Spill and Leaks Prevention
D Raw Material Modification
D Production Modification
O Process Modification (Clean and Degreasing)
D Process Modification (Surface Prep and Finish)
D Process Modification (Other)
D Other (specify below)
                              Recycling
                              O Began Onsite Recycling
                              O Began Off site Recycling
                              O Reuse in Original Process
                              O Reuse in Another Process
                              Energy Recovery
                              O Began Onsite Energy Recovery
                              O Began Off site Energy Recovery
                              Treatment
                              O Began Onsite Treatment
                              D Began Offsite Treatment
Briefly describe WM activity: Removal  of  Asbestos Brakes  and Clutches  to  be  replace with

a non-asbestos material.	__^_^___	__^_
Prepared by (MinNet Rep):  Bernard Alexander  Phone: 4-1365
Process Contact: Bernard  Alexander           Phone: A-1365
      7/22/93
PWA#:	
(to b« comploted by WMSC)

-------
 PROCESS DEFINITION

 SNL/NM. Organization:   7813-5
                  Sheet 2 of 2                   Page  2   of  2

               Process Name:  Asbestos Brakes  and Clutches Removal
    DATA FORM
    FISCAL YEAR 1992 WASTE
    MINIMIZATION ACTIVITIES
 Waste stream type affected:   D Hazardous (Chemical! Solid Waste
                            D Radioactive/Mixed Solid Waste
                                             O Waste Water Discharge
                                             O Air Emission
 Waste stream name affected (see corresponding Data Form 2): Asbestos  Brakes  and Clutches

 Did WM activity increase the toxicity of waste generated? D Yes  E No

 Did WM activity increase the quantity or toxicity of wastes emitted to other media (air, waste, land)?
 D Yes  0 No

 Did WM activity reduce toxicity but not quantity?  E Yes  D No

 Indicate the quantity impact of the WM activity (use most appropriate measure):
Mass before WM activity (kg/yrj:	
Volume before WM activity (4/yr):	
Specific activity before WM activity (Ci/kg/yr):
                         Mass after WM activity (kg/yrj:	
                         Volume after WM activity (l/yr|:	
                         Specific activity after WM activity (Ci/kg/yr}:
Basis of quantities (e.g., direct measurement, material balance calculation, published emission factors,
engineering calculations, engineering/scientific judgment):	
Has the WM activity been successful?  d Yes  D No
Is the activity still being used? Q Yes   O No

If unsuccessful or otherwise not being used, describe why:
Date:  7/22/93
PWA #:
Prepared by (MinNet Rep): Bernard Alexander  Phone:   4-1365
Process Contact:  Bernard Alexander          Phone:   4-1365
(to b« completed by WMSCI

-------
 PROCESS CHARACTERIZATION                              Page  i . of  1

 SNUNM Organization:  7813-5	Process Name:  Asbestos Brakes and Clutches
   DATA FCnM
  HAZARDOUS/RADIOACTIVE
        MATERIAL INPUTS
Nam* of Hazardous/Radioactive Material
Asbestos
Glove Bag
Tvvek Suits .Rags, Drip Cloth



















input Stream
Number
1
2
9



















Predicted
Frequency of
Usage"1






















Average
Annual Usage
Rate 
-------
 PROCESS CHARACTERIZATION             Sheet 1 of 3            Page   1   of

 SNUNM Organization:  7813-5	Process Name: Asbestos  Brakes and Clutches
   DATA FORM
    HAZARDOUS (CHEMICAL)
             SOLID WASTE
 Waste Stream Number (from Worksheet 1):  1,2,9.10
 Waste Stream Name (from Data Form 2/Worksheet 1):  Asbestos,tyvk  suits,rags .drip cloth,  plastic
 Location of waste generation (TA, building, room): SNL-Alb/SNL-CA/TTR-NV/KTF-Kauai	   bag
 Inside RMMA?  D Yes  ® No
 Briefly describe how waste is generated:  Asbestos  Brakes and Clutches are removed and  replaced
 with non-asbestos  material.  Glove bages.tyvek suits rags,  and drip cloth are  used in th
 removal process to remove  the  generated waste.	
 Frequency of waste generation:
           O Continuously
           d Monthly
D Daily
O Quarterly
D Weekly
O Annually
Which description fits the process step that generates the waste (check best one):
  IE A regularly scheduled process step that is likely to be repeated several times during the upcoming year.
  O A one-time activity that is not likely to be repeated during the upcoming year.

Predicted average quantity of waste generated annually - normal operations (kg):   200 Ibs.
Predicted min/max quantity generated annually - normal operations (kg): Min	Max	
List (describe) all hazardous constituents (e.g., mercury inside switches, benzene-tainted glassware)
or brand names (e.g., WD-40) that could be in the waste:
  Asbestos	,	     	___^__
Do the hazardous constituents of the waste stream listed above vary (e.g., sometimes contains lead,
sometimes contains lead and cadmium)?  D Yes  H No   if yes, describe how the waste varies:
Describe physical characteristics of wastes (e.g., aqueous solution, solid, sludge, oil, containerized
compressed gas - include % of solids or % moisture, If applicable):  Solid	
Date:   7/22/92
PWA#:	
{to b* completed by WMSCI
Prepared by (MinNet Rep): Bernard Alexander
Process Contact: Bernard Alexander	
            Phone:,
            Phone:
       4-1365
       4-1365

-------
PROCESS CHARACTERIZATION              Sheet 2 of 3            Page 2	of _

SNUNM Organization: 7813-5	Process Name:   Asbestos Brakes  and Clutches
   DATA FORM
                          HAZARDOUS  (CHEMICAL)
                                    SOLID  WASTE
The pH of the waste stream may range from   N/A    to   N/A     (answer if appropriate)
Is the waste ignitable? (see Guidance Manual for clarification!
Is the waste corrosive? (see Guidance Manual for clarification}
Is the waste reactive?  (see Guidance Manual for clarification)
D Yes
D Yes
D Yes
m NO
BNo
BNo
O Unknown
O Unknown
O Unknown
Does the waste stream contain any of the following toxic metals: Q Yes  H No  (check all that apply)
   D Arsenic         D Barium            O Cadmium           O Chromium
   O Lead           O Mercury           D Selenium           D Silver

Does  the  waste stream, contain  a  toxic volatile, semi-volatile,  or  pesticide  listed  in Table 3-2?
D Yes  S No    If yes, list:	
Does the waste stream contain any of the spent solvents listed in Table 3-3? O Yes  B No
If yes, list:  	
Does the waste stream contain, or is it generated from the production of, any of the following benzene
derivatives?  O Yes   0 No  (check all that apply)
   D trichlorophenol                              D tetrachlorobenzene
   O tetrachlorophenol                            Q pentachlorobenzene
   O pentachloropheno!                            D hexachlorobenzene
Is the waste any of the following? O Yes
   O waste water treatment sludge
   O petroleum refining waste
                                       E No  (check all that apply)
                                        O wood preserving process waste
                                        O leachate from treatment, storage, or disposal of waste

Does the waste contain cyanide or is cyanide used in the process?  O Yes   B No


Is the waste any of the following? O Yes  E No  (check all that apply)
O waste from the production of inorganic pigments
O waste from the production of inorganic chemicals
O waste from the production of organic chemicals
D waste from the production of explosives
D waste from the production of ink formulations
                                               D waste from the production of pesticides
                                               D waste from the production of metals
                                               O waste from the production of Pharmaceuticals
                                               D coking waste
                                               O petroleum refining waste
Date:  7/22/93
PWA #:	
(to be completed by WMSC)
                       Prepared by (MinNet Rep):Bernard Alexander
                       Process Contact: Bernard  Alexander
Phone: 4-1365
Phone:4-1365

-------
PROCESS CHARACTERIZATION               Sheet 3 of 3             Page   3  of

SNL/NM Organization:    7813—5	Process Name:  Asbestos  Brakesand  Clutches
   DATA FORM
    HAZARDOUS  (CHEMICAL)
              SOLID WASTE
Based on the above description of how the waste is generated, select the single best summary of the
waste-generating process step.
CLEANING AND DECREASING

D Stripping (A01)
D Acid cleaning ((A02)
O Caustic (Alkali) cleaning (A03)
D Flush rinsing (A04)
n Dip rinsing (A05)
D Spray rinsing (A06)
O Vapor degreesing (A07)
D Physical scraping and removal (A03I
O Clean out process equipment (AOSJ
O Other cleaning and degreasing (A19)

SURFACE PREPARATION AND FINISHING

D Painting (A21J
D Electroplating (A22)
D Electroless plating (A23)
O Phosphating (A24)
O Heat treating (A25)
D PieWing (A26I
D Etching (A271
D Other surface coating/preparation (A29)

PROCESSES OTHER THAN SURFACE PREPARATION

D Product rinsing (A31)
D Product filtering {A32»
O Product distillation (A33)
D Product solvent extraction (A34J
D By-product processing (ASS)
O Spent catalyst removal (A36)
O Spent process liquids removal (A38)
O Tank sludge removal (A38)
O Slag removal (A39)
O Metal forming (A40)
O Plastics forming (A41)

PRODUCTION OR SERVICE DERIVED ONE-TIME AND
INTERMITTENT PROCESSES

O Leak collection (ASK
O Cleanup of spill residues (A53)
D Oil changes (A54)
                            D Filter/battery replacement (ASS)
                            O Discontinue u*« of process equipment (ASS)
                            B Discarding off-spac material (A571
                            O Discarding out-of-date products or chemicals (ASS)
                            D Other production-derived on-time and  intermittent
                              processes (ASS)
                            D Sludge removal (A60)

                            REMEDIATION DERIVED WASTE

                            D Superfund Remedial Action (A61)
                            D Superfund Emergency Response (A62)
                            O RCRA Corrective Action at solid waste management
                              unit (A63)
                            D RCRA closure of hazardous waste management unit
                              (A64|
                            O Underground storage tank cleanup (A65)
                            O Other remediation (A69)

                            POLLUTION   CONTROL  OR  WASTE  TREATMENT
                            PROCESSES

                            O Filtering/screening (A71)
                            O Metals recovery (A72)
                            O Solvents recovery (A73)
                            D Incineration/thermal treatment (A74)
                            O Westeweter treatment (A75)
                            O Sludge dewetering (A76)
                            O Stabilization (A77)
                            O Air pollution control devices (A78)
                            O Leachate collection (A79)
                            O Other pollution control or waste treatment (ASS)

                           OTHER PROCESSES

                            S Clothing end personal protective equipment (A91)
                           S Routine cleanup wastes (e.g., floor sweepings) 
-------
Please Note:
This is the first page of this Sample P2 Plan.
       APPENDIX E


LEVEL II  EXAMPLE PPOA

-------
    [ PPOA-1 1                                     Original Issue Date: 8/31/91
    V	/                                          Revision Mn •
 Revision No.:
Revision Date:
      Pollution Prevention Opportunity Assessment

                           Team & Scope
          Assessment ID Code:                      Assessment Title:
     	SNL/CA MS001                     Machine and Fabrication Shop
    Name                           Job Classification        Phone
Alice Johnson- Duarte
Andy Cardiel
Charlie Schmitz
Kim Shepodd
WMin Coordinator
Shop Supervisor
Machinist
Waste Manager
4-3266
4-2544
4-2315
4-1475

    * Team Leader

      Assessment Scope:

    The Machining and Fabrication Shop is a support function whose principal
    purpose is machining parts requiring a quick turn-around, restriction of
    access due to classification, and/or close liaison with the designer and
    engineer. The shop maintains equipment suitable to perform turning,
    milling and grinding operations.  The major hazardous waste stream
    generated by this facility is the spent coolant used in the machining
    process.  The diluted Aqua-Syn  180 itself is a non-hazardous material per
    29CFR 1910.1200(c); however,  in the machining process it is mixed with
    small amounts of machine oil and metal shavings. The coolant is routinely
    changed after 3 to 4 months of service except as noted in the shop's
    operating procedures.
Potential for Pollution Prevention / Waste Minimization  or Recommendations:

    There are limited operational and administrative pollution prevention
    opportunities to reduce the spent coolant waste.

-------
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
              PROCESS FLOW DIAGRAM
PWA ASSESSMENT ID CODE: SNL/CA MS001
TITLE:  Machine and  Fabrication  Shop
      Unspecified Aqueous Solution
      CY91  Generated  11,000  pounds
   COOLANT
   SOLUTION

   Water, 20 Parts
   Aqua-Syn 180,
      1 Part
 Replaced
"only as "
 required
     Small Metalic Chips

     Thin Film Machine Oil
A total of
35 machines
including:
19 lathes,
9 mills,
5 grinders,
and 2 handsaws
use coolant.
                                  Waste
                                  Solution

                                  55 GAL
                               Sent to Off-site
                               Disposal

-------
   PPOA-2
                                                      Pago; 1 of
    Pollution Prevention Opportunity Assessment
               Material & Waste Stream  Summary
Assessment ID Code:  SNUG A MS001
 Title:   Machine and Fabrication Shop
Input
Material
Name/No.
Water
Aqua-Syn
Metafic chips
Machine oil





Annual
Quantity
Used
10400.0
520.0
65.0
15.0





%
Product









%
Recycled









Total Releases
%
Air
5
1







%
Liquid
95
99

100





%
Solid


100






         Totals/Page:    11000.0
   Total Annual Quantity    11000.0

  Does the process require further analysis
  based on the site's Priority Material/Waste
               Stream  List?
    ONo
[Level II DLevel II
                  9/16/93

-------
                                                                   Page _1_of J	

           Pollution Prevention Opportunity Assessment
                                Option Summary
          Assessment ID  Code:                      Title:
           SNL/CA MS001                             Machine and Fabrication Shop
Option Description
      One consideration for an operational improvement would be to recycle the spent coolant. According to industrial
      sources, a reduction of approximately 50% in the present amount of coolant disposed of.
Type
Recycling
Consider?
• Yes ONo
Feasibility
Fair
Estimated
Cost
$25,000.00
Estimated
Savings
$100.00
Anticipated
Reduction Qty
5,000.00
Qpilan Description
 &°-*  Analyze the spent coolant solution for contaiminants and determine if it is indeed hazardous.
  2
Type
Disposal
Consider?
OYes 9No
Feasibility
Poor
Estimated
Cost
$5,000.00
Estimated
Savings
$100.00
Anticipated
Reduction Qty
1,0000

-------
                                                                      Date
                                                                     8/31/91
       Pollution Prevention Opportunity Assessment


                             Final Summary

Assessment  ID  CodeSNUCA MS001
               Title: Machine and Fabrication Shop
 Assessment:
 A Level I and Level II PWA were completed on the Machining and Fabrication Shop
 coolant waste stream.  The machinist responsible for the operational maintenance of
 the machine shop equipment had limited suggestions for reducing the amount of
 spent coolant generated. Recycling and treatment options were generated and
 evaluated.  Assumptions made during this assessment were: the level of activity of the
 machine shop is relatively stable; the coolant must be changed on a periodic basis
 which is dependent on  use and/or time and; disposal costs are relatively stable.
Conclusions:
 The PWA team concluded the options are not economically feasible at this time since:
 1) option one would require a considerable investment with the possibility of
 increasing the actual amount of coolant waste caused by contamination; 2) the
 recycling equipment presently available is not designed to treat the small quantity of
 spent coolant generated; 3) a conservative approach regarding waste management is
 consistent with the site's policy.
Recommendations:
 The Line Management will continue monitoring the amount of waste generated and
 the availability of recycling equipment for improvement in the economical feasibility of
 implementation.

-------
\Tb\s \s the first page of this Sample P2 Plan.
         APPENDIX  F

  LEVEL III EXAMPLE PPOA

-------
   Worksheet 1
       Level ill
                                              Original Issue Date;
                                              Revision No.:
                                              Revision Date:
                              OI-Dae-1993
      Pollution Prevention Opportunity Assessment
                             PPOA Team
PPOA Title:  Polyurethane Foam Mixing and Curing
PPOA ID Code(s): G517-034-Machine_Mix
Name
"Team Leader
Additional Resources
      Job Classification
 Phone
*Bill Harrison
John Taylor
Albert Green
Mary White
Violet Jones
Process Engineer
Area Supervisor
Foam Machine Operator
Foam Machine Operator
Area Production Planner
X1234
X1235
X1235
X1235
X1236


     Name
 Phone
PPOA Coordinator
Waste Management
Industrial Hygiene
Environmental Protection
Safety
Fire Protection
Process Engineering
Materials Engineering
Utilities Engineering
Facilities Engineering
Maintenance (Equipment)
Analytical Lab Testing
Scheduling
Purchasing
Nancy Notrebmep
Hakim Senoj
Tim Sregge
Dottie Muldune
X5432
X5433
X5434
X5431
                                                                11/93

-------
  Worksheet 2
      Level 111
                                                 Revision No.:
                                                 Revision Date:
      Pollution Prevention Opportunity Assessment

                          Process Description

PPOA Title:    Polyurethane Foam Mixing and Curing	

PPOA ID Code(s):    G517-034-Machine_Mix	

Process Location:     Main Building #105, Post FN33	

Process Description:	

The foam mixing process is a process in which the required material	
components are metered and mixed at a defined ratio. The ratio of the two	
component streams is set and calibrated by production personnel. The	
materials are then mixed during the dispense cycle by the action of a motorized
impeller. The mixed material "foam" is transferred manually to a mold and cured
at temperatures from 165 to 350 deg. F. for four to six hours. Input materials
include polyol resins, isocyanates, cleaning solvent and processing supplies.
Five foam dispensing units are used. They range in age from four to fifteen	
years. The cure ovens are ventilated as is the foam pouring area.  The foam	
machine operators have sufficient training to operate the dispensing units.	
Their previous training did not emphasize pollution prevention.	
Waste streams include solid and liquid waste from the foaming operations as
well as air emissions from the foam pouring and curing activities.	
Description of Major Product(s) of Process:
Molded Polyurethane Foam Products
                                                                 11/93

-------

   Level 111
                                                     Revision No.: 0
                                                     Revision Data:
          Pollution Prevention Opportunity Assessment
                        Process Flow Diagram
PPOA Title or PPOA ID Code(s):
G517-034-Machine Mix
Inputs:
Isocyanate Comp.
Resin Component
Solvent	
Supplies
                        Process:
                          Foam Mixing
                          and Curing
                   Outputs:
                          Product
                         Hazardous
                       Non-Hazardous
                           Other

(PR2)
(PR3)
Solid
Foam
Product
Liquid
Air
                      Solid
Purge
Waste
                             Calibration
                             Waste
                      Air
Isocyanate
Emissions

(NH2)
(NHS)
Solid
Scrap
Product
Liquid
Air
(Sri)
(cm)
(OT3)
Solid
Liquid
Air
                                                               11/93

-------

    Level
Time frame
Pollution Prevention Opportunity Assessment
              Material Balance Summary
     PPOA Title or PPOA ID Code(s): G517-034-Machlne_Mlx
Revision No.: 	
Revision Date;	
Page	1	of
muni, ui— uan — 9£
To: 31-Dec-92
Material
Description
Isocyanate
Resin
Solvent
Supplies
Foam







Totals/Subtotals
Total
Input
313.6
186.4
80.0
94.0
0.0







674.0

Total
Output
124.5
73.5
80.0
94.0
302.0







674.0
Stream
ID Code
Foam
Product
(S)




237.0







237.0
Stream
ID Code
Purge
Waste
@)
98.3
58.9
80.0
94.0








331.2
Stream
ID Code
Calibration
Waste
(HZ2)
24.4
14.6










39.0
Stream
ID Code
Isocyanate
Emissions
(HZS)
1.8











1.8
Stream
ID Code
Scrap
Product
(NHI)




65.0







65.0
Stream
ID Code
o













Stream
ID Code
O













Stream
ID Code
O













Stream
ID Code
O













                                                                                     11/93

-------
  Worksheet 5
     Level 111                                       Revision No.: _
                                                  Revision Date:
                                                  Page  1   of


       Pollution Prevention Opportunity Assessment


                           Material Cost

PPOA Title or PPOA ID Code(s);  G517-034-Machine_Mix
Material
Isocyanate Component
Resin Component
Solvent
Supplies (paper cups, etc.)









Stock Number
(if applicable)














Cost Per
Unit
$1.96/lb
$2.25/1 b
$0.27/1 b
$O.S7/lb









Total /
Subtotal
Annual Cost
$614.65
$419.40
$ 21.60
$ 53.60









$1109.25
Waste Disposal Cost:
Material / Waste Stream
Waste Liquid
Waste Solid
Scrap Product










Waste Stream
Category
Haz. Liquid
Haz, Solid
Non Haz. Solid











Cost Per
Unit
$4.60/lb
$2.97/lb
$0.69/lb










Total/
Subtotal
Annual Cost
$179.40
$983.66
$ 44.85










$1207.91
                                                              11/93

-------
Worksheet 6
  Level III
   Pollution Prevention Opportunity Assessment

                      Option Generation

PPOA Title or PPOA ID Code(s):    GS17-034-Machme-Mix	
                                                                 Revision No.:
                                                                 Revision Date:
        Practices &
        Procedures
              Material
              Substitution
New Product
&/or Process
                  Reduce calibration
                 Amount & duration.

      Reduce solvent
      purge time
       Increase operator
      ^awareness & training
          Redefine foam
          kit requirements
                              In-line calibration
                              system
                            Use submerged
                            pumps
                                Equipment
                                Modification
                                                                                      Pollution
                                                                                      Prevention
                                                                                      Options
                                                                                           11/93

-------
   Worksheet 7
     Level III                                                   Revision No.: 	0_
                                                               Revision Date:	
                                                               Page   1 of 2
         Pollution Prevention Opportunity Assessment

                              Option Description

 PPOA Title  or PPOA ID Code(s):  G517-034-Machine_Mix	

 Option Name and Description
 (Include input materials, products affected, and anticipated reduction quantity.)

 Option No.   1   :   Calibration Reduction. Reduce the amount and duration of the
 calibration shots for the foam dispensers. Use new analytical methods "nitrogen
 testing" to justify the reduced level.	
	Consider; Yes X No_
 Practices & Procedures    X        Waste Segregation/Hazard Reduction 	
 Material Substitution 	                 Equipment Modification 	
 New Product &/or Process	         Recycling, Reuse, & Reclamation 	
 Option No.  2   :    Increase Awareness and Training.  Conduct training session to
 increase pollution prevention awareness. Instruct in the importance of the individual
 in the waste generation process.	
	Consider:  Yes X No_
 Practices & Procedures    X        Waste Segregation/Hazard Reduction 	
 Material Substitution 	                 Equipment Modification 	
 New Product &/or Process	         Recycling, Reuse, & Reclamation 	
 Option No.   3   :    Use Submerged Pumps.  Replace gear pumps on foam	
 machines with in-tank pumps.  Leakage will be into material tanks. This will eliminate
 material waste and exposure as the result of clean-up	
	Consider:  Yes X No	
 Practices & Procedures	     Waste Segregation/Hazard Reduction 	
 Material Substitution  	                 Equipment Modification 	
 New Product &/or Process   X          Recycling, Reuse, & Reclamation 	

 Option No.   4   :    In-Line Calibration System. Purchase new foam equipment
 with "in-line" calibration capability. This would replace the open cup method and
 would reduce the liquid and solid waste streams	
	 Consider:  Yes X No	
 Practices & Procedures	     Waste Segregation/Hazard Reduction 	
 Material Substitution  	                Equipment Modification    X
 New Product &/or Process	         Recycling, Reuse, & Reclamation 	

-------
   Worksheet 7
     Level III                                                    Revision No.:
                                                              Revision Date:
                                                              Page 2 of 2
         Pollution Prevention Opportunity Assessment

                              Option Description

 PPOA Title  or PPOA ID Code(s):  G517-034-Machine_Mix	

 Option Name and Description
 (Include Input materials, products affected, and anticipated reduction quantity,)

 Option No.   5   :   Substitute for TDI. Lessen the toxicity of the waste stream by
 replacing TDI isocyanate with a PMDI based foam system. PMDI is not a carcinogen
 and is not a RCRC Hazardous waste.	
	Consider:  Yes X No_
 Practices & Procedures	    Waste Segregation/Hazard Reduction	
 Material Substitution     X                     Equipment Modification 	
 New Product &/or Process	         Recycling, Reuse, & Reclamation 	
 Option No.   6   :   Reuse Calibration Material.  Retain spent calibration material
 for use on low end product requirements. This could include machine tryout parts,
 or foam billets used as base material for holding fixtures.	
	Consider; Yes X No_
 Practices & Procedures	     Waste Segregation/Hazard Reduction 	
 Material Substitution 	                 Equipment Modification 	
 New Product &/or Process	        Recycling, Reuse, & Reclamation   X

 Option No.   7   :    Reduce Solvent Purge Time.  Reset the solvent timers on the
 foam machine to the absolute minimum to flush the mix head. Subsequent soaking
 of mixer blade and housing can also reduce the required amount.	
	Consider; Yes X No_
 Practices & Procedures    X        Waste Segregation/Hazard Reduction 	
 Material Substitution 	                 Equipment Modification 	
 New Product &/or Process	        Recycling, Reuse, & Reclamation 	
 Option No.   8   :    Redefine Foam Kit Requirements. Set-up separate material
 numbers for resin and isocyanate components so ratio/usage of material will be
 balanced. Current "matched set" distribution result in waste of excess component.
	Consider: Yes X No_
 Practices & Procedures    X        Waste Segregation/Hazard Reduction 	
 Material Substitution 	                 Equipment Modification 	
 New Product &/or Process	        Recycling, Reuse, & Reclamation 	

-------
  Worksheet 8
     Level
Revision No.: 	0
Revision Date: _
Page  1  of	2_
       Pollution Prevention Opportunity Assessment

                      Options Cost Evaluation

PPOA Title or PPOA ID Code(s):  G517-034-Machine_Mix

Option No.:
1
Option No.:
2
Option No.:
3
Option No.:
4
Option No.:
5
Implementation Costs
Purchased Equipment
Installation
Materials
Utility Connections
Engineering
Development
Start up / Training
Administrative
Other

Total Implementation
Cost




$250

$100
$50


$400




$100

$100
$50


$250
$500
$100


$150

$150



$900
$75,000
$10,000

$2000
$3000

$5000



$95,000




$1000
$500




$1500
Incremental Operating Costs
Change in Raw
Materials
Change in Maintenance
Change in Labor
Change in Disposal
Other

Annual Operating
Savings/(Cost)
$215

$500
$50


$765
$100


$50


$150
Incremental Intang
Penalties and Fines
Future Liabilities
Other

Annual Intangible
Savings/(Cost)
Total Annual
Savings/(Cost)
Payback Period




$0
$765
0.5 yrs




$0
$150
1 .6 yrs
$150
($150)

$100


$100
$750

$500
$600


$1850
$500


$500


$1000
ible Costs




$0
$100
9.0 yrs




$0
$1850
51 yrs




$0
$1000
1.5 yrs
                                                              11/93

-------
  Worksheet 8
     Level III
Revision No.: 	0
Revision Date:
Page  2 of	2_
       Pollution Prevention Opportunity Assessment

                      Options Cost Evaluation

PPOA Title or PPOA ID Code(s):  G517-034-Machine_Mix

Option No.:
6
Option No.:
7
Option No.:
8
Option No.:
Option No.:

Purchased Equipment
Installation
Materials
Utility Connections
Engineering
Development
Start up / Training
Administrative
Other

Total Implementation
Cost




$200





$200




$150

$150



$300




$150


$150


$300
Incremental Operating Costs
Change in Raw
Materials
Change in Maintenance
Change in Labor
Change in Disposal
Other

Annual Operating
Savings/(Cost)



$180


$180
$15


$125


$140

Penalties and Fines
Future Liabilities
Other

Annual Intangible
Savings/(Cost)
Total Annual
Savings/(Cost)
Payback Period




$0
$180
1.1 yrs




$0
$140
2.1 yrs



$350


$350





































mm>mfmmmmm:mmmmm] ; • •.




$0
$350
0.9 yrs














                                                              11/93

-------
  Worksheet 9
   Level ill
Revision No.:
Revision Date:
Page   1  of
                     Pollution Prevention Opportunity Assessment
                               Weighted Sums Option Evaluation
PPOA Title or PPOA ID Code(s):   G517-034-Machine_Mix
Criteria
Public Health, Safety, &
Environment
Employee Health & Safety
Regulatory Compliance
Economic
Implementation Period
Improved Operation /
Product
Other
Subtotal
Likelihood of Technical
Success (Multiplier)
Likelihood of Useful
Results (Multiplier)
Total
Rank
Weight
W
10
10
8
6
4
2

iiiiiiiiiitill



liiiiiiiiiiilif
:-;•:•:•:--•.-:-.• :-:-;-:-:•:-;•:•;•;•:•:•:•:•:•:•:•:•:•:•:
;:;>:-[[[
:^S:?:^:^:^'^SS$!::™'. *:: :•
Option N
Scale
'S1
8
8
7
8
7
5

sssssiisspsss?
X
X
:%::?S:^S;:^^SS::^::::
;;x:x:£:;:x:;:;:;:;:;:|:;:;:;:£:j:;:;:;:
o.: 1
'WxS'
80
80
56
48
28
10

302
0.8
0.9
217
7
Option N
Scale
'S'
6
7
7
9
9
8


X
X


o.: 2
'WxS1
60
70
SB
54
36
16

292
1.0
0.9
262
4
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70
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-------
  IliiiiiBiiiaig^iiiiiiilllKliflaiSllaahi':
    Level III
                      Pollution Prevention Opportunity Assessment
                                 Weighted Sums Option Evaluation
Revision No.:
Revision Date:
Page   2  of
PPOA Title or PPOA ID Code(s):   G517-034-Machine  Mix
Criteria
Public Health, Safety, &
Environment
Employee Health & Safety
Regulatory Compliance
Economic
Implementation Period
Improved Operation /
Product
Other
Subtotal
Likelihood of Technical
Success (Multiplier)
Likelihood of Useful
Results (Multiplier)
Total
Rank
Weight
W
10
10
8
6
4
2


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111 \
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Option No.: _6 	
Scale
'S1 'WxS'
6
7
6
7
7
7

1
1
X
X


60
70
48
42
28
14

262
0.9
0.9
212
6
Option No.: 7
Scale
'S1 'WxS'
8
8
7
9
9
6


X
X
5i5:sg;S¥gft;: SSs : f
1111111$ 1 |l M
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80
80
56
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286
2
Option No.: _8 	
Scale
'S' 'WxS'
6
7
7
8
8
9


X
X


60
70
56
48
32
18

284
1.0
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284
3
Option No.: 	
Scale
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X
X














Option No.: 	
Scale
'S1 'WxS'








X
X














                                                                                            11/93

-------
  Worksheet 10
     Level HI
                                                              Revision No,:   0
                                                              Revision Date:	
                                                                     1 of  1


         Pollution Prevention Opportunity Assessment

                           Final Report Check Sheet

PPOA Title or PPOA ID Code(s):  G517-034-Machine_Mix	


      Requirement                                         Completed

Title Page                                                    X
      PPOA Title
      PPOA ID Code(s)
      Team members
      Issue date/revision date/revision no.
Executive Summary                                           X
      Process description
      Process assessment
      Option summary and analysis
      Conclusions
      Recommendations
Introduction                                                   X
      Background of evaluation
Process Description                                           X
      Associated equipment
      Process flow diagram
Process Assessment                                          X
      Methodology
      Material Balance
      Unusual occurrences
Option Summary and Analysis                                  X
      Option description and rank
      Upstream/Downstream impacts
      Material usage
      Anticipated reduction
      Estimated costs
      Estimated benefits
      Feasibility
      Waste streams affected
Conclusion                                                   X
      Concluding evaluation
      Option analysis decisions
      Concerns
      Options already implemented
      Lessons learned
Recommendations                                             X
      Future work
      New equipment
      Implementation strategies
Worksheets                                                   X
      1-10

                                                                             11/93

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                              Green Zia Environmental Excellence Program
                              New Mexico Environment Department
                              Office of the Secretary
                              PO Box 26110
                              Santa Fe, NM 87502
                              505-827-0677
                              pat_gallagher@nmenv. state, nm. us
Green Zia Environmental
Excellence Program
Auto Repair Shops
Guidance for improved environmental
performance and pollution prevention in
your auto repair business

-------

-------
        Acknowledgements

The material in this workbook is based on the Systems Approach to
Pollution Prevention, developed by Dr. Robert Pojasek of Pojasek and
Associates, and the Nothing to Waste Manual developed by US
Environmental Protection Agency Region 1.  Process maps were developed
by Ms. Alicia Hale of Los Alamos National Laboratory.

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

-------
Table of Contents





Introduction to Green Zia Program	Page 1



Green Zia Tools for Auto Repair Shops	Page 5



Process Maps for Auto Repair Shops	Tab 1



Auto Repair Shop Regulatory Guidance, Pollution Prevention Ideas



and Other Resources	Tab 2

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This page left blank intentionally.

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         The Green Zia
         Environmental Excellence
         Program

Guidance materials for auto repair shops
Introduction
This packet contains information on how to establish a pollution prevention program
specifically for an auto repair shop. The packet also contains waste management and
regulatory guidance materials to help you assure that you are in compliance with
environmental, health and safety regulations. Used together, this program can help you
establish a  pollution prevention program that will help you meet compliance and reduce
waste. Use of the tools from start to finish helps you qualify for the Green Zia
Environmental Excellence Program!

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

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

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

It is important to remember that environmental health and safety regulations are triggered
by the use of equipment and chemicals. Better use of chemicals, use of safer chemicals
and efficient operation of machinery can help reduce your regulatory burden.. .if you
aren't using hazardous materials, then you have fewer regulations to be concerned with!

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This program is based on first understanding work process and materials use and then
improving work practices to reduce cost, waste and regulatory concerns.

Working through the Green Zia Environmental Excellence Program will result in a
system that helps address environmental issues in cost effective ways, based on sound
business practices.  The system provides a framework for continuous improvement over
time and contributes to a thorough understanding of environmental issues in your
business.
What is Pollution Prevention?
Simply put, pollution prevention means not creating a waste in the first place.  Pollution
prevention is achieved by the efficient use of resources, including raw materials, energy,
water and even time and distance. The goal is to produce a product or deliver a service as
efficiently as possible, with the least amount of wasted materials and the least possible
environmental impact.

The bottom line is that pollution prevention or improved efficiency can help businesses
save money and help protect the environment at the same time.
What is Environmental Excellence?
Environmental excellence means moving beyond compliance with environmental, health
and safety regulations by establishing an environmental management system that
incorporates pollution prevention into core business practices.

A prevention-based environmental management system will:

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

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

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

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

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

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

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

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

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

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-------
         Tool#l:  Process
         Mapping
         To begin incorporating pollution prevention into your business,
         you must first get a full understanding of where wastes are being
         generated.  This  tutorial will discuss  the advantages of using
         process maps to logically evaluate each step of your process.
Warm-up Exercise
                                        Maps have been used throughout  the
                                        ages for many purposes  from helping
                                        sailors navigate the seas to providing a
                                        safe route for climbers hiking  to  the
                                        tallest peaks. You have probably drawn
                                        maps to your home or office so that
                                        someone could visit. It is important that
                                        the information on this map is complete
                                        and accurate or, as you may have found,
                                        your guest will get lost!

         Take a minute now and think of a coffee shop or restaurant nearby that everyone in the
         group knows. Draw a map from the building you are  currently m to this establishment -
         include traffic lights, landmarks, and any other important features along the way. Now
         compare maps with the other members of your group. Are they the same? If a person
         not familiar with the area were to use your map, would they have found their way?

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

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

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

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

A series of process maps have been developed for auto repair operations and are included
in this packet in Section 3. You should customize these maps for your operation, since
no two businesses are exactly alike.  These maps become a reference for you to use for
your pollution prevention program and can be updated to reflect changes as you improve
your operations.  These maps are also great for training new employees and other
problem solving needs.

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

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

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Example of a process map for General Auto Repair:
4. General Auto Repair
Paper on Plastic on
Flo









—*



or Mats Seats
Rags
„ I „
4.1
Prep Vechicle
& Assess Problem
|
Rags



4.4





Clean Up
Solvent D Materials
Kags
. 1 .
4.2
_fc^

| |
°irty T Dirty 1
S°'VentWaste Rags Clean Up
Materials
Fluids


4.5
. Check
Repair





Solvent Rags
|
4.3


|
1

ePart

^^
r
Dirty Dirty
Solvent Rags
Water Rags
Energy
V 1 V
4.6
Soap
1

. Prepare to Return
to Customer
! 1
Dirty Dlrty
Water t R^s


1
Spent
* Soap
Paper on p|astic
Floor Mats on seats
     Please review the process maps in Section 3. in the back of this booklet and make
     changes to reflect your operation.
         Once you have reviewed and revised the process maps to your
         operation, move to the next section...Activity-Based Costing!

-------

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Tool #2: Activity-Based
Costing
Every waste or  environmental loss costs you money. By determining the
activities that cause waste, you can focus your pollution prevention efforts to
minimize the cost to your business and protect the environment. This tutorial
will introduce you to a method of evaluating your waste.


Warm-up Exercise
Your daughter approaches you one evening and says that she is planning to buy a car.
                           With  the $400 she has left over each month, after
                           paying all of her bills, she is sure she will be able to
                           afford the $220 monthly car payment.
                           What are the other costs of operating and maintaining
                           a car that she is forgetting? Consider not only the
annual costs, such as insurance, but also the intermittent (once in a while) costs. Can she
really afford this car?

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

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


New Terms

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

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

Intermittent operations - Operations that occur once in a while.

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

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

       Regular activities:
       •   Tire replacement
       •   Radiator flush and drain
       •   Air conditioning repair
       •   General auto repair
       •   Changing brakes
       •   Oil changes

       Intermittent activities:
       •   Recycling antifreeze
       •   Parts cleaning
       •   Recycling solvents
       •   Waste oil management

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

3.  Reviewing your process maps, identify the operations in your shop that generate most
   of your waste or pollution problems. For example, does solvent use cause most of
   your environmental problems? Does the 80/20 Rule apply? Focus your efforts for
   now on the areas of your operations that you do the most or that create the biggest
   environmental problem for you.

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

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

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

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

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

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

10. Add the ledger costs and the hidden costs together to discover the true  costs!

11. Create a Pareto Chart.  Create a chart showing all these costs graphically.  On the x-
   axis, place costs in dollars, on the y axis (horizontal), show the true costs of the
   wastes. This chart will help graphically show how all the costs stack up against each
   other.  Does the 80/20 Rule apply here? Use this chart to identify the most expensive
   processes. This can be used to  identify the first area for improvement!  Which waste
   stream do you think you should focus on from this Pareto chart?

-------
Activity-Based Costing Example
    Paper on       Plastic on
    Floor Mats        Seats
            Rags


      ,     I     „
4. General Auto Repair

               Clean Up
   Solvent   D    Materials
          Rags
             4.1
         Prep Vechicle
        & Assess Problem
           T
            Rags

                                                           Solvent
                                                                    Rags
                                      4.2

                                Remove Defective Part
cD,irtyt *   Dirty
SolventWaste Rags Clean Up
             Materials
     Fluids
             4.4

         Replace Part
                                      4.5
                                     Check
                                     Repair
                                                            1       1
                                    4.3

                              Clean Repairable Part
                                Dirty
                               Solvent
                                                                    Dirty
                                                                    Rags
                                                         Water
                                                                  Rags
                                                              I   „   I
                                                                       Soap
                                    4.6
                                Prepare to Return
                                 to Customer

                                                         Dirty
                                                         Water
                                                                Ra9s
                                          Spent
                                          Soap
                                                          Paper on   p|astic
                                                          Floor Mats   on seats
Activities
                               Materials and Losses
    Tire Replacement
    Radiator Flush and Drain
    Air Conditioning Repair
    General Auto Repair
    Parts Cleaning
    Brake Change
    Oil Change
                                   Wheel Covers
                                   Lug Nuts
                                   Lead Weights
                                   Valve Stems
                                   Waste Water
                                   Antifreeze
                                   Lead Solder
                                   Hoses
                                   Clamps
                                   Air Emissions
                                   *Solvent Use
                                   Rags
                                   *Clean Up Material
                                   *Brake dust
                                   Metal shavings
                                   Energy
                                   Personal Protection Gear
                                   *Solvent Sludge
                                   *Fugitive vapors
                                   *Filters
                                   Oil Filters
                                   Oil
                               (*)  Indicates most important waste streams
                               and materials

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

Fugitive
Vapors




($1,240)
$1,240
4.8
Solvent
Sludge
$1,000

$2,500

($4,550)
$8,050
31.2
Brake Dust
$700

$500

($150)
$1,350
5.2
Solvent
Use

$5,000


($3,650)
$8,650
33.5
Filters
$800
$850


($2,000)
$3,650
14.2
Clean Up
Material
$600
$1,500
$100
$150
($500)
$2,850
11.1
Total
$3,100
$7,350
$3,100
$150
($12,090)
$25,790

Table 2. Hidden Cost Analysis (per year)
Fugitive Vapors
Activities/Cost
Factors
Monitoring
Reporting
Repairs
Materials
X ($200)
X
X
Space



Utilities



Services


X
Total hidden costs for vapors
Labor
X($1040)
X
X
($1,240)
Solvent sludge
Muck
out/disposal
Spill clean-up
Storage
Record
keeping
Generator fees
X
X
X
X
X

X
X










X

Total hidden costs for sludge's
X ($2,050)
X
X
X($ 1,000)
X ($1,500)
($4,550)
Brake Dust
Storage
X
X($150)


Total hidden costs for brake dust
X
($150)
Solvent Use
Record
keeping
Permit fees
Permit
Storage
Spill/clean-up
X
X

X
X



X




X



X ($3,000)

X
Total hidden costs for new solvent
X

X ($650)

X
($3,650)
Filters
Disposal
Repairs
X
X




X
X
Total hidden costs for filters
X (1,500)
X ($500)
($2,000)
Clean Up Materials
Handle/dispose
X



Total hidden costs for clean up materials
X ($500)
($500)

-------
Environmental Costs
5p1U,UUU
jo $8,000
to
8 $6,000
| $4,000
c
< $2,000

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

















































Total








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
































Total hidden costs for (waste stream)









Waste Stream
Monitoring
Reporting
Repairs
Muck
out/disposal
Spill clean-up
Storage
Record
keeping
Generator fees
































Total hidden costs for (waste stream)









Waste Stream
Monitoring
Reporting
Repairs
Muck
out/disposal
Spill clean-up
Storage
Record
keeping
Generator fees
































Total hidden costs for (waste stream)










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         Tool #3: Root Cause
         Analysis
Now that you have recognized the activities in your process that are costly
or expensive to your business, you can begin to focus your efforts on
pollution prevention. This tool presents a method of detecting the underlying
reason for an environmental loss so that the loss can be prevented.

Warm-up Exercise
  t:
MACHINES
broken alarm clock
Think of all of the times that you have been late for work and
list the different reasons for your delay. Maybe your alarm
clock did not go off, or perhaps your child was sick and you
needed to arrange for a sitter. Did you spend too much time
reading the newspaper or did you need to run to the store to
pick up milk.

Arrange all these reasons in the categories listed below, or
create an additional category. Some of the items on your list
may be entered more than once.

Now consider the last time you were late for work. Why were
you late? Circle the reason.

     PEOPLE
     sick child
METHODS
reading the newspaper
     MATERIALS
     out of milk

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Introduction


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

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

During this exercise you will:

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


Root Cause Analysis
After participating  in  process  mapping  and activity based  costing  exercises,  it was
determined that the largest loss, solvent use, accounts for approximately 80% of all
environmental costs in the auto repair business. The next step is to discover the root cause
of this loss.

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

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

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Since solvent use  is related to parts cleaning several things  may  come to mind. The
present  parts cleaning machine requires the use of a volatile solvent. The machine is
expensive and  requires  proper operation and maintenance.   Filters  must be changed
regularly and the distillation and recycling unit must be operating properly. By not using
used solvent to pre-clean parts inefficient solvent use may result.  Workplace conditions
such as  poor  lighting may lead to excessive solvent use to clean parts. Also the
availability  of solvents  can lead to them  being used to clean shop  floors as well as
employees hands. Training of employees and a good work attitude are critical to efficient
operations. All  of these  ideas should be entered under one of the four categories in the
fishbone diagram: Machines, Methods, Materials and People in the example in Figure 2.

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

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

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

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

  The solution is then to place a filter on the pump to capture metal chips.
Both tools can be used to find the root cause of the problem.  For most problems to be
permanently solved the root cause must be addressed. The fishbone diagram is a good
visual  tool  that helps you understand all  the  areas that contribute to a  problem.

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Understanding all the contributing factors will help facilitate problem solving.  The Five
Whys will also help you move past dealing with the symptoms of the problem to solving
the real problem.

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

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Figure 1: General Auto Repair Process - Process Map
4. General Auto Repair
Paper on Plastic on Clean Up
Floor Mats Seats Solvent Materials
Rags ounem Rggs
V T V V T V
4.1 4.2
Prep Vechicle Remove Defective Part
& Assess Problem ^ Remove Defective Part
! ! 1
Rags DirtV T Dirtv T
S°'VentWaste Rags Clean Up
Materials
Fluids



4.4 4.5
* RcDlaccPart to. Check
p. Kcpiaccrart p. Repajr




Solvent
|


Rags
I
4.3
.

1
Dirty
Solvent


Water
Energy
V 1
4.6
rable Part

^^
|
Dirty
Rags


Rags
Soap
„_!

^ Prepare to Return
^ to Customer
1 i
Dirty °lrt
Water v Ra£


I
y Spent
s ^r Soap
                                                            Paper on    Plastic
                                                           Floor Mats  on Seats

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Figure 2: Cause and Effect Diagram
               Methods
                                poor lighting
                                         spills
        Machines
                                                  requires volatile
                                                     solvent
 parts
cleaner
                                                     poor
                                                  maintenance
            no lid
                                                                            not efficient
                                                                               distillation unit
                                                                                      poor
                                                                                   maintenance
- filters

 type

type
,o»ent^. ^
mposition /
\
/ not used
dirty

bad
attitude
washing /



/ sufficient
Solvent
use

                               brushes
                                                    hands
         Materials
  People

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Figure 3: Dear Abby Letter
Dear Abby,

We run a small auto repair shop. Use of solvent is our most expensive business issue.
Solvents are highly regulated and we must comply with lots of regulations from air
quality to hazardous waste to health and safety.  Some auto repair shops have had to pay
lots of money for clean up of contaminated sites, which has put them out of business.
These are issues that we wish to take seriously.

Our group did root cause analysis and we believe that our biggest problem is our parts
cleaning equipment that requires the use of volatile solvents.  Employees affect solvent
use when cleaning parts from leaving the lid open to not pre-cleaning the parts. There is
also the issue of making sure we are in compliance with regulations. However, as you
know, changing equipment can be expensive and would probably require retraining of
our employees.

Can you help us?

Signed,

Fixing cars in Alamogordo

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

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Tool #4: Brainwriting
To  address  an opportunity  effectively, it is  important  to  recognize all
alternatives.  Very rarely is there one "right" way of preventing pollution.
Instead, there are many different potential solutions. This tutorial presents a
technique of listing many different alternatives for an opportunity.


Warm-up Exercise
                  You know the old adage "two heads are better than one". This is
                  especially true when trying to come up with new ideas. When you
                  generate ideas in a group you will notice that each member of the
                  group brings their unique set of experiences and strengths to the
                  table.
                  Try the following exercise with your group. Look at the picture
     cP            below (turn it on it's side and upside-down). What does it remind
                  you of? Write down all the images that come to mind-even images
that seem crazy should be included. Now go around the room, each person sharing one
image with the group. One person should volunteer to keep a list of all the images.
Repeat this step until every member of the group is out of images. How many images did
the group come up with? How does this compare with the number of images you
generated alone ?

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

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

During this exercise you will:

   •   Conduct a brainwriting session.
   •   Develop a list of all possible alternatives for an opportunity for improvement.
Brainwriting
First you have completed your process map to see how you can optimize your processes
and reduce losses, (see Figure 1) In the example provided, Activity-Based Costing helped
to identify that 80% of the environmental costs associated with auto repair was due to
solvent use. Not only are solvents expensive, they are considered a hazardous waste and a
hazardous air pollutant and they must be handled very  carefully. Spills must be avoided
to eliminate employee exposures and site contamination.

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

The next step is to develop as many alternatives to solve the problem as possible.  This is
done through the process of brainwriting.  Through brainwriting, staff works together to
generate  as many alternatives as possible regardless of how crazy they seem. In fact, to
make it more interesting  you can give a prize to the person  that comes up  with the
craziest idea.

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

Now list all the alternatives that were discovered.

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

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Figure 1: Auto Repair Process Map


Paper on Plastic on
Floor Mats Seats












~*


Rags
. I .
4.1
Prep Vechicle
& Assess Problem
!
Rags





4.4




4. General Auto Repair
Clean Up
Solvent Materials
Rags
„ I „
4.2


T^
J^t T Dirty i
S°'VentWaste Rags Clean Up
Materials
Fluids



4.5
^ Check
Repair








Solvent Rags
|
4.3


|
i

ePart

-*
r
Dirty Dirty
Solvent Rags


Water Rac
Energy
V 1 .
4.6


s
Soap
,


^ Prepare to Return
to Customer
1 !
Dirty Dlrty
Water v Ra9s


I
Spent
f Soap
Paper on Plastic
Floor Mats on Seats

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Figure 2: Sample of brainwriting
  1.
  Use non-toxic solvent to eliminate all
  environmental problems.
2.
Train people to maintain filtration
system and distillation systems better.
  3.
  Pre-clean parts with rags or brushes.
4.
Don't use solvent to clean shop floor.
  5.
  Convert to steam cleaning.
6.
Keep lid on parts cleaner closed when
not in use.
  7.
  Use old solvent to pre-soak dirty parts.
8.
Invest in better equipment.
  9.
  Place parts cleaner nearer to work
  areas.
10.
Test solvent to see if we are replacing
too soon.

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Figure 3: List of alternatives
1.  Use non-toxic solvent to eliminate all environmental problems.
2.  Train people to maintain filtration and distillation systems better.
3.  Pre-clean parts with rags or brushes
4.  Start a "clean shop" program to train employees to keep work areas clean to prevent
   spills and waste.
5.  Use old solvent to pre-soak parts
6.  Begin an employee incentive program to reward best operating practices for operating
   a clean work area.
7.  Replace existing parts cleaner with new equipment that uses non-solvent cleaning
   solution.
8.  Don't use solvent to clean shop floor.
9.  Pay employees small bonus for keeping good environmental records including
   hazardous waste and air quality records.
10. Test solvent to see if we are replacing too soon.
11. Create an employee problem-solving team to deal with waste of all kinds on a regular
   basis.
12. Convert to steam cleaning.
13. Train workers on pollution prevention and ways to reduce and reclaim spills.
14. Provide incentives for employees who reduce losses.
15. Invest in better equipment.
16. Keep lid on parts cleaner closed when not in use.
17. Place parts cleaner nearer to work areas.
18. Drain excess solvent from parts before removing from parts cleaner.

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Figure 4: Brainwriting Sheet
 1.                                     2.
 3.                                     4.
                                       6.
                                       8.
                                        10.

-------

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Tool #5: Bubble Up-Bubble
Down
You have now generated a list of alternatives for preventing an environmental loss
in your  business. But how  do you  choose the best alternative? This tutorial
presents one method  of prioritizing alternatives  to ensure  that the  most
appropriate alternative is selected.


Warm-up Exercise
                       Most of us use lists from time to time to make sure that we don't
                       forget to do the things that we need to get done. Without a shopping
                       list, for example, we may return from the store without milk, the
                       reason why we went in the first place.  Certain limitations, like time
                       or money, may cause us to drop things off our list. We often need
                       to prioritize and make sure that the most important things get done.
                      Make a list of the things that you need to get done tomorrow (try to
list at least ten things). List these items in the order that they come to mind. Now prioritize this
list by putting the most important items on the top of the list and the least important items on the
bottom. You should now have a "rank ordered" list. If you only have time to complete one of the
items on your list, which would it be? You should have answered the item on the top of the list
the most important item.

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

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

During this exercise you will:

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

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

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

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

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Figure 1: List of alternatives prioritized using Bubble-Up, Bubble-Down
   1.   Replace existing parts cleaner with new equipment that uses non-solvent cleaning
       solution.
   2.   Use non-toxic solvent to eliminate all environmental problems.
   3.   Pre-clean parts with rags or brushes
   4.   Use old solvent to pre-soak parts
   5.   Test solvent to see if we are replacing too soon.
   6.   Drain excess solvent from parts before removing from parts cleaner.
   7.   Keep lid on parts cleaner closed when not in use.
   8.   Place parts cleaner nearer to work areas.
   9.   Train people to maintain filtration and distillation systems better.
   10. Begin an employee incentive  program to reward best operating practices for operating a
       clean work area.
   11. Don't use solvent to clean shop floor.
   12. Pay employees small bonus for keeping good environmental records including
       hazardous waste and air quality records.
   13. Create an employee problem-solving team to deal with waste of all kinds on a regular
       basis.
   14. Convert to steam cleaning.
   15. Train workers on pollution prevention and ways to reduce and reclaim spills.
   16. Provide incentives for employees who reduce losses.
   17. Invest in better equipment.
   18. Start a "clean shop" program  to train employees to keep work areas clean to prevent
       spills and waste.

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Tool #6: Action Planning
Being able  to successfully  manage  a project  is  important  when trying  to
accomplish a task, especially when you are under a deadline. You need to set up a
schedule, ensure  that you have  the necessary resources,  and  assign the right
person to each part of the job. In this tutorial you will create an "action plan "for
the implementation of an alternative to prevent pollution.


Warm-up Exercise
                              Your group has been assigned the task of making chocolate
                              chip cookies. The cookies need to be ready in one hour and
                              the  cooking time is twelve minutes. Pick a person  to
                              manage this project. The manager must then assign the ten
                              tasks listed below to individuals in the group.

                              You will need to know how much time is required for each
                              task, what  tasks  need to be accomplished before others,
what resources (i.e.  bowls,  flour etc.) are required, and what the  most  efficient  way of
organizing these tasks (and remember the clock is ticking). Create a schedule.

Making chocolate-chip cookies:

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

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

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

Action Planning Questionnaire

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

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responsible for completing this task. A performance standard should then be  provided. This
standard is a way of establishing how well a task needs to be performed. Under "monitoring
technique" enter a measurable goal or target used to track the plan's implementation. A firm
deadline should then be set, and finally, indicate the resources that are needed to perform each
task. This form will help you organize your thoughts, keep track of all the actions that need to
be completed, and ensure that the proper quality is being maintained.
Use the form provided to track implementation of the project and to measure its success.
sample action planning form is included at the end of this section.
A
Overall Target: Employee Incentive Program
Action
1. Investigate
sources of
equipment
2. Bring in
equipment for
review
3. Employees
try out
equipment and
write up results
4. Have team
review results
and select
vendor
5. Purchase
equipment
6. Train
employees on
how to use
new equipment
Responsible
person
Tom
Tom
Harry
Harry
Dick
Harry
Performance
standard
List of vendors
Approved list of
vendors by Dick
How good does
the equipment
clean parts
Compare against
existing
equipment
Delivery schedule
Time and quality
of cleaning parts
Monitoring
technique
Discuss list with
Dick the owner
Dick allocates
time for
employees
Time to clean
parts
Time, quality
and cost
Dick allocates
funds
Costs of new
equipment
versus old
Completion
deadline
Jan 15
Feb 1
March 1
April 15
April 30
Junel
Resources
needed
Team of Tom,
Dick and Harry
Shop
employees
Shop
employees
Team of Tom,
Dick and Harry
Capital funds
Employees
time
Congratulations!!! You have completed the Pollution Prevention Training. Now it is time to put
these tools to work and remember pollution prevention is an ongoing process. If you continue to
implement  pollution prevention in  your business, you will increase the efficiency of your
process while helping the environment.  Simply revisiting your process maps and Pareto Chart
once a year and using the tools to continue to make improvements will make a big difference in
your operation.  Ongoing use  of these tools  will help you to participate in  the Green Zia
Environmental Excellence Program.

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Here are a few suggestions to make pollution prevention
continue to work for you:

• Return to the Nothing to Waste activities and concepts as
  you make business decisions.

• Schedule regular pollution prevention reviews of your
  business.

       Remember: Pollution Prevention saves resources,
       saves money,  and prevents accidents!

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










Performance
Standard










Monitoring
Technique










Completion
Deadline










Resources
Needed











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Process Maps for Auto
Repair Shops

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               General Process Map for Auto Repair
 Tire Replacement
                               Radiator Flush & Drain
                            Air Conditioning Repair
General Auto Repair
Brake Change
Oil Change

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                               1. Tire  Replacement
    Jack
                Energy
                            Pneumatic
                             Wrench     Energy
            1.1
          Raise
          Vehicle
          Energy
                                   1.2
                              Remove Wheels
                               from Vehicle
                                  Energy
                          Damaged      Lost Lug
                        Wheel Covers      Nuts
                                       Pneumatic
                                     Tire Remover
                  Energy
                                               1.3
                                           Remove Tires
                                           from Wheels
                                          Energy  T    Old
                                      Lead      Valve  Tire
                                     Weights     Stems
  Valve
  Stems
Pneumatic
   Tool
       Soapy
        Energy
                    Water
            1.4
       Put New Tires
        on Wheels
 Lead            Balancing
Weights          Machine
         Energy
                                   1.5
                                 Balance
                                Tire/Wheels
          Energy
 Damaged          Waste
Valve Stems         Water
 Pneumatic      wheel
  Wrench       Covers   Lug
        Energy        Nuts
                                               1.6
                                            Put Wheels
                                          Back on Vehicle
                           Energy
              Damaged
               Weights
  Damaged
Wheel Covers
                                                                      Energy
 Broken
Lug Nuts
            1.7
          Lower
          Vehicle

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Auto Repair Shop Process Maps

Map 1.0: Tire Replacement

1.1 Raise vehicle
   The vehicle is brought into the shop and raised up with either a floor jack or a vehicle lift.
This step uses energy if the jack/lift is not manually operated.

1.2 Remove wheels from vehicle
   Normally a pneumatic wrench is used to remove the lug nuts while a prybar is used to
remove the wheel covers. Energy is used to operate the pneumatic wrench. It is possible that the
wheel cover  could be damaged in removal and lug nuts could be lost.

1.3 Remove tires from wheels
   Tires are generally removed from the wheel using pneumatic tire removal equipment which
require energy. The old valve stem and balancing weights are removed. The old tire must be
dealt with according to the New Mexico Tire Recycling Regulations.

1.4 Put new tires on wheels
   New valve stems are put on the wheel before mounting the tire. Sometimes valve stems are
damaged. The same piece of equipment used in the previous step is used to put the new tire on
the wheel which requires the use of energy. Soapy water is generally used to act as a lubricant
for the tire bead.

1.5 Balance  tire/wheels
The wheel with a mounted tire are then brought over to a balancing machine which require
energy. New lead weights are placed on the wheel at the appropriate locations. Sometimes the
weights are damaged and have to be replaced.

1.6 Put wheels back on vehicle
The wheel and wheel covers are put back on reversing the operation of 1.2 using energy for the
pneumatic wrench. It is possible that wheel covers could be damaged in this operation and lug
nuts  could be broken.

1.7 Lower vehicle
Lower vehicle keeping in mind safety issues.

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                               2. Radiator Flush And Drain
       Clean Up
        Material
          2.1
     Open Pet Cock
       and Drain
        Radiator
                     Clean Up     Flushing
                     Material     Solution
                           Water       Energy
                                                Lead
                                               Solder
                                2.2

                               Flush
  Used
Antifreeze
Spillage
Wastewater
  Solution
                                            Leakage
                                            Repair Radiator
                                                Leaks
Spillage
Lead Solder
   Drips
    New         New
   Hoses      Clamps
                       New
                    Antifreeze
          2.4
     Check/Replace
         Hoses
                                             Water
                  Clean Up
                   Material
   Old
  Hoses
  Old
Clamps
                                2.5
                           Close Pet Cock
                             and Refill
                              Radiator
                                                 2.6
                                            Pressurize and
                                           Check for Leaks
           Spillage

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Map 2.0: Radiator Flush and Drain

2.1 Open pet cock and drain radiator
       In this process the used antfreeze is collected in a container for recycling or disposal.
Sometimes antifreeze is spilled on the shop floor which requires the use of clean up material to
absorb the antifreeze. This material is normally disposed of as hazardous waste.

2.2 Flush out radiator
       Machines which use energy are generally connected to the cooling system of the vehicle
to flush out any residual antifreeze and loose solid material. During this operation it is possible
for the solution to leak out of the cooling system or be acidently spilled on the shop floor. As
stated in 2.1 this will require the use of clean up material.

2.3 Repair radiator leaks
    This process may rely on the radiator being soldered with lead solder. Any lead that drips on
the shop floor must be removed and dealt with as a hazardous waste.

2.4 Check/replace hoses
If it was found that a hose was leaking during the flushing operation or if the hose appears to be
old and ready to break, it should be replaced with a new hose and appropriate clamps. The old
parts may be discarded in a dumpster.

2.5 Close pet cock and refill radiator
After all repairs are made and the pet cock is closed, new antifreeze and water are put into the
radiator. Care should be taken so as to not spill any antifreeze on the shop floor. Any antifreeze
that is spilled will have to be dealt with  as stated in 2.1. To insure that the cooling system is full,
the engine will have to be running long  enough to open the thermostat in the water pump.

2.6 Pressurize and check for leaks
While the engine is running the  cooling system should be checked for leaks. If found the return
to step 2.3 and repeat the remaining  steps.

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                 2.1 Antifreeze Recycling or Disposal
                                     Chemicals
   2.1.1
  Used
Antifreeze
4
2.1.2
Recycle
\
'


2.1.3
New Antifreeze

                                      Filter
                                       2.1.2


                                  Hazardous Waste
                                      Storage
                                                                              2.1.3
Disposal
                                                                            Spent Antifreeze

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Map 3.0: Air Conditioning Repair

3.1 Pressurize system chrck for leaks
   During this process, the AC system is generally connected to a machine that uses energy and
can inject a dye into the system so that leaks can be visable. If leaks are found they must be
repaired before the system can be checked out for its ability to cool. Any refrigerant that leaks
out will be disipated in the air.

3.2 Check system for cooling
   Assuming no leaks were found in the last step, a vent outlet in the vehicle has a thermometer
placed in it to measure the temperature of the air coming out.

3.3 Assess needed repairs
   Based on what was found in the previous two  steps an assessment of what needs to be
repaired or replaced is determined.

3.4 Fix leaks/defective parts or replace with new parts
   Any parts that are replaced can either be recycled or disposed of.

3.5 Refill system with refrigerant
   After all repairs are made the system is then attached to a machine that will refill the system
with the proper refrigerant.

3.6 Recheck system for cooling and leaks
   If any leaks are found or if the system is not cooling properly then go back to step 3.3 and
repeat the rest of the steps.

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                                   4. General Auto  Repair
 Paper on     Plastic on
Floor Mats     Seats
        Rags
               Clean Up
  Solvent       Materials
          Rags
         4.1
    Prep Vechicle
  & Assess Problem
           4.2

  Remove Defective Part
         Rags
        Dirty    I   Waste
 Dirty   Rags   *  Fluids
Solvent     Clean Up
           Materials
Solvent
              Rags
        4.3

Clean Repairable Part
                                                                            Dirty
                                                                           Solvent
              Dirty
              Rags
                                                                        Water
                                                                                   Rags

4.4
Replace Part




4.5
Check
Repair


\i
i
En
r
ergy
V
T
Soap
r v
4.6
Prepare
To Return
To Customer
i
Di
Ma
r
ty
ter i
1
Di
Ra
r
ty
gs i
y
Spent
rSoap
                                                                          Paper on
                                                                          Floor Mats
                                                   Plastic
                                                  on Seats

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Map 4.0:  General Auto Repair

4.1 Prep vehicle and assess problem
   During this process paper coverings are generally placed on the floor of the vehicle and
plastic is placed over the seats. Rags may be used in wiping off areas that appear to require
maintenance. These dirty rags maybe required to be handledd as hazardous waste depending on
what was wiped off.

4.2 Remove defective part
   Assuming a defective part is to be removed from the vehicle, it is not uncommon for a rag
with a solvent on it to be used to clean off an area to make removal easier. This rag is now
considered hazardous waste and must be dealt with accordingly. It is also possible for some sort
of fluid to be spilled at the point of removal. If it is allowed to fall on the shop floor then some
sort of clean up material  will be required to absorb the waste.

4.3 Clean repairable part
   Generally a part that  is to be repaired is taken to some sort of parts cleaner before it is
repaired. Rags may also be used to wipe off the part. Depending on what kind of parts cleaner is
used the dirty solvent and rags may be required to be dealt with as hazardous waste.

4.4 Replace part
   Replace the part in the reverse order it was removed.

4.5 Check repair
   The vehicle is now checked out to see if the new or repaired part solved the original
problem.

4.6 Prepare to return to customer
   The paper floor coverings and plastic seat covers are removed and reused or disposed of.
Some shops  may wash the vehicle before it is returned to the customer. If this is done it needs to
be accomplished in a method that collects the wastewater before it can enter the sewer system.

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                                      5. Brake  Change
     Pneumatic
      Wrench    Energy
                     Pneumatic
                      Wrench
              Energy
             5.1
       Remove Wheels
        from Vehicle
             T
           Energy
  Damaged        Lost Lug
Wheel Covers       Nuts
                                                                        Solvent         Air Gun
                                                                                 Rags
                               5.2
                         Remove Brake
                         Drums/Calipers
                         or Shoes/Pads
                                              5.3
                                         Clean Brake
                                          Assembly
                                         Drums/Rotors
                            Energy    T
                     Used          Broken
                   Shoes/Pads         Parts
                                             Dirty     T
                                     Dirty    Rags    Brake
                                    Solvent          Dust
  Brake Turning
     Machine
Energy
   New        Pneumatic
Shoes/Pads      Wrench
         Energy
Pneumatic
 Wrench
              5.4
         Turn Drums
         or Rotors
                                               1
      Metal
    Shavings
                Energy
                               5.5
                         Replace Brake
                         Shoes/Pads &
                         Drums/Calipers
Wheel
Covers Lug
                                                                              Energy
                                                                                         Nuts
                                                                                   5.6
                                          Put Wheels
                                        Back on Vehicle
                               V
                            Energy
                                            Energy
                                    Damaged
                                  Wheel Covers
                   T
                 Broken
                Lug Nuts

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Map 5.0 : Brake Change

5.1 Remove wheels from vehicle
   Normally a pneumatic wrench is used to remove the lug nuts while a prybar is used to
remove the wheel covers. Energy is used to operate the pneumatic wrench. It is possible that the
wheel cover could be damaged in removal and lug nuts could be lost.

5.2 Remove brake drums/calipers or shoes/pads
   This is normally done with a pnematic wrench which uses energy. The old parts will then be
recycled or disposed of.

5.3 Clean brake assembly drums/rotors
   Rear brake assemblies generally have drums that can accumulate brake dust that must be
removed in a safe manner according to OSHA Rules to protect the workers. A liquid brake
cleaner may be used to clean off the assembly. This will generate dirty rags that may be
considered hazardous waste.

5.4 Turn drums or rotors
   Depending on how out of round the brake drums and/or rotors are they may be required to
be turned. This is done on a machine that uses energy and generates metal shavings. These
savings may be collected and recycled.

5.5 Replace brake shoes/pads and drums/calipers
   This is done in the reverse order of operation 5.2 and uses energy

5.6 Put wheels back on vehicle
      The wheel and wheel covers are put back on reversing the operation of 5.1 using energy
for the pneumatic wrench. It is possible that wheel covers could be damaged in this operation
and lug nuts could be broken.

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                                      6. Oil  Change
                                   Clean Up     Clean
                                    Material       Rag
                                    Oil   Plug
                                   Filter
                                                                     Clean Up
                                                                     Material

6.1
Position Drip Pan Under
Hot Engine



V V
6.2
Remove Filter
8- Drain Plug
I I
T Drain rjirtv


V
6.3
Drain Oil
J T
                                                                 Used     Clean Up
                                                                  Oil     Materials
New
Filter
       Drain
Clean   Plu9
                                           Clean Up
                                   New      Clean
Clean Up
 Material
Rag
,. I .
Ol
_ L
6.4
Replace Filter
8- Drain Plug
i



Rag
, 1 ,
r i
6.5
Add Oil
1
I




6.6
Clean Up
i

     Dirty Rag
                                    Oil      Rag  Empty
                                 Spillage       Container
                                                                    Clean Up
                                                                     Material
                              6.3 Waste Oil  Management
V ^

6.3.1
Temporary Storage for
Used Oil and spill
Materials


Clean Up I
i
Material
6.3.2
Transfer to Used
Oil Storage Tank


i

6.3.3
Have picked up by a
waste oil recycler or
burn on site in a waste
oil heater
 Clean Up
 Materials
              Spills
                                     Spills
                                         Clean up
                                         Materials

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Map 6.0: Oil Change

6.1 Position drip pan under hot engine
   This is done to prevent waste oil from getting on the shop floor.

6.2 Remove filter and drain plug
   This operation can cause waste oil being spilled onto the shop floor which would then
require the use of clean up material to absorb the oil. The dirty material will need to be handled
as hazardous waste. Also dirty rags are generally generated. The oil filter should then be
properly drained of all oil and put into a filter crusher for recycling.

6.3 Drain oil
   The oil draining out of the engine should be going to a proper container that will prevent
used oil from getting on the shop floor. If any oil gets on the floor it must be properly cleaned
up. The clean up material may be required to be dealt with as hazardous waste.

6.4 Replace filter and drain plug
   During this operation a rag is generally used to wipe off any excess oil that may be on the
oil pan or engine block. This rag may be considered hazardous waste.

6.5 Add oil
   Care needs to be taken to prevent oil from being spilled. Any that is spilled needs to be
cleaned up with the appropriate  material and disposed of properly. The oil container needs to be
drained of any free liquid and may be recycled.

6.6 Clean up
   Any surface that has oil on it should be wiped off with a clean rag. This rag may be
considered hazardous waste.

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Auto Repair Shops
Regulatory and Pollution
Prevention Guidance and
Other Resources

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FACT SHEET FOR RADIATOR REPAIR SHOP

This fact sheet is  provided  by the New Mexico  Environment Department's Hazardous and
Radioactive Materials Bureau (HRMB) to provide regulatory guidance for the radiator repair
and reconditioning industry.

Radiator shops are  known to generate a variety of hazardous waste streams, primarily as a result
of lead contamination.  These wastes may include, but are not limited to,  sump sledges, spent
bead blast,  spent lead solder, lead contaminated dust and floor sweepings,  filter press cake, and
process wastewater.

The radiator shop  must first make hazardous waste  determinations to determine which of its
waste streams are in fact hazardous.   This determination  can  be done by  (1) collecting a
representative sample and having it analyzed, or (2) using knowledge of process. For example,
if you do not solder over the radiator test tank then there are probably no lead solder drippings
inside that tank and no reason for the water or sludge  to be hazardous for lead.  Please be aware
that if the facility chooses to use option #2, it has the burden of proving that the knowledge is
adequate,  and the HRMB  may collect  a sample of the waste to verify  the facility's
determination.

To determine  if the waste  is hazardous,  the waste should be tested for the Total  Metal
concentration of  lead, using EPA method  6010.  Total Metals  testing is the least expensive
method  and should cost less than  $100.00.    The  analytical  results  from  this  method
approximates the metal concentration by using the "20  Times Rule".   This rule of thumb
basically states that if the results of a "Totals"  analysis is 20 times the regulatory limit,
most likely the waste is hazardous. As an example,  if a "Totals" analysis for lead has a result
greater than 100 mg/1, this value is 20 times greater than the 5 mg/1 regulatory limit and is most
likely hazardous. If the shop wants to confirm that the lead value is greater than the regulatory
limit,  a  more concise test -  the Toxicity  Characteristic Leaching Procedure (TCLP)  must be
done.  These procedures are outlined in EPA Publication  SW-846.  HRMB recommends that
over a period of one year two separate samples should be taken of the waste and tested.  This
will provide the proof that your shop's routine   repair processes do not create a hazardous
waste.

One of the most important housekeeping practices that  a shop can do  to reduce lead
contamination and generation of hazardous waste is to designate one area  as the soldering area
and to keep the lead solder drips only in that spot.  Lead solder drips should not be swept  or
hosed into the drains or sumps.  Lead solder drips should be collected from the soldering area
and put into a bucket for recycling.  Lead solder recyclers do exist and will pick up the lead you
have collected.

Once the facility determines which waste streams are hazardous, it is very important to calculate
the total quantity of hazardous waste generated in order to determine the facility's regulatory
category. The three different types of generators and their regulatory requirements are:

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1.      Conditionally Exempt Small Quantity Generator (CESQG): is a generator of less
       than  220 Ibs  (100 kgs)  of hazardous  waste  in  a  month.   A  CESQG must make  a
       hazardous waste  determination for each waste generated and dispose of its hazardous
       waste at an authorized facility, which can be a hazardous waste facility or a landfill that
       is permitted to accept those wastes or other facilities approved by the state for industrial
       or municipal wastes.  A CESQG should not accumulate more than 2,200 Ibs (1000 kgs)
       of hazardous waste on-site at any one time.  If the facility  exceeds this amount then it
       becomes subject to the requirements for a small quantity generator.

2.      Small Quantity Generator (SQG): is a facility that generates  between 220 and 2,200
       Ibs (100 to  1000 kgs) of hazardous waste in a month.  A  SQG must comply with all
       applicable regulations found in 20 NMAC 4.1.301  and 801, which  incorporate the
       federal regulations 40 CFR Parts 262 and 268. A SQG must ship its hazardous waste
       only  to a facility with an EPA Identification Number.   A SQG should not accumulate
       more than 13,228  Ibs (6000 kgs) of hazardous waste on-site at any one time or store its
       hazardous waste on-site for longer than 270 days. If it does, then it becomes subject to
       the requirements for a large quantity generator.

3.      Large Quantity Generator (LQG): is a generator of greater than 2,200 Ibs (1000 kgs)
       of hazardous waste in a  month.  A LQG must comply with all applicable regulations
       found in  20 NMAC  4.1.301 and 801, which  incorporate federal regulations 40 CFR
       Parts 262 and  268.  The requirements  for a LQG  are much more comprehensive and
       stringent than  are those for either a CESQG or a SQG.

Above all else, avoid  disposing of any hazardous waste on-site, which is illegal and may subject
the facility to  significant fines,  unless the facility  has a permit to operate a disposal facility.
Please note that the regulatory requirements for a CESQG are the least burdensome.  Whenever
possible, most radiator shops will choose to operate as a CESQG.

The New Mexico Environment Department  wishes to assist the regulated  community  in
complying with all applicable regulations. Please contact the  Technical Assistance  Section of
the Hazardous and Radioactive Materials Bureau for further information and assistance (505-
827-1558 or 505-827-1512).  This assistance will  provide information to the  business owner
free of fear of fines or penalties.  Six-month amnesty from the enforcement section is provided
to those who take advantage of the program.

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FACT SHEET FOR VEHICLE PAINT AND BODY SHOP

This fact sheet is provided by the New Mexico Environment Department's Hazardous and
Radioactive Materials Bureau (HRMB) in order to provide regulatory guidance for the vehicle
paint and body repair industry.

Auto paint and body shops are  known  to generate a variety of  hazardous waste streams,
primarily as a result of repairing and painting activities.  These wastes may include but are not
limited to paint wastes and thinners, rust removers, solvents, degreasers,  sanding dusts, paint
covered booth filters, paint cone filters, and  cleaning fluids.  A shop  must first make  a
hazardous  waste determination  of which  waste  streams  are  in  fact hazardous.    This
determination can be done by (1) collecting a representative sample of each waste stream and
having it analyzed  for lead,  cadmium, arsenic  and  barium  by a  laboratory  capable  of
conducting hazardous waste analyses, or (2) using knowledge of process. Please be aware that
if the facility chooses to use option #2, it has the  burden of proving that the knowledge is
adequate,  and the  HRMB  may collect  a  sample  of the waste to  verify  the facility's
determination.

To  determine  if the waste is  hazardous,  the waste  should be  tested for the Total  Metal
concentration using EPA method  6010.  Total Metals testing is the least expensive method and
should cost less than $200.00. The analytical results from this method approximates the metal
concentration by using the "20 Times Rule".  This rule of thumb basically states that if the
results of a "Totals" analysis is 20 times the regulatory limit, most likely the waste is
hazardous.  As an example, if a "Totals" analysis for lead has a result greater than 100 mg/1,
this value is 20 times greater than the 5 mg/1 regulatory limit and is most likely hazardous. If
the  shop wants to confirm that the lead value is greater  than the regulatory limit,  a more
concise test - the Toxicity Characteristic Leaching Procedure (TCLP) must be done. These
procedures  are outlined in EPA Publication SW-846.  HRMB recommends that over a period
of one year, two separate samples should be taken of the waste and tested. This will provide
the proof that your shop's routine repair processes do not create a hazardous waste.

Lacquer thinners and paints are almost always hazardous waste and should be handled as such,
being kept in a closed container labeled hazardous waste.  This waste must be picked up and
disposed of by a hazardous waste management company or lacquer thinners and solvents can
be recycled by using a solvent still.  Solvent stills come in different sizes and will pay for the
still purchase price typically in one to two years.  The still will produce clean thinner or solvent
that can be reused and a cake of paint waste.  The paint waste sludge will be the only item that
has to be disposed of as a hazardous waste, which will  significantly reduce the volume of waste
thereby reducing the disposal costs as well as the thinner or solvent purchase cost.

Paint booth filters and sump sludge  may also be hazardous waste. These materials should be
tested prior to disposal to determine if the shop  processes create  a hazardous waste.  Once  the
materials have been tested then the shop will know how to handle those materials in the future.
The test results should be kept on file to prove to any regulatory agency that the disposal method
being used is the correct one.

-------
Once the facility determines which waste streams are hazardous, it is very important to calculate
the total  quantity of hazardous waste generated in order to determine the facility's regulatory
category. The three different types of generators and their regulatory requirements are:

1.      Conditionally Exempt Small Quantity Generator (CESQG):  is a generator of less
       than  220 Ibs (100 kgs) of hazardous waste in a month.  A CESQG must make  a
       hazardous waste determination for each waste  generated and dispose of its hazardous
       waste at an authorized facility, which can be a hazardous waste facility or a landfill that
       is permitted to accept those wastes or other facilities approved by the state for industrial
       or municipal wastes.  A CESQG cannot accumulate more than 2,200 Ibs (1000 kgs) of
       hazardous waste on-site at any  one time.  If the facility exceeds this amount then it
       becomes subject to the requirements for a small quantity generator.

2.      Small Quantity Generator (SQG): is a facility that generates between 220 and 2,200
       Ibs (100 to 1000 kgs) of hazardous waste in a  month. A SQG must comply with all
       applicable regulations found in 20 NMAC  4.1.301  and 801,  which  incorporate  the
       federal regulations 40 CFR Parts 262  and 268.  A SQG must ship its hazardous waste
       only  to a facility with an EPA Identification  Number.  A SQG cannot accumulate more
       than  13,228 Ibs (6000 kgs)  of  hazardous waste on-site  at any  one time or store its
       hazardous waste on-site for longer than 270 days.  If  it does, then it becomes subject to
       the requirements for a large quantity generator.

3.      Large Quantity Generator (LQG): is a generator of greater than 2,200 Ibs (1000 kgs)
       of hazardous waste in a month.   A LQG must comply with all  applicable regulations
       found in 20 NMAC 4.1.301 and 801, which incorporate federal regulations 40 CFR Parts
       262 and 268. The requirements for a LQG are much more comprehensive and stringent
       than  are those for either a CESQG or a SQG.

Do not dispose of any hazardous waste on-site, this is illegal and may subject the facility to
significant fines, unless the facility has a permit to operate a disposal facility. Please note that
the regulatory requirements  for a CESQG are the least burdensome.   When possible, most
vehicle paint and body shops will choose to operate as a CESQG.

The New Mexico  Environment Department wishes  to assist  the  regulated community in
complying with all applicable regulations. Should  you wish assistance, contact the  Technical
Assistance Section at 505-827-1512.  By participating in an assistance site visit your facility will
receive six months amnesty from the enforcement section of HRMB and learn what is required
to  operate in compliance with the regulations.

For further information concerning this fact sheet, please contact the Hazardous and Radioactive
Materials Bureau Technical Assistance Section at 505-827-1512 or 505-827-1558.

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FACT SHEET ON CONTAMINATED RAGS AND WIPERS

This fact sheet is provided by  the New Mexico Environment Department's Hazardous  and
Radioactive Materials Bureau (HRMB) to give regulatory guidance to those businesses  that
generate rags and wipers that may be contaminated with solvent, oil and other materials.

In order  to make an official regulatory  decision concerning the status  of rags  and wipers
contaminated  with   possible  hazardous  constituents,  HRMB  sent  a  letter  to the  U.S.
Environmental Protection Agency, Region 6, outlining HRMB's position and concerns.  Upon
receipt of this letter, and after subsequent conversations between HRMB and EPA  staffs, EPA
responded with a letter dated August 30, 1993.  In this  letter, EPA concurs with HRMB's
position on how contaminated rags should be regulated.

Specifically, HRMB will regulate  contaminated  wipers as per the New Mexico Hazardous
Waste  Management  Regulations (20  NMAC  4.1),  which adopt by reference, with a  few
exceptions, 40 CFR Parts 260-270, in the following manner:

1.     If a spent rag or wiper contains a listed  hazardous waste or exhibits a hazardous waste
       characteristic (ignitable, corrosive, reactive, or toxic), then the wiper will be regulated as
       a hazardous waste.  HRMB has not made in the past, and does not make at the present
       time, a  distinction as to when a wiper becomes hazardous waste. Once the  wiper is no
       longer being used, it must be handled as a hazardous waste if it meets the definition of
       hazardous  waste.  Therefore,  unless  the generator is a Conditionally Exempt  Small
       Quantity Generator (CESQG)(generating less than 220  Ibs of hazardous waste per
       month), wipers meeting the definition of hazardous waste would have to be manifested
       to a facility having an EPA identification number.

       CESQG facilities are only required to dispose of the hazardous waste correctly.  This
       means that wipers and rags that do not have free  flowing liquids can go to the local
       landfill if the landfill will accept them.   Contact the Solid Waste Bureau at 505-827-
       2938 or the local landfill for this determination.

2.     Laundering of wipers is considered a form of reclamation  since the spent material, i.e.
       the wiper containing the contaminants, has been used  and  as a result of contamination
       can no  longer serve as a cleaning agent without first being laundered to  remove the
       contaminants.  Therefore, wipers that are stored on-site prior to  shipment off-site or
       reclaiming on-site must be stored in compliance with  20 NMAC 4.1.  This regulation
       requires that the wipers be stored in a closed container.  The Occupational Safety and
       Health  regulations require  this  container to be  metal  due  to  the  possibility  that
       spontaneous combustion might occur.

-------
       If the facility is a Small Quantity Generator (SQG)(generating between 220 Ibs
       and 2,200 Ibs of hazardous waste per month)  or a Large Quantity Generator
       (LQG)  (generating  over  2,200  Ibs  of  hazardous  waste  per  month)  the
       requirements regarding storage are much more complex with such conditions as
       an emergency communication device, container labeling, weekly inspection of
       storage area, portable fire extinguishers, and training  for personnel,  as well as
       much more.

3.      In the case of contaminated wipers being shipped to a laundry for cleaning and
       reuse, other regulations such as the  Clean Water Act, may apply to the wash
       water.  Many  municipalities have their own regulations regarding what can go
       down the drain, contact the local wastewater treatment officials.  The hazardous
       waste regulations apply to the wipers only  until  they are actually placed into the
       laundry process.   An off-site laundry accepting regulated wipers  would have to
       obtain a hazardous waste  storage permit unless it washes the wipers within 24
       hours.

In a  letter dated January 23, 1991 to Lance R. Miller, Division of Hazardous Waste
Management, New Jersey  Department of Environmental Protection, from  Sylvia  K.
Lowrance,  Director,  Office  of  Solid  Waste, EPA  stated that  "...  the Regions  and
authorized  States  remain  in the best  position  to determine  the  hazardous  waste
regulations'  applicability in specific cases."   HRMB will enforce the hazardous waste
regulations as it deems necessary to protect human health and the environment in New
Mexico.

The Hazardous Waste Technical Assistance Section is available to assist all businesses in
complying with the regulations. Should you ask the Technical  Assistance section to help
evaluate your compliance, your  business would receive six months  amnesty from the
Enforcement Section of the Hazardous  and Radioactive Materials  Bureau.  Contact
Technical Assistance at 505-827-1512 or 827-1558.

Pollution Prevention Tips:

© Use as little solvent as necessary to get the job done.
©  Reuse the wipers as much  as possible to reduce the  number of wipers that are
contaminated.
©  Change to a non-hazardous  or  less hazardous  solvent to reduce the number of
requirements.
©  Wring or drain rags and wipers into waste  solvent or  waste oil tank to reduce
contaminants.
© Use drip pans to catch spills and eliminate the need to use rags or wipers.
© do not air dry contaminated rags or wipers.
©  Do not launder or pre-wash the  rags or wipers at  your facility,  residence or local
laundromat.

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          SPECIFIC REGULATORY GUIDANCE FOR AUTO REPAIR SHOPS

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

AIR EMISSION REGULATIONS:

Attached to this document is a brochure entitled "Automotive Paint and Body
Shops" that gives some basic ideas on what is required with respect to air
quality permits. Since the paint manufactures have been putting less and less
VOCs in their paints, the main concerns at a repair shop will be the solvents
being  used. As the brochure stated, if in doubt about determining your
classification (major vs minor) contact the NMED Small Business Assistance
Program at 1-800-810-7227 or the City of Albuquerque Air Quality Assistance
Program at 505-768-1964 if your business is located in Bernalillo County.

HAZARDOUS WASTE REGULATIONS:

Attached to this briefing paper is a document entitled "Fact Sheet for Vehicle
Repair Shops" that can assist you in being compliant with Hazardous Waste
Regulations.  It lists many of the hazardous materials that are generated. One in
particular that should not be disposed of is antifreeze, since it is a very easy to
recycle.

WASTEWATER REGULATIONS:

This can be of a major concern since liquids of all kinds  have a tendency of
leaking all over the floor of repair shops. Sealing the floor and drains is a very
good and inexpensive way of avoiding contamination of soils and possibly
ground water under your building. You should also restrict what is poured into
the sewer system.

OSHA REGULATIONS:

Attached to this document is a checklist entitled "Auto Repair Shop Safety
Checklist" that can assist you in being compliant with OSHA.

UNDERGROUND STORAGE TANK REGULATIONS:

Unless your business stores regulated material such as  gasoline in a LIST, there
is nothing unique that wasn't already covered in the General Guidelines. If in
doubt about LIST regulations, please contact the  LIST Bureau at 505-827-0188.

SOLID WASTE REGULATIONS:

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The solid waste regulations prohibit lead acid batteries in landfills as well as bulk
liquids such as used oil and used brake fluid. These products are easy to
recycle. Another waste unique to auto repair shops is a scrap tire. You are
allowed no more than 500 scrap tires on your premises at any one time. They
must be stored in such a way as to not be a fire hazard or have a vector (rats,
snakes, etc.) problem.
GENERAL REGULATORY GUIDANCE FOR NEW MEXICO SMALL BUSINESSES
The purpose of this briefing paper is to assist small businesses in New Mexico
in trying to understand the environmental regulatory requirements associated
with doing business by giving a general overview. It is not intended to be a
substitute for actual regulations. Businesses are responsible for operating their
business in full compliance of the law (regulations). Each bureau in the New
Mexico Environment Department (NMED) have staff available that can help you
directly in understanding what is expected of your business from a regulatory
point of view. It is in your best interest to contact the appropriate bureau if you
have questions.

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

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

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

Much of the national strategy for controlling air pollution centers around the
NAAQS. These standards set limits for the concentration in the ambient

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(outdoor) air of the six most common air pollutants: Ozone, Carbon Monoxide,
Particulate Matter, Sulfur Dioxide, Nitrogen Dioxide, and Lead.

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

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

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

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

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

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

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HAZARDOUS WASTE REGULATIONS:

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

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

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

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

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

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

Each classification has different record keeping, manifesting, and reporting
requirements. Since a businesses' classification is based on a monthly
generation, it is possible to move from one classification to another on a regular

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basis. All generators of hazardous waste are required to register with the
Hazardous Waste Bureau and pay a generator fee based on their classification.

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

It is important for any business generating hazardous waste to understand that
RCRA has established a "cradle to grave" responsibility for the generator of said
waste. In effect this means that if the hazardous waste the business generates
contaminates soil, surface water, or ground water in any manner until it is
properly disposed of, the business will be held responsible for the clean up of
the contamination. The cost of clean up could be substantial. It is therefore
imperative for any business to make sure trained employees handle their
hazardous material properly to avoid accidental spills, to only use permitted
haulers, to make sure their waste goes to a RCRA  permitted facility, to properly
store their hazardous waste, and never dispose of their hazardous waste at their
facility. It is also advisable to seal the floor of the facility if you use a hazardous
material in a liquid form in  your operation.

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

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

WASTEWATER REGULATIONS:

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

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

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business may be required to request a NPDES Permit from the EPA if the
discharge is to surface water.

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

Business need to be aware that even though their wastewater going into the
sewerage systems is allowed by the POTW, this does not necessarily relieve
them of potential contamination liability. A good example is  the case in which a
sewer pipe leaks and the wastewater contains hazardous constituents, below
RCRA levels, that were generated by your business. Over  time the wastewater
seeps into the ground water and the concentrations exceed State or Federal
water quality standards. If the contamination source can be traced back to your
business, you could be liable for the cost of cleanup. Most businesses will find
that the costs associated with proper handling of their wastewater are far
cheaper than the cost of cleaning up ground water. Prevention is an inexpensive
insurance policy.

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

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

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

OSHA REGULATIONS:

Every business is required to provide a safe and healthy working environment
for its employees. The Occupational Health and Safety Bureau (OHSB) is
responsible for making sure businesses are in compliance with OSHA
regulations. OSHA regulates permissible exposure limits (PEL's) for employees
exposed to certain air contaminants in the workplace.  The Bureau conducts
regular inspections of facilities and evaluates the establishment for safety and
health compliance. The OSHB  has a consulting program to assist facilities to be
in compliance with OSHA regulations. The service is free of charge to New
Mexico small businesses. Attached is a copy of "Frequently Asked Questions"

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about the program, a copy of "General Health & Safety Issues", as well as a
poster you are encouraged to display at your facility. They can be contacted at
505-827-4230.

UNDERGROUND STORAGE TANK REGULATIONS:

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

The Solid Waste Bureau (SWB) deals primarily with regulating solid waste
facilities (non-hazardous waste landfills, transfer stations, and recycling
facilities) and illegal dumping. The only responsibility for a small business is to
see that their non-hazardous waste is either sent to a recycler or to a permitted
landfill by a registered solid waste hauler. For information the SWB can be
contacted at 505-827-0197.

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OSHA Auto Repair Shop Safety Checklist


Yes  No


Walking Working Surfaces

D  D Are all aisles and walkways 22" or wider?
D  D Are permanent aisles marked and maintained free of obstructions?
D  D Are spills and slick areas cleaned up?


Hand Tools

D  D Are tools clean and in good condition?
D  D Are chisels and punches without mushroomed heads?
D  D Are wood hammer handles without cracks or splits?


Power Tools

D  D Are right angle grinders equipped with half moon guards?
D  D Is hearing protection worn when using impact tools?
D  D Are electric tools double insulated or grounded?
D  D Are bench grinder tools rests (1/4") and top tongue guards (1/8") adjusted?


Machinery

D  D Are all guards in place?
D  D Is machinery used according to manufacturers instructions?
D  D Does air compressor have Lock-out/Tag-out procedure? Locks and Tags?
D  D Are car hoists and lifts inspected annually by experts?
D  D Are overhead hoists and engine hoists inspected (internally) annually?
D  D Are air nozzles restricted to 30 psi or less?


Flammables

D  D Are flammables (<25 gallons) stored in approved cabinets?
D  D Are fire extinguishers available for types of flammables?
D  D Are spray paint operations performed inside spray booth  or area?
D  D Are torches  more than 20 feet from other flammables?
D  D Are torches  more than 20 feet from other spare bottles, including empties?

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           Yes

           Personal Protective Equipment

           D  D  Is  hearing  protection  provided  and  are employees  trained  on use and
           limitations?
           D  D  Is a Chemical Hazard Communication  Program in place?
           D  D  Is personal  protective equipment used?
           D  D  Is a written  Personal Protective Equipment program in place?


           Electrical

           D  D  Are all cords in good condition?
           D  D  Is strain relief provided for cord connections to tools or junction boxes?
           D  D  Is conduit used for permanent wiring?
           D  D  Are all outlets grounded?
           D  D  Are all areas within 6  feet of wet or potentially wet surfaces  protected by
           GFCI?

           Safety and Health Program (recommended)

           D  D  Is a Job Hazard Analysis written for hazardous jobs?
           D  D  Is training provided for Job Hazard Analysis tasks?
           D  D  Are safe behaviors observations conducted?
           D  D  Is there management commitment to the safety program?
           D  D  Are employees involved in a safety program?
           D  D  Is the safety program evaluated periodically?
   Note: If any of the above questions that are answered with "Yes", then the condition is probably
   adequate.  If any of the above questions are answered "NO", then re-evaluate the situation, as a
                   violation of the standards may exist. For assistance contact:

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

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

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             OSHA General Health and Safety Issues
YES   NO
D D  Do the employees wear respirators?
       If so,
D D  Does the company have a written respiratory protection program?
D D  Are  employees trained to properly wear, clean/maintain, and know in what
   situations the respirators are needed?
       If not,
D D  Is the indoor air quality such that they are not needed?
D D  Is there a written Hazard Communication Program?
D D  Are  MSD sheets  available for all the hazardous chemicals in the workplace
and are
       they updated regularly?
D D  Have employees received Hazard Communication training?
D D  Are  there elevated storage/equipment lofts or platforms present?
       If so,
D D  Are signs showing the weight capacity present?
D D  If the floors are more than 4 feet above a lower floor, are guardrails present?
D D  Are  all exits marked with signs?
D D  Are  exit doors free to access and are routes  to  these exits  kept free of
obstructions?
D D  Is there a procedure in  place for obtaining  medical treatment for injured
employees?
D D  Are  there first aid  supplies readily available?
D D  Are  there fire extinguishers on site?
D D  Are  they charged  and ready for use?
D D  Are  employees required to use these extinguishers?
       If yes,
D D  Is the path unobstructed?

YES   NO

D D  Are  they subjected to an annual inspection?

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           D  D Are employees trained to use them?
                 If not,
           D  D   Is there a written policy that requires employee evacuation?
           D  D   Does the company have  an emergency  action plan and fire prevention
           plan?
           D  D Has the electrical system throughout the facility been assessed for situations
           where
                 an  employee  may  come  into contact with  an electrical current,  or the
           electrical
                 system is  such  that  a fire  hazard  exists  (i.e.  bare conductors,  faulty
           equipment,
                 exposed electrical equipment where a flammable/explosive environment may
           exist)?
           D  D Does  the  employer (if 10+  employees are employed) record occupational
           injuries
                 and illnesses on the OSHA-200 log?
   Note: If any of the above questions that are answered with "Yes", then the condition is probably
   adequate.  If any of the above questions are answered "NO", then re-evaluate the situation, as a
                   violation of the standards may exist. For assistance contact:

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

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

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OSHA CONSULTATIONn'ECHNICAL SERVICES


FREQUENTLY ASKED QUESTIONS

What is the Consultation Service all about?

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

What does your service cost and who is eligible?

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

What types of places do you visit?

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

Where does the Consultation Service get its funding?

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

How long does the consultation process take?

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

What kinds of things do you look at?

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

Do we have to let you in all areas?

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

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

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

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

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

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

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

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

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

Do you come back to verify hazard correction?

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

How do we request an extension of time on corrections?

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

What is the SHARP Program all about?

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

Does Sharp keep OHSB enforcement out in all cases?

    No, At SHARP sites, OHSB will continue to make inspections in the following
situations:
    •   imminent danger;
    •   fatality/catastrophe;

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   •  formal complaints;
   •  referral from other government agencies; or
   •  follow-up on previously cited violations.

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

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

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

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

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

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

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

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

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

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

May I call your office anytime to ask questions?

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

Can anyone gain access to my report?

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

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

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

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

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

Have you been  or will you go to my competitor?

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

Where can I get a copy of the regulations?

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

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

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

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


Hazardous Waste Bureau
Debby Brinkerhoff
NM Environment Department
2044 Galisteo
P.O. Box26110
Santa Fe, NM 87502
505-827-1511
FAX: 505-827-1833
E-mail: debbv  brinkerhoff@nmenv.state.nm.us
Occupational Health & Safety Bureau
Debra McElroy
525 Camino de los Marquez, Suite 3
P.O. Box 26110
Santa Fe, NM 87502
505-827-4230
FAX: 505-827-4422
E-mail: debra  mcelrov@nmenv.state.nm.us

Ground Water Quality Bureau
Industrial Waste Team Leader
NM Environment Department
1190 St. Francis Drive
P.O. Box26110
Santa Fe, NM 87502
505-827-2900
FAX: 505-827-2965

Solid Waste Bureau
Jim Condiss
NM Environment Department
1190 St. Francis Drive
P.O. Box26110
Santa Fe, NM 87502
505-827-0559
FAX: 505-827-2902
E-mail: iim  condiss@nmenv.state.nm.us


Underground Storage Tank Bureau
Joyce Shearer, Ph.D.
NM Environment Department
1190 St. Francis Drive
P.O. 60x26110
Santa Fe, NM 87502
505-476-3779
FAX: 505-827-0310
E-mail: Joyce  shearer@nmenv.state.nm.us

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

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

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

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

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

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

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

(505)734-5482

(505)891-1223
(505)891-1223
(505)753-4740
(505)384-2302
(505)394-2576
(505)599-1315
(505)355-2401
(505)863-1210
(505)287-7927
(505)752-3201
(505)267-3021
(505)397-9315
CONTACT PERSON
Jose Miramontes
Charles Bowman, WW Utilities
Div. Director
Pat Banegas
Ernest Thompson, Mayor
Gary Spickelmier
Robert Rimorin
NickTobey
Casimiro Ruybalid
Lynn Steinle
Terry Cox
Gilbert Ybarbo
Steve Sale
Tony Gonzales, Mayor
Lino Paiz

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

Joe Alvarez

Donald Thymes
Donald Thymes
Frank Naranjo

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

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


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

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

(505)589-1979
(505)758-8401
Meryle F. Stueve, TSgt, USAF
Fred Seifts
David Sanchez, Mayor

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

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

Mark Boling
Mark Swan, Supervisor

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

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Online Resources:

City of Albuquerque P2 Progranrwww.cabq.gov
EPA Compliance Assistance Centerwww.ccar.com
US EPA: www.epa.gov
Additional Sources of Information:

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

The City of Albuquerque Public Works Department has a guidebook on pollution prevention for
the automotive industry. Please contact Bob Hogrefe at_505- 873-7030 for a copy.

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    Pollution  Prevention  and You:   Automotive
                         Industry Fact  Sheet
                     Eliminate - reduce - reuse - recycle - exchange
The improper handling of many of the chemicals used in the automotive industry is causing
environmental and health concerns.  If these chemicals are handled correctly, they can become a
source of revenue; for example, used motor oil, with the proper equipment, can be burned for heat.
The best way to eliminate much of this pollution is to find methods that will not create it in the first
place. Even small businesses can save money by participating in a program to cut back waste.
Remember, 80% of your environmental costs can be attributed to 20% of your actions

This fact sheet will point out several of the problems that exist in the automotive industry and offer
solutions that will save money, help the environment, and increase productivity. The Green Zia
program of New Mexico encourages all businesses to take part in an effort to reduce pollution.
Problem: Used Motor Oil
Used motor oil causes 40% of the pollution in U.S. waterways.  Annual illegal disposal of motor oil
equals nearly 20 Exxon-Valdez spills. One gallon of motor oil spoils 250,000 gallons of fresh water
for over 100 years.
Solutions:
]
   Cut oil disposal fees by converting motor oil waste into electricity or heat.
   Collect all used oil. Use a system that can remove 99.5% of used oil and turn oil filters into
   recyclable scrap metal.  Try the worksheet provided by the Clean Burn Company at
   http://www.cleanburn.com/UsedOil.cfm
   Learn which motor oil vendors will pick up used motor oil with a new purchase order.

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               Use products that are environmentally safe to clean motor oil spills. Most microbial products are
               biodegradable, non-leaching, and water repellent.
               Refer to http://biocleanplanet.com/oil sponge.htm for a cost comparison among traditional absorbents
               and microbial-based products.
               Compare traditional absorbents with a floor sweep product containing cellulose wood fibers at
               http://www.mcphee-env.com/sos.htm
               Fully separate and label individual solvent wastes. Used motor oil should never be mixed with
               antifreeze.  This causes harm to recycling equipment. However, some waste oil heaters can be
               set up to burn antifreeze with the waste oil.
            Problem: Antifreeze
i-
            Because antifreeze is very poisonous, it can cause respiratory and cardiac failure as well as severe
            brain damage and death.  Its sweet taste makes it a hazard to both children and pets.  Improper
            disposal and/or spills can cause ground and water contamination.
Solutions:
-i
               Collect and store used antifreeze separately from all other wastes.
               Immediately clean up all spills and never pour antifreeze down the drain.
               Use onsite recycling, which eliminates disposal costs and provides a reusable antifreeze source.
               Examine costs at http://www.antifreeze-recvcler.com/
               Use an alternate antifreeze that contains propylene glycol, a less toxic chemical than found in
               traditional antifreeze.  This chemical has an unpleasant taste, which discourages children and
               pets from sampling it.  Refer to http://autos.vahoo.com/repair/results/ques012.html for more information.
               Do not mix alternate antifreeze with traditional. Recycle and store it separately.
            Problem: Batteries
            Automobile batteries contain 18 pounds of lead and a gallon of sulfuric acid.  Lead is a highly toxic
            heavy metal that is a significant health hazard when leached into ground and water sources.
            Sulfuric acid is corrosive enough to dissolve most materials, including living tissue.
            Solutions:
                     ]
               Make sure there is no leakage when storing or transporting batteries.

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•  Batteries are 100% recyclable.  A complete recycle network is in place locally and nationally to
   deal with recycling batteries.
•  Examine http://www.recvcle.net/recvcle/batteiWclass bl/xv020100.html for information and phone
   numbers for battery recycling and trading.
Problem: Brake and Transmission
Fluids
Brake fluid, which is corrosive and combustible, and transmission fluid, which contains petroleum
distillates and is ignitable, pose serious threats to the environment.
Solutions:
j
•  Do not mix brake or transmission fluid with motor oil.  This causes both to be non-recyclable.
•  Keep both fluids away from heat and fire, and clean up spills immediately.
•  Use a tank with a 200-gallon minimum capacity for storage.
•  Your local used oil recycling services provider may provide brake and transmission fluid
   services.

For more information on recycling and storing dangerous automotive fluids, refer to the following
web-sites:
http://www.coloplains.com/recycling/auto.html
http://www.csma.org/
http://www.orcbs.msu.edu/AWARE/pamphlets/auto/
http ://www. ecoregs. com/currdevl .htm
http://www.p2pays.org/ref/01/00124.htm
www.ccar.com

The following local contacts are also  available to answer questions about Pollution Prevention:

Patricia Gallagher, New Mexico Environment Department: (505) 827-0677

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City of Albuquerque P2 Program:
Before discharging any type of wastewater to the sanitary sewer system call your local

treatment plant, or the Industrial Pretreatment Program to find out if there are any

restrictions.

1.  Wastes that effect the treatment system include heavy metal wastes along with chemicals that are
   listed as toxic or hazardous.

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

3.  Training programs regarding proper handling of wastes and chemicals for operators and
   maintenance personnel is essential.

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

5.  Inspection and spill control plans are also required.

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

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

Why Recycle Antifreeze?

Did you know that spent antifreeze often contains heavy metals? Heavy metals from a car's engine
accumulate in antifreeze. The American Society of Testing and Materials (ASTM) conducted a
study of spent antifreeze. The study determined that roughly 40 percent of waste antifreeze is
hazardous waste due to elevated levels of lead. Even though newer models of cars have radiators
made of composite plastic they still have coils inside, usually copper, brass or aluminum.  The solder
used for radiators most often contains lead. Metals most likely to be found in antifreeze are copper,
lead and zinc. Also, spent antifreeze may contain phenols. Phenols are a carcinogen that are
classified as extremely hazardous by the EPA. Absorption of phenolic solutions through the skin
can cause damage to kidneys, liver, pancreas, spleen, and edema of the lungs.  Handle waste
antifreeze properly by:

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1.  Analyzing the antifreeze using the Toxicity Characteristic Leaching Process in order to determine if
   there are hazardous metals present.

2.  As long as your shop recycles spent antifreeze on site or off site within New Mexico the spent
   antifreeze does not need to be manifested or tested.

3.  The management of used antifreeze is regulated by RCRA and by individual state requirements. It
   is the generator's responsibility to determine whether a waste is hazardous.

Why Do I Need A Spill Prevention Plan?

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

 Some General Spill Control Procedures Include:

1.  Isolating the spill area

2.  Tending to any injured or contaminated personnel.

3.  Notifying the proper authorities.

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

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             United States
AIR FORCE MATERIEL COMMAND
Compliance Through Pollution Prevention
                 (CTP2)
            Implementation Guide
                  Interim Final
                  29 Jun 2001
  Prepared for.
  311 HSW/XPE
  Brooks AFB, TX
  Prepared by:
MELE Associates, Inc
  Brooks AFB, TX
                  GSA contract:
                 GSOOTOOAC4131

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                                                 CTP2 Implementation Guide
                                                                    29 Jun 2001
                                                                    Interim Final
                            TABLE OF CONTENTS


1 INTRODUCTION TO AFMC'S COMPLIANCE THROUGH POLLUTION PREVENTION (CTP2)
PROCESS AND CONCEPTS	1
   1.1 CTP2 Definition	1
   1.2 AFMC CTP2 Mission Statement	2
   1.3 AFMC CTP2 Goals	2
   1.4 CTP2 Relationship to API 32-7080	2

2 THE CTP2 CYCLE	3

3CTP2TEAM	5
   3.1 CTP2Team Responsibility	5
   3.2 Establishing the CTP2 Team	5
   3.3 Finalizing the CTP2 Team	5
   3.4 Checklist of CTP2 Team Skills and Responsibilities	5
      3.4.1 CTP2 Team Skills	6
      3.4.2 CTP2 Team Responsibilities	6
   3.5CTP2Team Contact Information	6
   3.6 Overall CTP2 Team Tasks/ Deliverables	6

4 CTP2 MANAGEMENT ACTION PLAN  (MAP)	8
   4.1 What to do First	8
   4.2 Installation Specific Background Information	8
   4.3CTP2Team Members	9
   4.4 Installation CTP2 Goals and Objectives	9
   4.5 Installation CTP2 Strategy	9
   4.6CTP2 Executive Summary	10

5 COMPLIANCE SITE IDENTIFICATION	11
   5.1 What is a Compliance Site	11
   5.2 General Information on Compliance Sites	11
   5.3 CTP2 Applicable Environmental Laws	11
   5.4 CTP2 Excluded Environmental Laws	11
   5.5 Compliance Site Physical Location	12
   5.6 Tools to Determine Compliance Sites	13
   5.7 Compliance Site Inventory	13

6 COMPLIANCE SITE BURDEN DETERMINATION	14
   6.1 Compliance Site Costs	14
   6.2 Determining EC Recurring Costs	14
   6.3 Compliance Site Inventory Compliance Site Cost Fields	14
   6.4 Maintaining Compliance  Site Cost Information in the CSI	15
   6.5 Compliance Site Risk	15
   6.6 Compliance Site Burden	16
   6.7 Maintaining Compliance  Site Risk Information in the CSI	16
   6.8 CSI Fields for Compliance Site Burden	16

7 COMPLIANCE SITE GROUPING	17
   7.1 Steps for Compliance Site Grouping	17
      7.1.1 Step 1: Rank Order Compliance Sites	17
      7.1.2 Step 2: Group Compliance Sites	17
   7.2 CSI Grouping	18
   7.3 PSG Information	18
  AFMC	Page i

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                                                 CTP2 Implementation Guide

                                                                    29 Jun 2001
                                                                   Interim Final

8 GROUP PRIORITIZATION	20
   8.1 Steps for PSG Prioritization	20
      8.1.1 Step 1: Establish PSG Burden Rank	20
      8.1.2 Step 2: Identify, Evaluate, and Address Local Considerations	20
      8.1.3 Step 3: Set PSG Priority	21
   8.2 PSG Information	21

9 PROCESS SPECIFIC OPPORTUNITY ASSESSMENTS (PSOA)	22
   9.1 STEP 1: PSOA Background Development	23
   9.2 STEP 2: Form PSOA Team	23
   9.3 STEP 3:Characterize Process	23
   9.4 STEP 4: Select Opportunity	23
   9.5 STEP 5: Root Cause Analysis of Selected Opportunity	24
   9.6 STEP 6: Develop Potential Solutions	24
   9.7 STEP 7: Draft Action Plan for Solutions	24

10 CTP2 SOLUTION PLANNING & PROGRAMMING	26
   10.1  PSOA Solution Selection	26
   10.2  PSOA Solution Selection Funding Considerations	26
   10.3  BMP Solutions	26
   10.4  PC and COTS/GOTS Solutions	26
      10.4.1 Pollution Prevention Solution	26
      10.4.2 Weapon System Specific Solution	27
      10.4.3 Capital Investment Solutions	27
   10.5  DEM VAL and R&D Solutions	27

11 CTP2 SOLUTION IMPLEMENTATION	28
   11.1  Step 1: Reaffirm Process Owner(s) Commitment	28
   11.2  Step 2: Develop Implementation Plan	28
   11.3  Step 3: Oversee Implementation	28
   11.4  Output to CTP2 MAP	28

12 CTP2 SOLUTION EVALUATION	29
   12.1  Output to CTP2 MAP	29

GLOSSARY	30

APPENDIX A CSI FIELDS FOR COMPLIANCE SITE IDENTIFICATION	32

APPENDIX B EC RECURRING COST DETERMINATION	41

APPENDIX C COMPLIANCE SITE RISK ALGORITHM	42

APPENDIX D SAMPLE STATEMENT OF WORK (SOW) FOR CONTRACTOR SUPPORT IN
CONDUCTING PROCESS SPECIFIC OPPORTUNITY ASSESSMENTS (PSOA)	49

APPENDIX E PSOA SOLUTION SELECTION TOOL	51
   E.1 Process/Methodology	51
   E.2 Solution Selection Tool	51
   E.3 Step 1: Solution Selection Tool Preparations	52
      E.3.1 CSI Table Link Changes	52
   E.4 Step 2: Load Solution Data	59
      E.4.1 Getting Started	59
      E.4.2 Description of Solution Data Used	59
      E.4.3 Loading Solution Data	60
      E.4.4 Completing the Data Loading Process	64
   E.5 Step 3: Rank Solutions	65
      E.5.1 Getting Started	65
      E.5.2 Solution Ranking Options	65
      E.5.3 Ranking Considerations	66
  AFMC	Page

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                                                  CTP2 Implementation Guide

                                                                      29 Jun 2001

                                                                     Interim Final

    E.6 Other Tool Tips	66
       E.6.1 Background on CSI Links	66
       E.6.2CSI Link Updates	67
       E.6.3 Making Tool Copies	67

APPENDIX F HOW THE PSOA SOLUTION SELECTION TOOL WORKS	69
    F.1 Return on Investment (ROI) Payback in Years Calculation	69
    F.2 EC Cost, Risk, and Burden Reduction Score Calculations	69

APPENDIX G PROCESS SPECIFIC OPPORTUNITY ASSESSMENT (PSOA) GUIDANCE MANUAL
 	73
    G.1 Overview	74
    G.2 Plan and Schedule PSOA's	75
    G.3 STEP 1: PSOA Background Development	75
       G.3.1 Must Check Resources	75
       G.3.2 Should Check Resources	76
       G.3.3 Go/No Go Decision on Need for PSOA	76
       G.3.4 Preliminary Data Collection	76
       G.3.5 Background Information Documentation	77
       G.3.6 Meet with Decision Maker (DM)	77
    G.4STEP2: Form PSOA Team	78
       G.4.1 Team Selection Considerations	78
       G.4.2 PSOA Ground Rules Considerations	78
       G.4.3 PSOA Team Documentation	79
    G.5 STEP 3:Characterize Process	79
       G.5.1 Review of Process Description/Background Information	79
       G.5.2 Develop the Process Flow Diagram	79
       G.5.3 Review of the Process Diagram	82
    G.6 STEP 4: Select Opportunity	83
    G.7 STEP 5: Root Cause Analysis of Selected Opportunity	83
       G.7.1 Identifying the "Effect"	84
       G.7.2 Identifying "Causes" for the Effect	84
       G.7.3 The "People" Cause Category	84
       G.7.4 The "Tools & Equipment" Cause Category	84
       G.7.5 The "Materials" Cause Category	84
       G.7.6 The "Methods" Cause Category	84
       G.7.7 Completing the Cause Identification Process	84
       G.7.8 Analysis Documentation	85
    G.8 STEP 6: Develop Potential Solutions	85
       G.8.1 Identifying Solutions	85
       G.8.2 Solution Categories	86
       G.8.3 Initial Prioritization of Solutions	86
       G.8.4 Follow-on Actions for Recommended Solutions	87
    G.9 STEP 7: Draft Action Plan for Solutions	88
       G.9.1 Decision Maker Coordination	88
       G.9.2 Follow-on Actions	88

APPENDIX G1  PSOA WORKSHEETS	90

APPENDIX G2 RESOURCES FOR PSOA BACKGROUND DEVELOPMENT	109

APPENDIX G3 OTHER RESOURCES FOR PSOA BACKGROUND DATA/INFORMATION	111

APPENDIX G4 PSOA SAMPLE PROCESS OWNER/DECISION MAKER PRESENTATION	112

APPENDIX G5 EC COST/RISK DECISION TREE DIAGRAM	124

APPENDIX H ALLOWABLE PSG NAMES	125
  AFMC	Page iii

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                                                        CTP2 Implementation Guide

                                                                              29 Jun  2001

                                                                              Interim  Final

                                    LIST OF FIGURES

Figure 1:  Environmental Management Hierarchy	1
Figure 2:  CTP2 Cycle	3
Figure 3:  PSOA Solution Selection Tool Macro Warning Screen	53
Figure 4:  PSOA Solution Selection Tool Automatic Links Selection Screen	53
Figure 5:  PSOA Solution Selection Tool Start Menu	54
Figure 6:  PSOA Solution Selection Tool Work Data Worksheet	55
Figure 7:  PSOA Solution Selection Tool Paste Special Menu	56
Figure 8:  PSOA Solution Selection Tool "Work Data" Worksheet Start Menu Return	58
Figure 9:  PSOA Solution Selection Tool: Loading Solution Data (Start Menu)	59
Figure 10:  PSOA Solution Selection Tool "Inputs" Worksheet	60
Figure 11  PSOA Solution Selection Tool Clear Solution Data Option	61
Figure 12 PSOA Solution Selection Tool Loading Common EC Cost and Risk Data	61
Figure 13 PSOA Solution Selection Tool Copying Solution Titles from PSOA Worksheet WS-6D	62
Figure 14 PSOA Solution Selection Tool Pasting Solution Titles in "Inputs" Worksheet	63
Figure 15 PSOA Solution Selection Tool Copying Other Solution Data from PSOA Worksheet WS-6D	63
Figure 16 PSOA Solution Selection Tool Pasting Other Solution  Data in "Inputs" Worksheet	64
Figure 17 PSOA Solution Selection Tool Solution Ranking (Start Menu)	65
Figure 18 PSOA Solution Selection Tool "Solution_Rank" Worksheet	66
Figure 19 PSOA Solution Selection Tool Macro Pop Up Window	68
Figure 20 Block Flow Diagram (Top-Level), Vehicle Maintenance	80
Figure 21  Block Flow Diagram(First Sub-Level), Vehicle Maintenance Step 2 (Maintenance Shop)	80
Figure 22 Block Flow Diagram (Second Sub-Level), Chrome Plating Step 1.2 (Strip Old Plating From Part)... 80
Figure 23 Block Flow Diagram (Summary), Chrome Plating	81
Figure 24 Block Flow Diagram (Predecessor Level) Chrome Plating Operations	81
Figure 25 Process Step Details Vehicle Mantenance Step 5.4 (Paint)	82
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                                     LIST OF TABLES

Table 1: AFI 32-7080 Compliance Cost Ranking	15
Table 2: AFI 32-7080 Compliance Burden Levels as a Function of Risk Level and Cost Rank	16
Table 3: Installation ACES-PM Codes	32
Table 4: Site Type = AST Include/Exclude Criteria	33
Table 5: Site Type = Air Sources Include/Exclude Criteria	33
Table 6: Site Type = Drinking Water Include/ Exclude Table	34
Table 7: Site Type = EPCRA Include/Exclude Criteria	34
Table 8: Site Type = HAZWASTE Management Include/Exclude Criteria	34
Table 9: Site Type = Landfills Include/Exclude Criteria	34
Table 10: Site Type = RCRA Cleanup Include/Exclude Criteria	35
Table 11: Site Type = UST Include/Exclude Criteria	35
Table 12: Site Type = Waste Water, Storm Water Include/Exclude Criteria	35
Table 13: Allowable Compliance Site Categories	36
Table 14: Allowable Compliance Site Descriptions	38
Table 15: Allowable Compliance Site Type, Categories, and Descriptions	39
Table 16: Risk Algorithm Element Risk Score/Rank, Cp, Permits/Registration Scoring Matrix	42
Table 17: Risk Score/Rank, CN, NOV Has Been Issued Scoring Matrix	42
Table 18: Risk Score/Rank, Ci, Reportable Incident Scoring Matrix	43
Table 19: Risk Score/Rank, CK, Inspections/Record-Keeping Performed Scoring Matrix	43
Table 20: Risk Score/Rank, CR, Reports Required Scoring Matrix	43
Table 21: Risk Score/Rank, FWF, Future  Regulatory Impact Scoring Matrix	43
Table 22: Risk Score/Rank, HWF, Hazard Weighing Factor Scoring Matrix	44
Table 23: Risk Score/Rank, MWF, Mobility Weighing Factor Scoring Matrix	44
Table 24: Risk Score/Rank, PWF, Proximity Weighing Factor Scoring Matrix	45
Table 25: Risk Score/Rank, RWF, Release Weighing Factor Scoring Matrix	45
Table 26: Risk Score/Rank, EWM, Worker Exposure Weighing Matrix	46
Table 27: Risk Score/Rank, OAM, Operational Complexity Additive Matrix	47
Table 28: Risk Score/Rank, NAM, Container Additive Matrix	47
Table 29: Risk Score/Rank, LAM, Containment Additive Matrix	48
Table 30: AFI 32-7080 Reporting Risk Levels	48
Table 31: PSOA Solution Selection Worksheets	52
Table 32: CSI Reference Changes in PSOA Solution Selection "Work_Data" Worksheet	57
Table 33: PSOA Solution Selection Current Process EC Cost Rank Scoring	69
Table 34: PSOA Solution Selection Percent Savings Scoring	70
Table 35: PSOA Solution Selection Current Process EC Risk Score Rank Scoring	70
Table 36: PSOA Solution Selection Percent Reduction in Process EC Risk Score Scoring	71
Table 37: PSOA Solution Selection Current Process EC Burden Rank  Scoring	71
Table 38: PSOA Solution Selection New  Process EC Burden Rank Scoring	71
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                                    PREFACE

This document is intended to provide all of the information required to fully understand and implement
the  Air  Force  Materiel Command's  (AFMC) Compliance Through  Pollution  Prevention (CTP2)
environmental management strategy.   It is designed to become a web-based  resource for AFMC
installations to which appropriate links can be constructed  in the CTP2 Management Action  Plans
(MAP).
For ease of use, the Process Specific  Opportunity Assessment (PSOA) Guidance has been included
as an easily detachable self-supporting document in Appendix G.
The   principal  user  of  the  document  should  be  AFMC   installation  level  personnel.
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                                             1
    INTRODUCTION TO AFMC'S  COMPLIANCE THROUGH POLLUTION
                PREVENTION  (CTP2) PROCESS AND CONCEPTS

    1.1  CTP2 DEFINITION

CTP2 is an environmental management strategy designed  by  AFMC.   It sustains and enhances
mission  readiness by implementing sound cost-effective strategies for complying with existing or new
environmental requirements while minimizing or eliminating potential hazards to human health and the
environment.  CTP2 focuses  on the use of pollution prevention  (P2) as the preferred approach for
assuring environmental compliance (EC).  CTP2 is not an environmental management system (EMS)
in  that   it  does not  address  all  of  the environmental "pillars" such  as  restoration  and
conservation/stewardship.
Both AFMC and the Air Force are aggressively working to break down the artificial  barriers preventing
the integration of P2 and EC.  Traditional schools of thought with  compliance as "must-do" and P2 as
"nice to  do" have driven  investment towards  end-of-pipe treatment and disposal.  The reality is that
"compliance" with laws,  regulations,  and policies is  the ultimate objective and cost-effective P2
solutions should  be  preferred over treatment and disposal, whenever possible.  This is exactly the
intent  of Executive Order 131481.  Less pollution,  improved processes, and reduced costs make for
good business.
As shown  in the Environmental  Management
Hierarchy, pollution  prevention, which  is also
known as source reduction, followed by reuse /
recycle,  and then treatment  /  disposal  is the
preferred approach  to achieving  cost-effective
environmental  compliance.    AFPD   32-702
states,   "The    Air   Force    is   committed
to...eliminating  pollution whenever  possible."
Pollution prevention  reduces total ownership
costs  (TOC),  compliance  requirements,  and
pollutant discharges by addressing pollution  at
the source.
                       Figure 1:  Environmental Management Hierarchy
However, P2 solutions are not always easy. To properly identify them takes commitment from the civil
engineer (CE) community and other process owners  (such as XP,  DO, LG, SG,  EM and  single
managers).  Since weapon systems drive most AFMC  environmental  compliance costs, many cost-
effective  P2  solutions  will  involve changes to fielded weapon system  design,  operations, or
maintenance. It will take a concerted effort of all communities to identify and budget P2 solutions into
their respective Program Elements.
It  is critical  to  apply  the AFMC  Environmental Management  Hierarchy  to every  environmental
compliance requirement and evaluate alternatives from a "best business" approach.  To achieve this,
it is vital for  installations  to program effectively.  The Air Force fully supports all level 1 compliance
requirements.   However, there  are two  paths  to  achieve compliance: the  standard compliance
approach (end-of-pipe) or a long-term P2 approach (process-oriented).
 Executive Order 13148 of April 21, 2000, "Greening the Government Through Leadership in Environmental
Management."
2 AFPD 32-70, "Environmental Quality," 20 July 1994.
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The CTP2  process applies the environmental  management hierarchy to  select P2 solutions that
achieve environmental compliance while reducing  compliance  cost  and  risk,  improving  mission
performance, and reducing any other compliance requirement.  Installations  should thoroughly review
P2 and EC programs  for opportunities to  eliminate compliance drivers and focus on compliance
burden reduction by identifying cost-effective solutions, which are highest  on  the  environmental
management hierarchy.
The CTP2 approach instills the "compliance through P2" ethic into all AFMC environmentally regulated
processes.  It  is a truly  innovative investment  strategy to evaluate and invest  in P2 solutions for
compliance driven requirements.

    1.2 AFMC CTP2 MISSION STATEMENT3

According to HQ AFMC/ CEV, the mission of CTP2 is:
                                 CTP2 Mission Statement
     Sustain and enhance mission readiness by implementing sound cost-effective strategies for
     complying with existing or new environmental requirements while minimizing or eliminating
                    potential hazards to human health and the environment.
    1.3 AFMC CTP2 GOALS4

•   Document the correlation between the installation's environmental burden and the base activities
    using the Compliance Site Inventory (CSI)
•   Develop an initial  multi-year investment strategy  to target efforts to  reduce  the installation's
    environmental burden and improve operations
•   Implement  a process to define opportunities and implement cost-effective alternatives to reduce
    compliance burden and improve operations
•   Implement  a process to adjust the investment strategy based on completed environmental burden
    reduction efforts and changing requirements

    1.4 CTP2 RELATIONSHIP TO AFI 32-7080

CTP2,  as developed  by AFMC, supports the requirements of the draft AFI 32-7080:  Compliance
Assurance and Pollution Prevention .  It differs somewhat from the form and structure of the AFI  in
that it is  more  detailed and tailored for the unique business structure of AFMC. AFMC developed
CTP2 prior to  the revision of the AFI that  institutionalized the strategy for the Air Force.  CTP2
concepts     have     subsequently     been    embraced     by    the    other    services.
3 Boucher, Michael N., Lt Col HQ AFMC/CEVV, recent guidance, dated: 5 Dec 2000, Subject: CAP MAP Update
4 Ibid
5 AFI 32-7080 "Compliance Assurance and Pollution Prevention," 26 May 2000 draft.


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                                 THE CTP2 CYCLE
The CTP2 cycle contains eight elements designed to facilitate the installation's ability to perform all of
the steps necessary to  successfully implement  pollution  prevention  initiatives that will ultimately
reduce compliance costs  and risks. The elements contained in the process are listed below.
                  1)     Compliance Site Identification
                  2)     Burden Determination
                  3)     Compliance Site Grouping
                  4)     Group Prioritization
                  5)     Process Specific Opportunity Assessment (PSOA)
                  6)     Solution Planning & Programming
                  7)     CTP2 Solution Implementation
                  8)     CTP2 Solution Evaluation
                       Solution
                      Evaluation
                                   Compliance
                                        Site
                                   Identification
                   Solution
               Implementation
                                      MAP
St
    Burden
Determination

    Compliance Site
       Grouping
                     Solution
                   Planning &
                  Programming
       Group
   Prioritization
                                 Process Specific
                                   Opportunity
                                  Assessments
 *
                                 Figure 2: CTP2 Cycle
The CTP2 process,  graphically  depicted above,  supports tracking  of progress toward  identified
targets, aids in investment decision-making, and contains all of the necessary tools to complete the
tasks.  The first two elements build or make changes to the existing CSI.  Elements 3, 4 and 5
recommend and  select solutions  based upon the rate  of return  on  investments,  reduction  in
compliance costs, and reduction in  risks. Elements 6 and 7 contain the steps and forms needed  to
plan  and  program  a  solution,  put  together  an  implementation  plan,  and carry  out  actual
implementation.  Element 8 provides for the evaluation of the solution after being fully implemented.
Finally, the CTP2  MAP ties the  entire process together.  More information about each of these
elements is in subsequent sections.
All of the  CTP2 cycle elements produce data and  documentation that contribute to an installation's
CTP2 MAP and detail  how the  installation intends to accomplish its stated CTP2 goals.  These
outputs include, but are not limited to: applicable regulatory drivers, installation strategies, compliance
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site cost and risk baselines, identified actions, investment plans, and progress tracking systems. The
CTP2 MAP for each installation consists of the following information/data.
•  Installation Strategy
•  CSI
•  Process Specific Groups
•  PSOA
•  PSOA Solutions

I
I Co
I PSOA Solutions Planning
I AFMCPSOAs
Process Specific Groups
Installation Strategy
ttoliance Site Inventor*
CTP2
Management Action
Plan


-
-
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                                      CTP2 TEAM
To be effective, a CTP2 team should be formed with overall responsibility for CTP2 functions.

    3.1  CTP2 TEAM RESPONSIBILITY

The CTP2 Team's responsibilities include:
•   Conduct   the   installation's   CTP2    Process
    and  prepare the CTP2 MAP
•   Set   and   update   installation    CTP2   strategy
    and  local priorities as necessary
•   Provide   oversight   (reality  checks)   for  the
    PSOA teams

    3.2  ESTABLISHING THE CTP2 TEAM

API 32-7080  states that, "Integrated pollution  prevention  management  (procedures,  education,
training,  and funding)  at MAJCOM level is  vital  to successful  program  execution."   Installation
commanders, working through their Environmental Protection Committees  (EPC) or Environment,
Safety, and Occupational Health Committees (ESOHC) should establish an effective, integrated, and
cross-functional CTP2 Team.  As team members are identified, they will assume the responsibility of
completing the final list of team members based on the range of skills needed  and all further tasks.

    3.3  FINALIZING THE CTP2  TEAM

CTP2 team members and overseers are responsible for finalizing the team by identifying missing skill
sets and bringing in additional team members or resources as needed. As this process of finalizing
team  members gets under way, the  CTP2 team  will be responsible for developing a  timeline of
activities and contact  information.  Upon  recognition of the tasks to be completed by  each  team
member, activities will be completed  parallel to each other when possible.  Prior to beginning the
CTP2 process, or even continuing through further steps in the process, it is  important to  review and
build a working team that embodies all of the necessary skills to complete the tasks. Depending on
installation size, mission complexity, personnel  skills availability,  and need for contractor support, the
team should be composed of representatives from the following organizations.
•   Environmental Management
•   Bioenvironmental Engineering
•   Logistics
•   Civil Engineering
•   Safety
•   Product Center & Systems Engineering Representatives (as applicable)

    3.4  CHECKLIST OF CTP2 TEAM SKILLS AND RESPONSIBILITIES

The following checklist of skills for team members should be considered in order to develop the CTP2
Team.  Potential team members most likely include the installation's existing  Hazardous Materials
Management Program  (HMMP) team.  However, the CTP2 team may require skills in  addition to
those already represented on the HMMP team.  Once team members  have  been identified, their
names,  specific responsibilities and contact  information  become  part of the Installation Strategy
information for all CTP2 Team members to access. This list should be updated as changes occur to
the installation operations, mission requirements, pollution prevention priorities, regulatory compliance
requirements or installation staffing changes that may require a modified skill set, or to fill in any
unforeseen gaps.
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       3.4.1  CTP2 Team Skills
    •   Process or operational activity/task definition
    •   Process and environmental cost analysis
    •   Regulatory (environmental especially, but also safety and occupational health) requirements
       and compliance management
    •   Project planning
    •   Process engineering
    •   Environmental and safety engineering
       3.4.2  CTP2 Team Responsibilities
    •   Provide guidance and oversight for execution of all CTP2 steps and requirements
    •   Develop installation goals and build the strategy statement
    •   Develop annual timeline for the conduct of CTP2 activities
    •   Gather or coordinate the collection,  updating and/or validation  of compliance site inventory
       data
    •   Support and validate inclusion of cost and risk information in the compliance burdens
    •   Identify and apply relevant local criteria influencing CTP2 priorities
    •   Implement a strategy for grouping compliance sites and identifying candidate processes or
       operational activities for improvement
    •   Group compliance site, target processes and prioritize the groups for PSOAs
    •   Identify required capabilities and form individual PSOA teams
    •   Work  with the individual teams to plan and schedule PSOAs
    •   Assist PSOA teams in developing  sub-contract Statement of Work (SOW) for complex
       PSOAs requiring external contractor support
    •   Oversee and coordinate the PSOA process across the installation
    •   Develop a category-specific action plan for CTP2 solution selection
    •   Work  with the PSOA teams to perform CTP2 solution selection
    •   Develop the necessary information for incorporating CTP2-based  solutions into the  project
       planning and budgeting process
    •   Provide guidance and support for  next-generation  P2 technology integration into  future
       projects
    •   Develop planning and funding plans for the selected CTP2 solutions
    •   Implement the identified cost-effective CTP2 solutions
    •   Establish effectiveness indicators and monitor the success of the CTP2 process
    •   Address environment, health, and safety information with all planned milestones
    •   Provide financial management to the  defined efforts
    •   Analyze benefits accrued from P2 initiatives
    3.5 CTP2 TEAM CONTACT INFORMATION
In order to facilitate communication, contact information for each team member should be included as
part of the Installation Strategy information of the CTP2 MAP.
    3.6 OVERALL CTP2 TEAM TASKS/ DELIVERABLES
•   Review the  overall policy and regulatory drivers to  understand the installation's  environmental
    requirements and goals and how the CTP2 process would work within that context
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•   Develop the installation's strategy and provide a basis for the management action plan so that all
    members will understand the installation's specific goals. This strategy should be disseminated to
    all team members periodically to reinforce installation specific goals.
•   Determine concurrent schedule to implement the CTP2 process. This includes a timeline with all
    tasks,  subtasks, and milestones to complete the CTP2 cycle.  This timeline will include tasks
    linked to responsible individuals in order to enforce accountability.
The CTP2 team is responsible for various elements of the CTP2 cycle.  This team will be responsible
for  establishing multiple PSOA teams having  the  primary responsibility to conduct the  PSOAs.
However, there may be cross-linked members of both sets  of teams, and each team should utilize the
skill set of the  other if needed.  The CTP2 Team is ultimately  responsible for completing all of the
elements defined under the CTP2 process.
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                   CTP2 MANAGEMENT ACTION PLAN (MAP)
An Installation's CTP2  MAP is the defining document for that installation's CTP2 strategy.  It defines
the current state of EC  burden at the installation in the CSI; it states the installation's annual objectives
and long-term goals towards reducing EC burden; and it specifies the strategy the installation intends
to take to achieve the goals and objectives.  The strategy is defined in terms of which PSOAs will be
conducted and when, the funding needed to implement PSOA identified solutions in a yearly schedule,
the supporting R&D required, as well as the DEM VAL support required.
The CTP2 MAP is dynamic because it is updated  as the supporting information  is updated.  It fully
communicates the installation's P2  requirements to HQ AFMC/CEV  and serves as their basis
document to justify requirements to Air Staff.  Some elements of the CTP2 MAP are more dynamic
and change more frequently than others.  For example, specific information  on individual compliance
sites should be updated as that information becomes available.  Other information such as goals and
objectives may only change on an annual basis.
The CTP2 MAP drives the CTP2 process for each installation.  Though the structure is the same,
each installation has its own unique CTP2 MAP containing information specific to that installation.

   4.1 WHAT TO DO FIRST

•  Understand the relevant Air Force Instruction (AFI) and regulatory drivers because they will affect
   strategic planning and compliance considerations
•  Become familiar with additional local, state, and regional laws and regulations, or new federal
   regulations that may affect your strategy and the installation's approach to implementation
•  Consider the Air Force compliance and pollution  prevention (CAPP) goals identified in AFI 32-
   7080 when developing the installation's overall CTP2 strategy. Consider ways to attain these AFI
   goals and ways of measuring progress toward these goals.
       "Comply with all applicable environmental laws, regulations, and requirements"
       "Reduce compliance burden (the combination of environmental compliance costs and  ESOH
       risks)"
       "Reduce Total Ownership Costs (TOC)"
       "Improve mission capability"
       "Permeate the CTP2 program to all mission areas through comprehensive education, training,
       and awareness  of the CTP2 process"
       "Institutionalize the program into all phases of the weapon system (WS) life cycle from concept
       exploration through operations, sustainment, and disposal"
       "Incorporate the CTP2 process into all aspects of installation operations"
       "Transition innovative P2 technologies to the field."
•  Consider AFMC's Business Goals, which include gathering costs associated with processes and
   activities.

   4.2 INSTALLATION SPECIFIC BACKGROUND INFORMATION

Background information helps define local considerations, which make  each installation unique.  It
includes but is not limited to the following
•  Mission(s): Include current as well as  any projected changes.
•  Tenant Organizations: Include current as well as projected changes.
•  Regulatory Climate and Regulatory  Agencies  by Media:  Identify by media where the federal
   government has delegated  primacy and identify those regulatory  agencies  that have been
   particularly aggressive in enforcement
       Federal
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   -  State
      County
      Municipality
•   Recent major and significant ECAMP Findings only
•   NOVs in the prior 5 years
•   News Media Issues: Any ESOH related issues receiving local news media attention
•   Compliance Site Trends:
      EC Recurring Cost for prior 5 years
   -  Total number of compliance sites
      Number and cost of compliance sites by type

    4.3  CTP2 TEAM MEMBERS

Information (name,  organization  and contact data) for the lead  CTP2 Team member should be
identified and included as part of the Installation Strategy information.  Information  about the other
CTP2 Team Member(s) can also be included in the Installation Strategy information.

    4.4  INSTALLATION CTP2 GOALS AND OBJECTIVES

Installation CTP2 Goals: should  clearly state what the installation envisions CTP2 can ultimately
achieve. Remember, even with the most aggressive program, environmental
compliance sites and costs cannot be eliminated.  However, it is reasonable to
set a goal to reach a specified level by a given date.
Installation CTP2 Objectives: should be viewed as annual milestones, which if
met on time, would lead to the achievement of the CTP2 Goals.
A hypothetical example of a CTP2 Goal might be to reduce compliance costs
by 50% within 5 years.  A CTP2 Objective toward meeting that goal could then
be a 10% reduction  in compliance costs annually.
Another  goal might  be to  reduce compliance risk by a given percentage within
a specified time, and the corresponding objective toward meeting that goal
would then be a  minimum percentage reduction in risk annually.
                  "Goals" are what one is trying to ultimately achieve.

             "Objectives" are the intermediate steps that must be achieved
                               in order to attain a "Goal."
Both the Installation  CTP2 Goals and  the  Installation CTP2  Objectives are maintained  in the
Installation Strategy information.

    4.5 INSTALLATION CTP2 STRATEGY

The installation strategy ties closely to the Installation CTP2 Objectives but also incorporates flexibility
to bring in more qualitative elements.  An example of a qualitative element might be to investigate
opportunities to find alternative operation and maintenance (O&M) funding. The qualitative data in the
Installation Strategy includes:
•   CSI Review Interval:  the frequency of reviewing and updating the  CSI (in Installation Strategy
    information)
•   EC Cost Update Date: the actual date by fiscal year (FY) that the EC costs in the CSI for the prior
    year are archived and the data from the just completed  FY is included in Installation Strategy
    information
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•   PSG  Review Date:  the actual date that the PSG information is reviewed to determine if the
    contents are still valid and whether or not some groups should  be deleted and/or new  PSGs
    added (in Installation Strategy information)
•   PSG  Prioritization Review Date: the actual date that the PSG  Burden Priorities contained in the
    PSG  information are reviewed and adjusted as needed (in Installation Strategy information),
•   PSOA Scheduled is the FY in which a specific PSOA is scheduled (in PSG information)
•   PSOA Estimated Cost is the  installation's estimate of the funds required to complete a specific
    PSOA (in PSG information)

•   Selected Solution  FY is the FY for which installation is requesting HQ AFMC
    CEV  funding to implement a  particular solution  (in  PSOA  Solutions
    information)
•   Required Solution Funding defines the funds required  by FY to implement a
    solution (in PSOA Solutions information)
The  CTP2 Team  should  periodically  review  the  contents  of  all  the  CTP2
information/data, in particular, the  PSOA Solutions information because it contains
all of the information required by HQ AFMC/CEVto determine how much funding a
specific installation requires by FY to implement  P2 solutions that reduce EC burden
the installation's R&D and DEM VAL requirements

    4.6 CTP2 EXECUTIVE SUMMARY
It also defines
A  printout  of the  Executive Summary of the  CTP2 MAP  can be  used for discussions with
management, regulatory agencies, and other interested parties.  It includes all of the information in
sections 4.1 -  4.5 plus  summary statistics  about the  CSI, PSG,  and  PSOA Solutions data.
Summaries of key HQ AFMC/CEV information  should also be included along with prior year(s)
expenditures and anticipated future expenditures by FY.
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                                            5
                      COMPLIANCE SITE IDENTIFICATION

    5.1 WHAT is A COMPLIANCE SITE

API 32-7080 defines compliance sites as follows: "A compliance site is any regulated facility, regulated
process, or a discharge to a regulated facility or process. This includes any discrete location under Air
Force control wherein activity occurs that is subject to current or known future (resulting in known
consequences) federal, state, and local statutes and regulations; E.O.s; DoD and  Air Force policies;
and the OEBGD, FGSs and international agreements."  A Compliance Site is the physical location
where determination  of compliance/non-compliance with an environmental law or regulation can be
made.  Its existence is determined first based on  an  applicable existing  regulatory standard, and
second on a definable physical location.
All installation compliance sites should be included if they are the responsibility of the installation
commander. Exceptions include non-DOD agencies holding their own environmental permits on out-
granted, permitted use or non-DOD owned property.
Small sites may be grouped together if they are managed as a group in  keeping with the controlling
regulatory authority.

    5.2 GENERAL INFORMATION ON COMPLIANCE SITES

Compliance Sites are defined in a manner to break compliance activities into the smallest possible
units.  That gives  installations the  greatest  possible latitude  in  grouping  compliance sites  in
preparation for conducting Process Specific Opportunity Assessments. Any grouping should include
all related compliance  sites.   For more  information on grouping, see  Compliance Site Grouping
(Section 7) and Group Prioritization (Section 8).
For program consistency, it is worthwhile to have only one person manage the CSI information/data.

    5.3 CTP2 APPLICABLE ENVIRONMENTAL LAWS

For Compliance Site Identification, applicable environmental laws include the following federal  laws,
their amendments, and associated state or local  regulations:
•   Clean Air Act (CAA)
•   Clean Water Act (CWA)

•   Emergency Planning and Community Right to Know Act (EPCRA)        j—  ^
•   Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
•   Oil Pollution Act (OPA)
•   Resource  Conservation  and Recovery Act  (RCRA)  to include
    Military Munitions Rule.
•   Safe Drinking Water Act (SDWA)

    5.4 CTP2 EXCLUDED ENVIRONMENTAL  LAWS

The following laws are not currently part of CSI:
•   Asbestos School  Hazard Abatement Act
•   Coastal Zone Management Act
•   Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)
•   Endangered Species Act (ESA)
•   Hazardous Materials Transportation Act
•   Indoor Radon Abatement Act
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•   Lead Contamination Control Act
•   Lead-Based Paint Poisoning Prevention Act
•   Marine Protection, Research, and Sanctuaries Act
•   Medical Waste Tracking Act
•   National Environmental Policy Act of 1969 (NEPA)
•   Shore Protection Act
•   Shoreline Erosion Protection Act
•   Solid Waste Disposal Act
•   Superfund Amendments and  Reauthorization Act (SARA)
•   Toxic Substances Control Act (TSCA)
    5.5 COMPLIANCE SITE PHYSICAL LOCATION
A compliance site is the physical  location where determination of compliance/non-compliance with an
environmental law or regulation can be made. Its existence is determined first based on an applicable
existing regulatory standard, and second on a definable physical location.  Locations of compliance
sites include the following:
•   A facility (e.g., a waste treatment storage, or disposal facility)
•   A process (e.g., painting, fueling)
•   The end of a pipe (e.g. an outfall, a stack)
There may be multiple compliance sites at one location. For example, a plating line can be permitted
under the Clean Air Act as well as the Resource Conservation and  Recovery Act.  It would then be
designated as two compliance sites. Consider the following types:
•   Air sources (as defined under Title V permit of CAA)
•   HAZWASTE management  sites  (including initial accumulation points, 90-day accumulation sites,
    treatment, storage, and disposal facilities as defined under RCRA subpart B, but not OSHA or IRP
    sites)
•   RCRA cleanup sites (RCRA subpart B)
•   USTs and ASTs
•   Drinking water
•   Wastewater and Storm water
•   EPCRA sites
•   Pesticides
•   Landfills
•   Open burn/detonation (RCRA Subpart X)
•   "Permit-by-rule" as deemed by various states
All installation compliance sites should be included in the inventory if they are the responsibility of the
installation commander.   Exceptions include  non-DoD agencies holding  their  own environmental
permits on out-granted, permitted use or non-DoD owned property.
Some states include sources by means of "permit by rule" without formally identifying the source.
These should be counted as compliance sites because the existence of the permitted activity creates
an environmental risk. Small sites may be lumped together if they are managed as a group in keeping
with the controlling regulatory authority.
Not all environmental compliance activity can  be associated with a compliance site.  For instance,
requirements to  maximize the  use of recycled materials cannot be  associated with a  specific
compliance  site.
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    5.6 TOOLS TO DETERMINE COMPLIANCE SITES
In order to assure that compliance site designation is accurate and complete, it is important to locate
all of the compliance sites.  Tools to aid in the collection of site information may include the following:
•   Component plans
•   EPCRA documentation
•   Media plans
•   Environmental permits
•   ECAMP findings
•   Safety inspections
•   Bioenvironmental engineering activity evaluations
•   NEPA documentation
•   Notice of violations
•   Environmental information files (e.g. WIMS, APIMS, etc.).
    5.7 COMPLIANCE SITE  INVENTORY
Detailed information on each compliance site is stored in the Compliance Site Inventory (CSI). Details
are  provided in Appendix A.  Compliance site information should be updated on  a real time basis
whenever:
•  A new compliance site is identified,
•  An existing compliance site is no longer valid, or
•  Any non-cost information on an existing compliance is determined to be incorrect.
In  addition, recurring costs should be updated annually based on the EC obligated budget.  See
Appendix B for additional information.
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                                            6
                COMPLIANCE SITE BURDEN DETERMINATION
Compliance Site Burden  is comprised of two elements: Environmental Compliance Cost and Risk.
Together, they form Burden.  Each compliance site  has  its own cost, risk, and burden  which are
determined according to the following guidelines.

    6.1  COMPLIANCE SITE COSTS

CTP2 defines the following four types of compliance site costs.
•   EC Recurring Costs  are those that recur on a predictable cycle such as
    every year and  are identified line  items in the Environmental Management
    (EM) EC obligated budget. An example would be the cost of a particular air
    permit.

•   Non-EC Recurring Costs, OH are  recurring costs associated with the site that are incurred as part
    of Occupational Health surveillance.  An  example would  be  the cost for personal  protective
    Equipment.
•   Non-EC Recurring Cost, Other would be any other recurring cost (i.e., environmental costs funded
    by CE, Defense Military Activity Group (DMAG), DRMO and others)  associated with  that
    compliance site.
•   One-Time EC Cost is a cost that may appear in the EC obligated budget but does not  recur on a
    predictable cycle.

    6.2 DETERMINING EC RECURRING COSTS

EC Recurring Costs are derived  from  costs  in the EC Obligated  Budget that is available at the end of
each fiscal  year.   Only  obligated costs  are used because they do not change.   For  a detailed
explanation of how costs are assigned to a compliance site, see Appendix B.

    6.3 COMPLIANCE SITE INVENTORY COMPLIANCE SITE COST FIELDS

•   EC  Recurring  Cost (k$/yr), Assigned  by Site: This  includes  environmental compliance (EC)
    recurring costs assigned to that specific compliance site.
•   EC Recurring Cost (k$/yr), Assigned by Type/Cat/Desc: This amount includes EC recurring costs
    actually assigned to that compliance site type, category, and/or description.
•   EC Recurring Cost (k$/yr), Annualized: These are identified EC costs which recur on a greater
    than 1-year interval. An example would be a Title  V air permit that must be paid every five years.
    One-fifth of that cost would be entered here.
•   EC Recurring Cost (k$/yr), Residual: For some EC Recurring Costs, there is no basis to  assign
    them to a specific  compliance site type/category/description. An example would be some TOY
    Costs.    These  costs are   distributed  equally  to  all  compliance   sites  regardless  of
    type/category/description and called "Residual" costs.
•   EC Recurring Cost  (k$/yr), Total: This is the sum of the four EC Recurring Cost elements
      EC Recurring Cost (k$/yr), Assigned  by Site
      EC Recurring Cost (k$/yr), Assigned  by Type/Cat/Desc
      EC Recurring Cost (k$/yr), Annualized
   -  EC Recurring Cost (k$/yr), Residual
•   Non-EC Recurring Cost (k$/yr), OH: This cost represents any identified occupational health costs
    that could be assigned to the site. An  example would be the annual cost of providing personal
    protective equipment.
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•   Non-EC Recurring Cost (k$/yr), Other:  Recognizing that EC Recurring Costs are  often only a
    small portion of the total ownership cost associated with a compliance site, this includes any other
    readily identifiable costs.  These costs may have been obtained from organizations  such as CE,
    DMAG or DRMO.
•   One-Time EC Cost (k$): Where the budget contained one-time costs that could be assigned to a
    specific site or group of sites, those costs are included for information purposes only.
•   API  32-7080 Reporting, Cost Percentile (%): This  is the percentile for the site's EC Recurring
    Cost, Total. High cost items are denoted by high percentiles.
•   API  32-7080 Reporting, Cost Ranking: The cost percentiles are divided into quintiles from top to
    bottom  and assigned  highest, high, medium, low, or lowest rankings as  shown in the following
    table.
                              Cost Percentile    Cost Ranking
                                81 - 100%         Highest
                                 61 - 80%           High
                                 41 - 60%         Medium
                                 21 - 40%           Low
                                 0 - 20%          Lowest
                       Table 1: AFT 32-7080 Compliance Cost Ranking

    6.4 MAINTAINING COMPLIANCE SITE COST INFORMATION IN THE CSI

Compliance site cost information should  be updated only once a year after the EC Obligated budget
for the prior fiscal year is  available.  At that time, the prior year's cost information should be purged
from the system and the new fiscal year's obligated budget values entered.  At the same time, the CSI
should be archived with an identifier for the appropriate fiscal year.  A copy of that CSI should then be
used  as a  working copy through the  next fiscal year to track  any changes  in compliance site
identification information.

    6.5 COMPLIANCE SITE RISK

A risk algorithm provides guidance to the CTP2 team during the
compliance  site  risk  assessment  process to  calculate  a
comparative risk for each compliance site based upon  the core
components  of  Risk  -  Hazard,  Exposure,   Severity and
Probability.  Detailed knowledge of the specific compliance sites
is critical in this step.  Therefore, it is very important to involve
individuals associated with those specific site categories.  For
example, it is recommended  that for the "underground storage
tanks" (USTs) compliance site  category, as  many  individuals
(and their files)  as  possible  having  knowledge  / expertise  be
involved.  Their knowledge/expertise should  be related to  the tanks  location, material(s) stored,
compliance history,  secondary containment, worker traffic near the  tank, etc.   Having this team
together plus actually inspecting representative  tanks will facilitate completing the assessment and
assigning scores in a most efficient manner.  Also, while these experts are together, review the CSI to
see if any compliance sites in their domain have  been missed on the CSI listing and also if any other
categories of the CSI can also be scored at the same time.
In  addition,  linking the CSI  to  all the  related  files on the  installation  leads  to  enhanced Risk
Assessment process efficiency and identification of  any discrepancy in the  CSI  listing  in terms of
unlisted sites etc.
Compliance Site Risk is determined  by  means  of a  unique  quantitative comparative risk algorithm
developed by AFMC. The algorithm is defined in  Appendix C.
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   6.6 COMPLIANCE SITE BURDEN
Compliance Site Burden combines EC Cost and Risk into a single metric.  The two are combined
according to the guidance  provided  in API 32-7080  into four  burden levels: extremely high, high,
medium, and low.

   6.7 MAINTAINING COMPLIANCE SITE RISK INFORMATION IN THE CSI

Compliance site  risk information contained in the CSI should be maintained  in the same manner as
the site identification information. That is to say that when new information is  obtained the CSI should
be updated accordingly. This should be a continuous process as contrasted by the cost information
that is only updated on an annual basis.

   6.8 CSI FIELDS FOR COMPLIANCE SITE BURDEN

There is  only  one CSI element that relates  to compliance site  burden: AFI  32-7080  Reporting,
Compliance Burden Level.  Burden levels are assigned based on cost rankings  and  risk levels
according to the following table.
                                     AFI 32-7080 Reporting, Cost Ranking

oo .52
0 CL
CM g»"i
CO -f 0
I—I ^ ^^
51
*

Extremely
High
High
Medium
Low
Highest
Extremely
High
Extremely
High
High
Medium
High
Extremely
High
High
Medium
Low
Medium
High
High
Medium
Low
Low
High
Medium
Low
Low
Lowest
Medium
Low
Low
Low
   Table 2: AFI 32-7080 Compliance Burden Levels as a Function of Risk Level and Cost Rank
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                                             7
                           COMPLIANCE SITE GROUPING
The objective of this element is to form Process Specific Groups (PSG) of compliance sites that can
be subsequently prioritized and become candidates for PSOAs. A PSG is a single site or a group of
compliance sites formed based on:
•  A common related industrial process, e.g., building 180 chrome plating line,
•  A common owner, e.g., 311th HSW,
•  A common location, e.g., Building 146,
•  The same activity, e.g., All aircraft ground support equipment, or
•  Any other logical grouping that  can produce  an aggregated group  EC burden high enough to
   justify the resources required to  conduct a PSOA.   (For planning purposes, one should assume
   that a PSOA costs no more than  $50,000 to conduct and can be completed within 8 weeks.)
Any one compliance site  may exist in more than  one PSG.   It  is highly recommended that the
industrial process  basis be selected as the subsequent PSOA procedure works best with process
related groups.

   7.1 STEPS FOR COMPLIANCE  SITE GROUPING

Compliance Site Grouping is a stepwise process that begins with the CSI, builds PSGs, and ends with
a rank-ordered list of  PSGs specific  to the installation.  To assure that the subsequent Group
Prioritization process is effective,  it  is  advised that all  logical PSGs be formed during one activity.
Process grouping is best accomplished as a team effort with the following  individuals.
•  Installation CTP2 Coordinator
•  EM media managers
•  Other individuals as required that help to understand the industrial processes at the installation.

       7.1.1 Step 1: Rank Order Compliance Sites
To begin the process, sort the CSI by AFI 32-7080 Reporting, Compliance Burden Level. The existing
CSI can  be sorted by any element.  This will partition the  compliance sites  into one of the four
following categories:
   •   Extremely high,
   •   High,
   •   Medium, or
   •   Low.
At the same time,  it is advisable to obtain information from other resources such as the Air Program
Information Management System (APIMS) and installation specific files. The EM directorate's ACES-
PM listings  of high priority projects for funding should also  be included on the list of evaluation tools.
Previous Opportunity Assessments  and past DEM/VAL projects  may  also be  helpful  resources.
These  resources should be used to gather additional site-specific information for use during the steps
to follow.

       7.1.2 Step 2: Group Compliance Sites
Begin with the sites in the Extremely High category.  Take the first site and determine what process it
supports based on available information  such  as,  site  location, site owner,  or other process
knowledge. Proceed through the list  of compliance sites and identify the next site associated with that
PSG until all compliance  sites associated with that PSG have been identified.  Go back to the
beginning of the  site list,  select the next assigned compliance site and repeat the procedure for
another PSG.  If a site supports more  than one PSG, such  as a shared accumulation  point, try to
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determine all the PSGs it supports.  It may be best to exclude some common sites from the grouping
process,  such  as a  RCRA TSDF,  because these sites  may distort the PSG cost/risk calculation.
Grouping is complete when all compliance sites in the CSI have been examined and added to one or
more PSGs. When all associated sites  have been identified, stop and compute the PSG cost and risk
as follows.  In cases of sites that support more than one PSG, try to distribute the costs to each of the
PSGs on a rational basis.
    •   PSG Cost:
           Sum all of the values in the  EC Recurring Cost (k$/yr), Total column for the compliance
           sites in the PSG. This becomes the PSG EC Recurring Cost (k$/yr.
           Sum all of the values in the  Non-EC Recurring Cost (k$/yr), OH column for the
           compliance sites in the PSG.  This becomes the  Non-EC Recurring Cost (k$/yr), OH
           Sum all of the values in the  Non-EC Recurring Cost (k$/yr), Other column for the
           compliance sites in the PSG.  This becomes the  Non-EC Recurring Cost (k$/yr), Other.
           Sum all of the values in the  One-Time EC Cost (k$) column for the compliance sites in
           the PSG. This becomes the PSG One-Time EC  Cost (k$).
    •   PSG Risk: Identify the highest value for each risk algorithm factor from the sites in the PSG
       and recalculate the risk score using these values.  This becomes the PSG Risk Score.

    7.2 CSI GROUPING

The grouping process is  linked to the CSI and software tools  are built into the CSI to assist the  user.
A user identifies a compliance site as the starting point for a PSG. The user cycles through the CSI
and identifies compliance sites for the potential PSG. After selecting the sites, the user calculates the
cost and the risk for the PSG as indicated above using  the CSI software tools.  At the end of the
process, the user then:
•   Selects a PSG Name according to Appendix H,
•   Collects any Additional Base Specific Information that may help identify the PSG, and
•   Assigns a  unique  PSG Number (installation  ACES-PM  code +  2-digit fiscal  year  +  4  digit
    sequential number assigned by installation) to the PSG.

    7.3 PSG INFORMATION

The grouping process results in the following PSG information/data.
•   PSG Number: This number  is the installation ACES-PM code +  2-digit fiscal year + 4  digit
    sequential number.
•   PSG Name must be selected from the list in Appendix H. PSG names are constrained to facilitate
    searching for prior PSOAs on similar processes.
•   Additional Base Specific Information is additional clarifying  information provided by the installation
    that precisely identifies the subject PSG.
•   Date Created  (dd/mm/yy):  The date the PSG was identified/formed.  This date is used to
    determine whether the PSG is current. Care should be used in starting a PSOA on a PSG whose
    creation date is several months to  a  year old  because  compliance site burden information  may
    have changed significantly.
•   Site Number(s) are the compliance sites included in the PSG
•   PSG EC Recurring Cost (k$/yr) represents the sum  of  the individual compliance site Recurring
    Costs.
•   PSG Non-EC Recurring Cost (k$/yr) represents the sum of the individual compliance site Non-EC
    Recurring Costs.
•   PSG One-Time EC Cost (k$) represents the sum of the individual compliance site One-Time EC
    Costs.
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•  PSG Risk Score is calculated from the highest value for each risk algorithm factor from the sites
   in the PSG.
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                                             8
                              GROUP  PRIORITIZATION
Once the  PSGs  have been formed, the  prioritization process places
them in the appropriate order for PSOAs.

    8.1  STEPS FOR PSG PRIORITIZATION

PSG prioritization is a straightforward three-step process. The first step
is to rank  order the PSGs based upon burden; the second step is to
adjust the  order to allow for "local considerations;" and the third step is
to assign a priority number to each PSG.

       8.1.1 Step 1: Establish PSG Burden Rank
    •   Determine PSG Cost Rank  by sorting the PSGs from highest to lowest based on  PSG EC
       Recurring Cost (k$/yr). Once sorted, calculate a percentile ranking to each PSG. The higher
       the cost, the higher the ranking.
    •   Determine PSG Risk Rank by sorting the PSGs from  highest to lowest based on PSG Risk
       Score. Once sorted,  calculate a percentile ranking to each PSG. The higher the risk score,
       the higher the ranking.
    •   By adding the PSG Cost Rank to  the PSG Risk Rank  and dividing by 2 the user determines
       PSG Burden Rank for each PSG.  The result is the PSG Burden Rank.

       8.1.2 Step 2: Identify, Evaluate, and Address Local Considerations
Local considerations are those issues, which in the installation leadership's view, justify an adjustment
in the PSG Burden Rank. Once local considerations have been applied, the rank ordered list of PSGs
is considered prioritized and ready for the PSOA process.
The  determination of local  considerations is  a  key factor  in  an  installation's overall  CTP2
implementation strategy.    Local consideration  should be  evaluated and addressed to  the  extent
possible at this stage. External  factors such as  local civilian  community associations, regulatory
agencies, etc. have the potential  to influence the type and importance of local considerations.  Some
of the factors that could contribute as local considerations are discussed  below.  This is  by no means
a comprehensive list and others may exist.

           8.1.2.1 MISSION CRITICALITY

       One should be able to quickly ascertain the mission  criticality related to a PSG. Ensure that
       PSGs with a high compliance burden and associated with mission critical activities are
       adequately addressed through the  PSOA process in a timely manner.  Failure to address the
       compliance burden of such a PSG  may lead to interruption of the operational readiness.
       Mission criticality needs to consider the true possibility of an environmental regulatory
       authority stopping a mission.

           8.12.2 ANTICIPATED REGULATORY CHANGES

       Federal, regional, state, and  local regulatory changes or the interpretation of existing rules
       may significantly influence the priority of a PSG. Investigate and recognize the possible
       implications of any forthcoming regulatory changes likely to be introduced and their impact on
       compliance burden levels associated with the compliance site(s) in the PSGs.

           8.12.3 REMAINING DURATION OF PROCESS

       The process owner representative  assisting the team on the earlier consideration could
       provide assistance on this factor. The expected remaining duration of the process is critical to
       the prioritization process as it could influence the priority of a PSG. If the process is nearing
       its end or likely to be discontinued  over the next few years, its priority should be reduced.
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           8.1.2.4 TOTAL OWNERSHIP COST (TOO)

       Total Ownership Cost analysis delineates to the process owner the costs related with
       environment, safety, occupational health and other process related activities. These costs are
       often accounted as overhead expenses and termed as "hidden costs". For example, a
       compliance site with high TOC could be a candidate site to qualify under local consideration to
       be included in the list of candidate PSGs.

           8.12.5 FUNDING OR TECHNOLOGY CONSTRAINTS

       A funding or technology related constraint could be best addressed by continuing to include a
       particular PSG in the initial rank order listing and then evaluating  it during the periodic
       prioritization process. Such constraints may arise from prior PSOAs that identified the
       absence of any viable process improvements.

       8.1.3 Step 3: Set PSG Priority
Having identified, evaluated, and  applied the appropriate local considerations, each PSG should be
assigned a PSG Priority number from 1 to n, where 1 is the highest priority  and n the lowest. Where
local considerations have changed the position of a PSG, the rationale should be noted.

    8.2 PSG INFORMATION

The PSG prioritization process results in the following PSG information/data.
•   PSG Cost Rank is the percentile rank PSG based upon cost.
•   PSG Risk Rank is the percentile rank order of the PSG based upon risk.
•   PSG Burden Rank is the percentile rank order of the PSG based upon burden.
•   PSG Burden Priority:  PSG Burden Rank is adjusted for local considerations to provide the PSG
    Burden Priority, which establishes the order for PSOAs.
•   PSG Burden Priority Rationale explains why each PSG is prioritized as it is.
•   PSOA Scheduled (yr) provides the year in which the PSOA for that PSG  is scheduled.
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         PROCESS SPECIFIC OPPORTUNITY ASSESSMENTS  (PSOA)
AFMC has conducted "fence-to-fence" P2 Opportunity Assessments (OA) for several years in order to
reduce hazardous waste production, cut costs, and/or meet environmental compliance objectives.
Fence-to-fence P2 OAs typically covered an entire installation in an attempt to identify obvious P2
opportunities that could be easily addressed.  In addition to the fence-to-fence OAs, a number of
focused studies were done, for instance, on an installation's solid waste or on types of processes.
The fence-to-fence approach was done to comply with existing Department of Defense (DoD) and Air
Force (AF) P2 requirements to reduce the pounds of hazardous waste generated.  Although many of
the P2 OAs that were done in the past contain valuable technical information, there was no focus on
compliance burden,  nor on return on investment; and many P2 projects were implemented without
evaluating or documenting their effectiveness.
To address  these  shortfalls, AFMC developed the  PSOA  methodology that applies  opportunity
assessment  methodology in a very focused manner to minimize  costs while  maximizing return on
investment.  The methodology works best  on an industrial process although it is  flexible enough to
apply to other groups.  It was developed from standard techniques proven effective within industry and
government and is consistent with the methodology described in the new USEPA guidance6. It is an
improvement over the  current system because  it is focused,  standardized, reproducible, and results-
oriented. In addition, it is structured to first search available AF and DoD resources to determine what
has been done or is being done to address the issue.  It is designed to be done by either installation
personnel or a contractor - someone who has been trained to perform the methodology. (Appendix D
contains a draft Statement of Work to use to sub-contract PSOAs.)
The  methodology allows for input from any prior successful  P2 projects; however, it also promotes
new, "out of the box" thinking  and solutions. It requires broad cooperation across the installation and
working closely with process owners and other  process experts to obtain "buy-in" to  potential
solutions.
PSOAs produce prioritized lists of potential solutions that fall into one of five categories.
•  Best Management Practices (BMPs),  things that are very easy and quick to do
•  Process Change (PC), usually not requiring a capital expenditure
•  Commercial Off-The-Shelf Technologies  (COTS)  or Government Off-The-Shelf  Technologies
   (GOTS)
•  Demonstration/Validation (DEM VAL)
•  Research and Development (R&D)
Solutions within each of the five categories are ranked according to effectiveness, ability to implement
and cost.
A cost analysis is accomplished  on all potential solutions in the first three categories.  This analysis
considers the reduction in environmental  compliance costs and risk as well as Total Ownership Cost
(TOC) to the greatest extent possible. Emphasis is placed on capturing those  costs that will change
because of solution implementation.
Solutions are sufficiently documented to provide the appropriate decision  maker all the  information
necessary to make an informed decision  as to whether or not to implement any solution and what its
overall impact will be upon the subject process.
Each step of the methodology is documented  electronically in a worksheet stored in a master file
(Microsoft Excel workbook) for that particular PSOA. All PSOAs are archived in the AFMC PSOA file.
This  methodology also includes  a process characterization tool used  to document process specific
information.  The process-diagramming phase is where  most of the process, material and cost
information are collected. This information can be invaluable to overall process operation.
 ' Draft Document: "A New Vision: An Organizational Guide to Pollution Prevention," EPA, June 2001.


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At the end of the PSOA, and with the concurrence of the process owner, any recommended solutions,
together with all supporting data should be transmitted to the CTP2 team for further action.  The
completed PSOA should also be added to the AFMC PSOA file.
  A full PSOA consists of the following seven sequential steps.
  •   Develop  background information.  Find  out as much as possible about the selected process
      and related processes and historic P2 activities.
  •   Form the PSOA team, a team of individuals that know and understand how the process runs
      and other experts such as individuals from the installation's Environmental Management (EM),
      Bioenvironmental Engineering, and Unit Environmental functions.
  •   Characterize the process using process diagrams.
  •   Select a process step, or steps, that have a significant opportunity for improvement.
  •   Conduct  a root cause analysis to determine the underlying cause of the opportunity.
  •   Develop a list of potential solutions.
  •   Draft an action plan for each potential solution
Full documentation of the PSOA approach is attached in a document designed for those responsible
for conducting a PSOA. The following presents a brief overview.

    9.1  STEP 1: PSOA BACKGROUND DEVELOPMENT

In preparation for the PSOA, the CTP2 team first defines the process and the related compliance sites
being considered for the PSOA.
Then, the CTP2 Team  identifies completed,  ongoing  and  planned  studies  including  previously
accomplished P2 OAs for the selected process(es). The information sources for this research fall into
two categories: (1) those that must be checked, and (2) those that should be checked.

    9.2  STEP 2: FORM PSOA TEAM

The PSOA can be conducted with installation level personnel only, through contract resources only, or
a combination of in-house and contract resources. Each  PSOA Team is ad hoc.  Additional "experts"
from the installation (such as members of the  HMMP team) can supplement the team as needed.
The  installation  EM  function  director/manager  determines  how and  by whom  (e.g.,   CTP2
Team/coordinator, P2 division chief, etc.) the PSOA team  members will be selected.

    9.3  STEP 3:CHARACTERIZE PROCESS

Once a  decision has been made to conduct a  particular PSOA and a team of process experts has
been formed, it is time to draw upon everyone's  expertise to characterize the process.  Flow diagrams
are used to characterize the steps of the process as well as material and cost information associated
with each step.

    9.4  STEP 4: SELECT OPPORTUNITY

Using the process characterization information, the team then selects one or more of the lowest level
steps for further study.  This selection is based  on risk, cost, complexity, HAZMAT use, HAZWASTE
generation, air emissions or other criteria.  The  intent is to focus on  a portion of the process where a
change  would  have  the  greatest possible positive  impact (environmental burden reduction, cost
savings,  labor reduction,  etc.).  If the  selection criteria have not been pre-established by  the
installation and/or AFMC, the  PSOA team can consider the following hierarchy when making  its
selection:
•   Environmental compliance risk (risk of non-compliance)
•   Environmental compliance cost
    Occupational health and safety concerns


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•   Operating cost
•   HAZMAT used
•   HAZWASTE generated
•   Air emissions generated
•   Greatest number of inputs/outputs
This suggested list is  not all-inclusive and should be revised by the PSOA team  to fit installation
needs.  The hierarchy should also be  modified to include process specific issues from  the process
owner/decision  maker.   The  PSOA team makes  its  selections,  which  become the  process
"opportunities", using the ground rules previously established and documented.

    9.5 STEP 5: ROOT CAUSE ANALYSIS OF SELECTED OPPORTUNITY

The PSOA team then uses root cause  analysis to examine the opportunities. The team identifies the
specific problem/issue for each opportunity to be  addressed.  The issue/problem is the "effect" the
team will focus on. The team then identifies the "causes" behind the effect. Causes in four categories
are generally identified: people, materials, methods, and tools. A cause and effect (fishbone) diagram
may be used in the  process.  It is extremely important that the team explores all possible causes.
After identifying the causes, they should be reviewed and grouped where similar.

    9.6 STEP 6: DEVELOP POTENTIAL SOLUTIONS

The root cause analysis provides the ideal lead-in to developing solutions. After thoroughly analyzing
the opportunity, identifying the problems/issues/effects and discussing/consolidating causes, the team
should move right into solution generation from the root cause analysis.  Here  again all of the PSOA
team should participate.  The team may also consider having other individuals participate, who may
be  more familiar with  the details of some of the causes  identified during the previous step (e.g.,
technical orders, standard operating procedures, process worker training, process equipment, etc.).
The team should consider conducting this solution identification phase  near or in the process location
to encourage participation by those most familiar with the Process. Solutions are prioritized within the
five solution categories previously identified.  Some preliminary analysis of the impact of the solutions
on EC burden  and TOC is also accomplished.  Someone should check outside sources  for possible
solutions to that particular opportunity.

    9.7 STEP 7: DRAFT ACTION PLAN FOR SOLUTIONS

The worksheets  prepared  during the  PSOA, any other documents  used and  a PSOA executive
summary become the PSOA final report.  It is very important that all data sources and/or assumptions
are documented. It is also helpful to create a Table of Contents worksheet to identify the worksheets
included in the package.  The team should then prepare a  short (approximately two page) executive
summary for the PSOA. The executive summary should include the following:
•   PSOA Background.   This section summarizes the rationale  for the selection of  the  subject
    process  for a PSOA.  It lists the  organizations  involved, PSOA Team Chief, and any Process
    points of contact (POCs). It also includes any relevant issues encountered during the  PSOA (e.g.,
    assumptions, data collection issues, rationale for limiting scope of PSOA, etc.).
•   Process  Overview. This section presents a brief description of the subject process  including its
    annual operating cost, environmental compliance burden impact, etc.
•   PSOA Findings.  This section summarizes the opportunities selected by the team, rationale for the
    selection, causes behind the opportunities and  potential solutions/alternatives.
•   Recommendations.  This  section  summarizes the recommended solution(s) identified  by the
    team.  It  also includes a summary of proposed  follow-on actions and benefits from implementation
    of the solution(s).
All  completed  PSOAs should  be entered  into the  AFMC PSOA file for future access. Required
information includes:
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•  PSOA Completed Date,
•  PSG Name,
•  Additional Base Specific Information,
•  P2 Project Number,
•  PSOA Tech Order(s),
•  PSOA Site Number(s),
•  PSOA Preparer, and
•  PSOA File Address.
All identified solutions should be added to the PSOA Solutions information. Those solutions that the
installation wishes to pursue are identified by identifying a Selected Solution FY element of the PSOA
Solutions information.
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                                          10

                CTP2 SOLUTION PLANNING & PROGRAMMING
The objective of this CTP2 element is to select the best P2 solutions and then use the budgeting
process to successfully implement those solutions.
Solution Planning  & Programming activities vary, depending upon the Solution  Category   Best
Management  Practice  (BMP) solutions require  little or no  funding and  if acceptable  can be
implemented immediately.  Process Changes (PC)  and COTS/GOTS, and DEM VAL solutions require
some  funding and thus  programming for funds is necessary.  Funding  R&D solutions is  typically
beyond the capabilities of an installation.  These solutions would thus be submitted either through the
ESOH  TPIPT Tech Needs process for MAJCOM / USAF  /  DOD  consideration  or directly to
SERDP/ESTCP for funding.  Installations can receive 3400 funding for DEM VAL projects from HQ
AFMC by submitting a PPPN.

    10.1  PSOA SOLUTION SELECTION

In  order to differentiate among  solutions  in the  competition  for funding, additional factors,  both
subjective and objective, come into play.  Objective factors can best be evaluated using the PSOA
Solution Selection Tool in Appendix E. Subjective factors  such as mission imperatives should also be
considered.

    10.2 PSOA SOLUTION SELECTION FUNDING CONSIDERATIONS

The following criteria must be considered when deciding which P2 solutions to pursue.
•   For a solution to qualify as an Air Force Level 1 P2 project and thus qualify for Air Force P2 funds,
    the impacted  PSG must contain at least one  compliance site having either "extremely  high" or
    "high" burden.
•   Any solution must have no more  than a 5-year payback on TOC to be eligible for Air Force P2
    funds. The Dem Val category of solutions is not subject to the 5-year payback requirement, but
    must demonstrate savings.
•   If  less than 50% of a solution's  savings can be applied to EC, then joint funding should be
    considered.

    10.3 BMP SOLUTIONS

BMP solutions are easy to  implement requiring only local  approval and  little or no funding. The date
the solution  was  implemented [Solution  Operational Date  (dd/mm/yy)]  is included  in the PSOA
Solutions information.

    10.4 PC AND COTS/GOTS SOLUTIONS

Different funding lines exist for projects depending to some extent upon the nature of the solution.

       10.4.1 Pollution Prevention Solution
If the  solution meets the criteria established by HQ AFMC/CEV for P2 funding, a funding  request
should be sent to  them in the form of a pollution prevention program narrative (PPPN). The date the
PPPN  was submitted  [PPPN Submitted  Date (mm/dd/yy)] is  included in  the  PSOA Solutions
information.
The Automated  Civil Engineering System Project Management Subsystem  (ACES-PM)  is  the
successor to the  Interim Work Information  Management System (IWIMS) software  for Project by
Contract  Management  System   (PCMS),   Programming Design  and  Construction  (PDC),  and
Environmental Subsystem  (WIMS-ES) programming and management.   ACES-PM is the official
information system that AFMC will use to validate and track environmental requirements and report
budgets and program execution through the Air Staff. The ACES-PM module is an integral part of the
Air Force budget process and the day-to-day management of the budgetary aspect of environmental
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them in the ACES database.  Items that should be entered into the ACES-PM module are comprised
of O&S, level I and level II projects included in the Program Objective Memorandum (POM) and Fin
Plan.  ACES-PM requirements represent items that are highly likely to  be funded and should not
include a wish list of everything possible.  Data from ACES-PM is used by AFMC and Air Staff to
develop and document the annual Budget Estimate Submission (BES) and Fin Plan and to develop
program dollars  for the  POM.  Thus, proper use of the ACES-PM module is key to successfully
advocating for funds for CTP2 solutions.

       10.4.2 Weapon System Specific Solution
P2 funds can be used for solution(s)  affecting maintenance processes for single or multiple weapon
systems or for solutions that directly impact multiple weapon systems.  P2 funds, however, cannot be
used for solutions that directly affect (modify,  etc.) a single weapon system. In  the case of solutions
affecting  a single weapon system, the LG environmental  managers should work with the Single
Manager and submit a Weapon System (WS)  Program Elements (PE) P2 POM submittal.

       10.4.3 Capital Investment Solutions
For capital investment solutions, develop POM submittals highlighting cost-effective P2 solutions and
stressing environmental  management hierarchy, risk  reduction, Total  Ownership Cost savings,
projected gains in mission productivity, health and safety, and transferability.
When submitting MILCON  projects, installations will include a comparison of the cost of compliance
and the cost of the P2 solutions on the AF Form 1391.

    10.5 DEM VAL AND R&D SOLUTIONS

DEM VAL and R&D Solutions should be submitted through the ESOH TPIPT Tech Needs process.
Online submittal is available through http://xre22.brooks.af.mil/.
The date the solution was submitted [Submitted as ESOH Tech Need (dd/mm/yy)] is included in the
PSOA Solutions information.
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                                          11

                       CTP2 SOLUTION  IMPLEMENTATION
The objective is to implement the selected process-specific P2 solutions to reduce the installation's
EC costs and risks.

    11.1 STEP 1: REAFFIRM PROCESS OWNER(S) COMMITMENT

The buy-in  of the process owner(s)  was obtained  during the PSOA phase of the  CTP2 cycle.
However, when it comes to implementing  a  solution, it is critical to verify the process owner(s) is
supportive of the proposed solution and the associated investment of time and resources.  It will be
especially critical for processes involving pilot demonstration projects or process modifications, which
may lead to  some production downtime.

    11.2 STEP 2: DEVELOP IMPLEMENTATION PLAN

This stage involves preparation of the cost breakdown and schedule for implementing the solution.  It
is  important that the project rationale  and  justification devised in earlier stages  of the CTP2 cycle
remain valid and are documented in the implementation plan. Consider the timing  of the availability of
funds when  building the implementation scenario.

    11.3 STEP 3: OVERSEE IMPLEMENTATION

In  addition to ensuring that process owners are "on-board" with  implementing the solution, it may also
be necessary to obtain  their  support  for any related activities.  Most likely, process  changes will
require technical order modification  in accordance with the  procedures outlined  in AFTO Form 22,
Technical Manual Change Recommendation and Reply. The following information will be required to
aid in  execution and oversight of the  Implementation Plan. The data will also provide a basis  for
measuring the effects of funded projects.
•   Budgets and financial information developed during the planning phase.
•   Tracking of implementation milestones.
•   Tracking of progress on implementation.
•   Documentation of missed milestones, slippages, etc.

    11.4 OUTPUT TO CTP2 MAP

Information  about solution implementation is included  in the PSOA Solutions information of the CTP2
MAP.
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                                            12
                           CTP2 SOLUTION EVALUATION
The objectives of this element are to evaluate CTP2 solutions after they have been
fully implemented and to communicate the results throughout AFMC so that other
installations can benefit.  The specific impact on  individual compliance sites will be
noted through  the routine process of CSI maintenance.  This  element augments
that reporting process by evaluating a fully implemented solution against the metrics
that were used to justify the solution in order to determine to what extent they were
or were not met. Trends on these metrics as well as on the impacted compliance
sites should be reported back to HQ AFMC/CEV  yearly through the Project Management Review
(PMR) process using "quad" charts or the then currently acceptable format.
Reporting against the installation's Business Performance Indicators (BPIs) is external to this element.
    12.1 OUTPUT TO CTP2 MAP
Qualitative  data  regarding  the  effectiveness of implemented  solutions is  included  in  the PSOA
Solutions information. Reporting should be made in reference to the estimated benefits resulting from
the solution. The following data is used to report for a 5-year horizon and is part of the PSOA Solution
information. This duration is used anticipating that projects with a greater than 5-year payback will not
be funded.
•   Baseline Process Operating Cost (k$)
•   Initial Investment Cost (k$)
•  Actual Solution Operating Cost, year 1 (k$)
•  Actual Solution Maintenance Cost, year 1 (k$)
•  Actual Solution Process Cost Savings, year 1  (k$)
•  Actual Solution EC Cost Impact, year 1 (k$)
•  Actual Solution EC Risk Impact, year 1
•  Actual Solution Operating Cost, year 2 (k$)
•  Actual Solution Maintenance Cost, year 2 (k$)
•  Actual Solution Process Cost Savings, year 2 (k$)
•  Actual Solution EC Cost Impact, year 2 (k$)
•  Actual Solution EC Risk Impact, year 2
•  Actual Cap. Inv. Cost, year 5 (k$)
•  Actual Solution Operating Cost, year 5 (k$)
•  Actual Solution Maintenance Cost, year 5 (k$)
•  Actual Solution Process Cost Savings, year 5 (k$)
•  Actual Solution EC Cost Impact, year 5 (k$)
•  Actual Solution EC Risk Impact, year 5
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                                    Glossary
ACES - Automated Civil Engineer System
ACES-PM - Automated Civil Engineer System, Project Management
AF - Air Force
AFI - Air Force Instruction
AFMC - Air Force Materiel Command
AFPD - Air Force Policy Directive
APIMS - Air Program Information Management System
AQUIS -Air Quality Utility Information System
BES - Budget Estimate Submission
Burden - Compliance Cost plus Compliance Risk
BMP - Best Management Practice
BPI - Business Performance Indicator
CAPP - Compliance Assurance and Pollution Prevention
CCS - Command Core System
CE - Civil Engineer
COTS - Commercial Off The Shelf Technology
CSI - Compliance Site Inventory
CTP2 - Compliance Through Pollution Prevention
DEM VAL - Demonstration Validation
DO - Director of Operations
DoD - Department of Defense
DUSD-ES - Deputy Under Secretary of Defense for Environmental Security
EC - Environmental Compliance
ECAMP - Environmental Compliance Assessment and Management Program
EM - Environmental Management
EMS - Environmental Management System
EPC - Environmental Protection Committee
ESOH - Environment, safety, and Occupational Health
ESOHC - Environment, Safety, and Occupational Health Committee
ESTCP - Environmental Security Technology Certification Program
FY-Fiscal Year
GOTS - Government Off The Shelf Technology
HMMP - Hazardous Materials Management Plan
HMMS - Hazardous Material Management System
IWIMS ES - Installation Work Information Management System Environmental Subsystem
LG - Logistics
MAJCOM - Major Command
MAP - Management Action Plan
NOV - Notice of Violation
OA - Opportunity Assessment
O&M - Operation and Maintenance
P2 - Pollution Prevention
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PC - Process Change
PE - Program Elements
PMR - Program Management Review
POM - Program Objective Memorandum
PSG - Process Specific Group
PSOA - Process Specific Opportunity Assessment
RDT - Requirements Development Team
R&D - Research and Development
SERDP -Strategic Environmental Research Development Program
SG - Surgeon General
SOW - Statement of Work
TOC - Total Ownership Cost
TPIPT - Technology Planning Integrated Product Team
UPID - Universal Process Identifier
USEPA - United States Environmental Protection Agency
WS - Weapon System
XP - Long Range Planning
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                                     Appendix A
                        CSI  FIELDS FOR COMPLIANCE SITE IDENTIFICATION
Detailed information required to identify each compliance site should be entered and maintained in the
following CSI data elements.
•   Base ID Number: Cross-referencing identification number for other files such as AQUIS.  Alpha-
    numerics are permitted in this data field.
•   Base Name: Select from the following choices:
   -  Arnold Air Force Base
      Brooks Air Force Base
      Edwards Air Force Base
      Eglin Air Force Base
      Hanscom Air Force Base
      Hill Air Force Base
      Kirtland Air Force  Base
      Los Angeles Air Force Base
      Robins Air Force Base
      Rome Laboratory
   -  Tinker Air Force Base
   -  Wright-Patterson Air Force Base
•   Site Number:  Sequential number from aaaaOOOl to aaaa9999, where "aaaa" is the installation's
    ACES-PM code shown below. The number is retired and never used again once the associated
    compliance site is closed. New numbers are  assigned beginning with the last number. If the site
    should be  returned to service for some  reason, it must be  assigned a new compliance site
    number.
                    Installation Name (ACES-PM)
                        Arnold Air Force Base
                        Brooks Air Force Base
                       Edwards Air Force Base
                         Eglin Air Force Base
                       Hanscom Air Force Base
                         Hill Air  Force Base
                       Kirtland Air Force Base
                      Los Angeles Air Force Base
                        Robins Air Force Base
                          Rome Laboratory
                        Tinker Air Force Base
                   Wright-Patterson Air Force Base
                          Table 3:  Installation ACES-PM Codes
 •   Site Location: The physical location of the site.  Use whatever  appropriate information is needed
    to clearly identify the location so others can locate the site. Examples include:
      Facility and/or building number plus post/door/room number or other applicable location
      designation.


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      CIS coordinates
   -  Tank number
There may be multiple compliance sites at a single location.  In those cases, all of the co-located sites
must have identical "site location" information.
•   Site Owner: The organization  or function (with organizational symbol)  owning the  process or
    activity associated with the site. The process should be generating the air, liquid, or solid waste.
•   Environmental Permit Number: The number of the appropriate environmental permit.
•   Site Type:  The first level of compliance site definition is Site Type.  Select from the following list of
    allowable choices.
   -  AST:  Above ground (petroleum) storage tanks with a capacity of 660 gallons or more. Multiple
      tanks relying upon the same containment should be counted as  separate compliance sites.
      Subject tanks are those addressed in Spill Prevention Control and Countermeasure Plan.
       	   + Include:
        Only tanks containing petroleum products
	   Exclude:
Mobile storage tanks unless specifically
  included by state or local regulation
Pressure vessels such as propane tanks
         Hydraulic reservoirs
           Only tanks larger than 660 gallons
        Underground tanks contained in concrete
            vaults with interstitial monitoring
                                           ^^^^^^^H ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^H
                                                     Tanks containing chemicals, such as
                                                   ethylene glycol and methylene chloride.
                                                   These may be captured as EPCRA sites.
                     Table 4:  Site Type = AST Include/Exclude Criteria
      Air Sources:
                                     + Include:
       Individual regulated sources accounted for under Title V permit (whether
            major, minor, or  insignificant sources) or by individual permit or
       registration that must be periodically accounted for to ensure compliance
                               (Srandfathered sources
        Any sources that either are or would be regulated under a Title V permit
       Mobile sources may be included, if and only if, state or local requirements
          include them in the facility air permit; for example, aircraft ground
                         equipment is included in some states.
                 Table 5: Site Type = Air Sources Include/Exclude Criteria
                           -  Exclude:
                             Fugitive
                              dust
                             permits
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     Drinking Water:

        Potable water system components such as Air Force managed     Mandatory sampling
       water sources (such as production wells or surface reservoirs),         locations
       treatment systems (such as chlorination, air stripper, filtration,
        or a system with multiple unit processes), major storage sites
             (such as water towers), and distribution system(s)
               Table 6: Site Type = Drinking Water Include / Exclude Table
     EPCRA: Count as sites those storage areas containing more than 100% of the reporting
     threshold for a 312 reported chemical.

       HAZMAT storage sites exceeding reporting thresholds defined    Portable containers,
                      under EPCRA, Section 11022                     lab gas cylinders,
                                                                         pails, etc.
                     Only permanent tanks or vessels
         Most tanks containing fuels as components likely to exceed
                         EPCRA reporting levels
       A single location where multiple containers of a single chemical
      are stored such that the total quantity of the chemical exceeds
                      the 312 reporting threshold
                  Table 7:  Site Type = EPCRA Include/Exclude Criteria
     HAZWASTE Management:

              Initial accumulation points                Sites governed only by OSHA
              90-day accumulation sites             Installation restoration program sites
                                                                 (IRP)
       Treatment storage, and disposal facilities
       (RCRA Part B permitted or  interim status)
         Table 8: Site Type =  HAZWASTE Management Include/Exclude Criteria
     Landfills:

         On-installation permitted solid waste
                      landfills
                                                         - Exclude
                                           Unauthorized disposal sites discovered on
                                           the installation (e.g., cans of paint found in
                                            dumpster and unauthorized construction
                                                     demolition dumping).
            Table 9: Site Type = Landfills Include/Exclude Criteria
Open Burn / Open Detonation (OB/OD): Includes RCRA Subpart X permitted or interim status
sites.
Pesticides: Includes all storage and mixing facilities operated by certified pesticide applicators.
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     RCRA Cleanup Sites: Sites should not be confused with CERCLA required cleanups.
                          +Include:
        - Exclude:
IRP sites or areas of concern
          Confirmed SW management units subject to a
       regulatory (RCRA) compliance agreement or a Part B
                            permit
I        Sites that are still under the long term monitoring
                       phase of cleanup
                       UST cleanup sites
              Table 10:  Site Type = RCRA Cleanup Include/Exclude Criteria
     UST (underground storage tanks) including connecting piping to include state regulated fuel
     hydrant systems.
      +  Include:                                - Exclude:
        All size                          Tanks containing heating oil
         tanks
                    Underground tanks contained in vaults which should be counted as ASTs
                   Table II:  Site Type = UST Include/Exclude Criteria
     Waste Water and Storm Water

         National Pollutant Discharge Elimination System      Storm water permits resulting
             and/or permitted storm water outfalls           from construction activities
                Permitted regional  connections                    Sewer systems
       Other permitted discharges (e.g., treatment plants
      discharging to evaporation ponds or land application)
•         Oil-water separators and other pretreatment
        systems  which feed to regulated discharge points
              Sewage sludge land application sites
        Table 12: Site Type  = Waste Water, Storm Water Include/Exclude Criteria
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•   Site Category:  The second level of compliance site definition is Site Category.  Only two Site
    Types, Air Sources and RCRA Cleanup, have Site Category(s).
•   For Air Sources                            •   For RCRA Cleanup
 Major: Major / minor breakpoint is a function
       of state and/or local regulations
                                             Study:  Sites are first studied and then,
                                           depending upon the outcome, move to one of
                                          the following or are determined to require no
                                           action and are dropped from the inventory.
                                          Depending upon the activity, the same physical
                                          site can be a cleanup, LTM, and LTO site. No -
                                              action - sites should not be included.
                                          Cleanup: A definable cleanup activity that can
                                           be completed in a relatively short time span,
                                                for example, a building demolition.
                                          LTM (long  term monitoring):  A requirement to
                                             monitor over a long period, such as the
                                           migration of a contaminant; considered as an
                                                           LTM site.
                                          LTO (long term operating): An operation that
                                          runs for an extended time such as a pump-and-
                                             treat operation that runs for 30 years;
                                                    considered an LTO site.
                   Table 13: Allowable Compliance Site Categories
Site Description:  The third  level of compliance site definition is provided by the  Site Description.
Site Descriptions exist for five of the Site Types:  Air Sources, Drinking  Water, Waste Water /
Storm Water, RCRA Cleanup, and HAZWASTE.  The following table lists the allowable choices
for each.  For all others leave blank or enter N/A.
Insignificant: Generally identified sources that
      require minimal permitting support
                                                                                      1
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For Air Sources
Abrasive Blasting
      Boiler
  For  Drinking Water:
     Treated Water
   Distribution (List by
system and count public water
systems as only those with 15
 or more service connections
    regularly served by 25
individuals for 60 days or more
[DUSDES definition]. Wells or
 systems not meeting criteria
  will only be counted under
     well/treatment, not
     distribution system.
Treated Water Storage:
     (e.g. water towers)
 Raw Water Supply: (e.g.
  production wells, surface
  reservoirs, connection to
      regional systems)
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   For HAZWASTE:
 ACCS (90-day) satellite
    accumulation point
  For RCRA Cleanup:
  activities leading to the
    contaminant release
 Industrial Waste Line
                                                                                        Leaking UST
                                                       TAP (Initial Accumulation
                                                                Point)
TSDF (treatment, storage,
    or disposal facility)
  Munitions Rule: Most
ranges will be captured under
      this definition.
  For Waste Water /
      Storm  Water

 NPDES (National Pollutant
Discharge Elimination System)
  Outfall: Defined to be the
   point where compliance
samples are collected.  Include
 permit sampling point number
  and/or number from storm
   water P2 plan or other
 identification in Site Location
  block.  Include permitted
storm water discharge points.


    Other Permitted
Discharge: (e.g., discharges
 to evaporation ponds or land
  application) Defined as the
  discharge  point to ponds or
the sludge application location.
    If each pond is listed
  separately in permit, each
    pond can be counted.
 Otherwise, multiple ponds at
  one location count as one.
 Pretreatment:  Includes
oil/water  separators and other
 pretreatment systems, which
 feed to regulated discharge
 points and sewage sludge  land
application sites. This includes
   domestic and industrial
wastewater treatment plants.
 Each olant  is counted as one.
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     Fuel Dispensing
 Water Treatment: Count
   treatment at each well
   separately, but multiple
    treatments - such as
 chlorination, fluoridation, etc.
 - in one well house is counted
as one multiple unit treatment.
 List by well number or other
 ID  in "Site Location" block.
  Other HAZWASTE:
Include unique state and local
       requirements.
Spill Site
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               and individual unit operations
                are not counted separately.
                Each oil/water separator is
              counted as a site regardless of
                permitting. Includes silver
              recovery units.  Include active
              septic tanks with drain fields.
               List type of unit and location
                  in Site Location block.
              Regional Connection: The
                point where the installation
              sewer system connects to the
                     regional line.
       Generator
       Paint Booth
   Process Operations
       Solvent Use
      Storage tank
   Other: for permitted
   activities not otherwise
defined, including unique state
   and local requirements
                                                         Other RCRA Cleanup: For
                                                           activities not otherwise
                                                         defined. Include unique state
                                                            and local requirements
                                                         Other Wastewater: For
                                                           activities not otherwise
                                                        defined. Include unique state
                                                          and local regulated sites.
                                            Table 14:  Allowable Compliance Site Descriptions
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                            Insignificant
                            N/A
                            N/A
In  summary, the only allowable combinations for Type, Category, and Description are listed in the
following table.
                                          Description
                                          N/A
                                          Abrasive  Blast,   AGE,  Boiler,  Fuel  Dispensing,
                                          Generator, Paint Booth, Process Operations, Solvent
                                          Use, Other
                                         ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^H
                                          Abrasive  Blast,   AGE,  Boiler,  Fuel  Dispensing,
                                          Generator, Paint Booth, Process Operations, Solvent
                                          Use, Other
                                          Abrasive  Blast,   AGE,  Boiler,  Fuel  Dispensing,
                                          Generator, Paint Booth, Process Operations, Solvent
                                          Use, Other
                                          N/A
                                          Raw  Water  Supply,  Treated  Water  Distribution,
                                          Treated  Water Storage, Water Treatment
                                          ACCS, IAP, TSDF, Other HAZWASTE
                                          N/A
                                          N/A
                                          N/A
                                          Industrial Waste Line, Leaking UST, Munitions Rule,
                                          Spill Site, Other RCRA
                                          Industrial Waste Line, Leaking UST, Munitions Rule,
                                          Spill Site, Other RCRA
                                          Industrial Waste Line, Leaking UST, Munitions Rule,
                                          Spill Site, Other RCRA
                                          Industrial Waste Line, Leaking UST, Munitions Rule,
                                          Spill Site, Other RCRA
                                          N/A
                                          NPDES,  Other  Permitted  Discharge,  Pretreatment,
                                          Regional Connection, Other Wastewater
            Table 15: Allowable Compliance Site Type, Categories, and Descriptions
    AF Database Compliance Site Category: This information is required for reporting compliance site
    information to Air Staff.  Select from one of the following.
       01-a-Air, Abrasive Blasting
   -   01-b-Air, AGE
   -   01-c-Air, Boiler
       01-d-Air, Fuel Dispensing
   -   01-e-Air, Fuel Cell
       01-g-Air, Incinerators
   -   01-h-Air, Paint Booth
       01-i-Air, Process Operations
 EPCRA
 Drinking Water
^^^^^^^^^^^^^^^^^^^^^H
 HAZWASTE Management
 Landfills
 OB/OD
 Pesticides
 RCRA Cleanup
                            N/A
                            Cleanup

                            LTM
                            LTO
                            Study
UST
Waste Water / Storm Water
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     01-j-Air, Solvent Coating Ops.
  -   01-k-Air, Solvent Use
     01-l-Air, Storage Tank
  -   01-m-Air, Test Cell/Hush House
  -   02-a-CERCLA, ERA-Funded Cleanup Sites
     03-b-Drinking Water, Treated Water Distribution
     03-d-Drinking Water, Water Treatment
     04-a-Wastewater / Storm Water, Collection
  -   04-b-Wastewater / Storm Water, General NPS
  -   04-c-Wastewater / Storm water, NPDES Outfall
     04-d-Wastewater / Storm Water, Other Permitted Discharge
     04-e-Wastewater / Storm Water, Pretreatment
     04-f-Wastewater / Storm Water, Regional Connection
     04-g-Wastewater, Sewage Sludge Land Application Site
     05-a-Aboveground Storage Tank (AST)
  -   06-a-EPCRA
     07-a-Pesticides, Storage
     07-a-Pesticides, Mixing
  -   08-a-HAZWASTE Mgmt.,  Initial / Satellite Accumulation Point
  -   08-b-HAZWASTE Mgmt.,  90-Day Accumulation Site
  -   08-c-HAZWASTE Mgmt.,  Permitted TSDF
  -   08-d-HAZWASTE Mgmt.,  Interim  Status TSDF
  -   08-e-Non-Haz Solid Waste Mgmt. Site
  -   08-f-Underground Storage Tank (UST)
  -   08-g-RCRA Cleanup Site (non-ERA funded site)
  -   09-a-Toxics, PCB
  -   09-b-Toxics, LBP
     09-c-Toxics, Radon
  AF Database, Media: This information is required for reporting compliance site information to Air
  Staff. Select from one of the following.
  -   CAA (Clean Air Act)
  -   CWA (Clean Water Act)
     EPCRA (Emergency Preparedness and Community Right-to-Know Act)
  -   HW (Hazardous Waste)
  -   SDWA (Safe Drinking Water Act)
  -   SW (Solid Waste)
     UST (Underground Storage Tank)
  PSG Number(s):  If there is  an ongoing project addressing the site, the number of the  project
  should be entered here as well as in the records for all other compliance sites addressed  by that
  project. (It is highly unlikely that a project will address only one compliance site but rather a group
  of compliance sites.) If there is no ongoing project, then the number(s) of any Process Specific
  Groups of which the compliance site  is a member should be  entered.
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                                      Appendix B
                               EC RECURRING COST DETERMINATION
Starting with the first line item in the EC Obligated Budget, first determine if it is a recurring cost. If it
is, then determine which of the following "Activities" is most appropriate.  If it isn't a  recurring cost,
then it is a One-Time EC Cost and is addressed in a subsequent section.
•   Compliance Audits / Assessments
•   Permit Maintenance
•   Plan Maintenance
•   Program Overhead
•   Sampling, Analysis, and Monitoring
•   Record  keeping and Reporting
•   Training
•   Waste Management & Disposal
•   Labor
Then, if either all or a portion of the line item can be associated with a particular compliance site, do
so and reduce the amount  for that line item accordingly. If either all or a portion of the residual can be
assigned  to a particular type, category, and/or description of compliance site, then divide that amount
equally among the impacted sites and  reduce the residual  accordingly.
Repeat the  process for each line item  in the obligated budget.  When completed, total all the line item
residual amounts and then distribute them  equally to  like  compliance  sites  based on the "act"
distribution in the budget.
•   Act = CA identifies all air media compliance site related line items
•   Act = RC identifies all  solid media compliance sites of the type: UST, AST, RCRA CAP, EPCRA,
    HWSS, Landfill, OB/OD
•   Act = SD or CW identifies all liquid media compliance sites of the type: DW or WW/SW
If Pesticide  compliance sites exist, they should be assigned 1% of the residual and the remaining 99%
distributed according to the preceding procedure.
If a line item recurs on a greater than  one-year cycle, then it should be included  in the calculation but
on an annualized basis. For example, if a cost recurred  every 5 years, then one-fifth  of it should be
used in the determination of EC Recurring Costs.
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                                     Appendix C
                                COMPLIANCE SITE RISK ALGORITHM
         Comparative Risk = Cwz - FWF - HWF - MWF - PWF - RWF - EWM - ((OAM + Nm + Lm)/3) where:

         CWE = Compliance Weighing Factor (Probability risk component),
         FWF= Future Regulatory Factor (Probability risk component),
         HWF = Hazard Weighing Factor (Hazard risk component),
         MWF = Mobility Weighing Factor (Severity risk component),
         PWF = Proximity Weighing Factor (Exposure risk component),
         RWF = Release Weighing Factor (Severity risk component),
         EWM = Worker Exposure Weighing Matrix (Exposure risk component),
         OAM = Operational Complexity Additive Matrix (Probability risk component),
         NAM = Containers Additive Matrix (Probability risk component), and
         LAM = Containment Additive Matrix (Probability risk component).
Note that in the algorithm, the Weighing Factors and Weighing Matrices: Cwz, FWp, HWF, MWF, PWF,
RWF, & EWM are multiplied and the Additive Matrices; OAM,  NAM, & LAM are added to complete the
calculation.
•   CWE,  Compliance  Weighing Factor:  The Compliance  Weighing
    Factor has six individual components, which are added together to
    produce the  overall  multiplier.  Each of the six components is
    independent and  all  relate to  the  compliance site's  regulatory
    history and status.  The future regulatory impacts component has
    been removed from the Compliance Weighing Factor and is now a
    separate weighing factor. Each is described in the following Tables
    14 through 18.
       I
                                  Criteria:                               Score:
       If the compliance site has more than one permit from a federal, state or      2
                                 local agency
           If the compliance site has one permit and/or it requires agency          1
          |                    registration
                                   Default                                  0
Table 16: Risk Algorithm Element Risk Score/Rank,  Cfi Permits/Registration Scoring Matrix


         If the compliance site incurred a historical notice of violation or other        4
             enforcement action from any federal, state or local agency

          Table 17:  Risk Score/Rank, CN, NOV Has Been Issued Scoring Matrix
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          If the compliance site incurred an incident, which was reported to an        3
                              environmental agency

             Table 18:  Risk Score/Rank, CIi Reportable Incident Scoring Matrix
                                   Criteria:            Score:
                          	Daily                 3
                           Between daily and Monthly       2
                               More than monthly           1
    Table 19:  Risk Score/Rank,  CK Inspections/Record-Keeping Performed Scoring Matrix


                       If reporting is required by any agency     2
                                    Default                  0
              Table 20: Risk Score/Rank, CR,Reports Required Scoring Matrix
•   Risk Score/Rank, FWF Future Regulatory  Impact:  New and proposed  regulations may have
    significant  impact on  risk.  Risk  is best  reduced by addressing  subject sites prior to future
    regulations taking effect. The closer a regulation comes to being enacted, the higher the risk.


   If a new regulation relating to the compliance site has been promulgated, but is not       5
                                  yet effective
          If a new regulation has been proposed, but is not  yet promulgated               4
    If a new regulation is in the advanced notice of proposed  rulemaking status, but  is       3
                                not yet proposed
                    If there is no future regulatory action known                        1
          Table 21: Risk Score/Rank, Fw, Future Regulatory Impact Scoring Matrix
•   Risk Score/Rank, HWF Hazard Weighing Factor: The hazard-weighing factor depends upon the
    chemical(s) of interest at the individual compliance site appearing on a particular agency list. The
    chemical(s) in  the system can be used,  produced or stored to qualify. Examples  include propane,
    naphtha, Freon, sulfuric acid, ammonia, hydrogen, etc.  A score  modification, for low  volume
    chemicals,  is made at the end of this section.
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                                                                                 l
                                                                               NOTE
                                                                              Score:
                                                                                 5
                                    Criteria:
   3 or more chemicals on the EPCRA § 304 EHS or CERCLA Reportable Quantity (RQ)
     lists, or the State's toxic chemical list (if one exists), or RMP Level 3 designation
   One or 2 chemicals on the EPCRA § 304 EHS or CERCLA RQ lists or the State's toxic
                  chemical list (if one exists) or gasoline or jet fuel
      3 or more chemicals on the EPCRA § 313 TRI list or diesel fuel or RMP Level 2
                                  designation
       One or 2 chemicals on the EPCRA § 313 TRI list or designated RMP Level 1
                          No chemicals on the above lists
  If the total volume of the chemicals of concern is less than 10 gallons, a score of
   5 is reduced to 3, a score of 4 is reduced to 2, and a score of 3 or 2 is reduced
                                      tol.
          Table 22:  Risk Score/Rank,  Hw, Hazard Weighing Factor Scoring Matrix
•  Risk  Score/Rank, MWF Mobility Weighing Factor:  This factor is used to determine the potential
   for gaseous, liquid or solid contaminants from the  compliance site to  enter the environment and
   the speed  at which they would migrate in various media.   Each chemical  associated with the
   compliance site (determined in the hazard factor above) should be evaluated with the  most mobile
   (or highest score) prevailing.  The mobility-weighing factor should  be considered for normal
   operation including minor upsets and failures but not catastrophic events. A score modification for
   uncontaminated air, and combustion gases from  propane and  natural gas  combustion and a
   score modification for low volume chemicals are also made at the end of this section.

           Liquid pollutant/contaminant impacting surface water or a gaseous
                      pollutant/contaminant impacting the air
                   Liquid pollutant/contaminant impacting  the soil
      Liquid pollutant/contaminant impacting the air or  a solid pollutant/contaminant
                                impacting water
                    Solid pollutant/contaminant impacting the air
   Uncontaminated  air and combustion gases from propane and fossil fuel  (except coal)
                                  combustion
                                    All others
  If the total volume of the chemicals of concern is less than 10 gallons, a score of
   5 is reduced to 3, a score of 4 is reduced to 2, and a score of 3 or 2 is reduced
                                      tol
         Table 23:  Risk Score/Rank, MWF, Mobility Weighing Factor  Scoring Matrix
•  Risk  Score/Rank, PWF Proximity Weighing  Factor: This factor is used to  measure the potential
   impact upon receptors, whether human, ecological or environmental.   The score  is  entered into
   the box marked Proximity.
                                                                              Score:
                                                                                 5
                                                                                 2
                                                                                 1
                                                                               NOTE
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                                                                                   Score:
                                                                                     5
                                       Criteria:
       Proximity of the compliance site on or within 1 mile of a pristine area (such as a
      National Park or Forest), tribal area, and  within 1A mile of a public receptor located
      either on or off the base. A public receptor can be a  road, building or house where
                             human occupancy is frequent.
       Proximity of the compliance site on or within 1 mile of a pristine area (such as a
       National Park or Forest), tribal area, or within 1A mile of a public receptor located
                                either on or off the base.
      Proximity within 5 miles of a pristine area, or tribal property and within 1/2 mile of a
                              public receptor on or off base
L       Proximity within 5 miles of a pristine area, or tribal property or within 1/2 mile of a
                              public receptor on or off base
                                   None of the above                                    1
          Table 24:  Risk Score/Rank, Pw, Proximity Weighing Factor Scoring Matrix
•   Risk Score/Rank, RWF  Release Weighing  Factor:   The  release-weighing factor is  used to
    determine  the score associated with the normal type of release from the compliance site. The
    release factor is based on the type of activity that most normally occurs at the compliance site.


     A compliance site with a continuous process discharge, Examples are: active boilers,       5
     	 WWTPs, active  RCRA CAPs, etc.
        LA compliance site with a batch process discharge, Examples are: paint booths,
      abrasive blasting, fuel dispensing, HW lAPs, HW ACCSs, HW TSDFs, plating shops,
                                       labs, etc.
      A compliance site with a batch discharge due to filling or emptying, Examples are:
                                   storage tanks, etc.
     LA compliance site with a batch discharge due to breathing, Examples are drums and
                                   smaller containers.
                                        Default                                         1
           Table  25:  Risk Score/Rank, Rw,Release Weighing Factor Scoring Matrix
•   Risk Score/Rank, EWM, Worker Exposure Weighing Matrix:  The worker exposure weighing matrix
    is a 3x3 matrix used to quantify the level  of exposure to humans who are in direct or indirect
    contact with the compliance site.  The  horizontal axis determines the boundary  or  amount of
    exposure based upon the compliance site physical setting.
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The vertical axis quantifies the number of individuals who are within the compliance site's physical
boundary during the most active one-hour period of its operation.  The choices are greater than 5
individuals, 1-5, and 0. When there is usually no one at or around the compliance site, worker traffic
is scored 0. The worker exposure matrix is consulted to determine the score that can range from 1-5.
                                          BOUNDARY

                  Within a room that
                       is either
                  unventilated or has
                   a floor area less
                   that 400 square
                         feet
 Indoors greater than
  400 square feet or
    outdoors with
obstructions (such as
a wall) within 20 feet;
 Outdoors but
   with no
 obstructions
within 20 feet.
            Table 26: Risk Score/Rank, EWM, Worker Exposure Weighing Matrix
    Risk Score/Rank, Om  Operational Complexity Additive  Matrix:   The operational  complexity
    matrix is a 3x3 matrix used to quantify the degree of sophistication and complexity of both the
    compliance  site  operation and  the  individuals  who perform  operations  associated  with the
    compliance  site.  One axis  measures the level of automation  - fully automated  where the
    instrumentation performs all  of  the  operations,  partially automated where the operator  must
    perform some of the operations, and manual  where  the operator  must perform all of the
    operations.  The second axis measures the operator skill level - trained operator who must make
    decisions and take action to operate the compliance site, a skilled operator who only must follow
    directions  from a procedure, or an  unskilled operator who just observes  the  instrumentation
    associated  with the compliance site operation and who must notify others before action can be
    taken.
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              AUTOMATION

                PARTIAL           FULLY
          Table 27:  Risk Score/Rank, OAM, Operational Complexity Additive Matrix
•   Risk Score/Rank, NAM Container Additive Matrix: The container additive matrix is a 3x3 matrix
    that quantifies the  number and size of containers associated with the compliance site and is only
    to be used for sites with drums or cans equal to or less than 55 gallons in size.  If not applicable, a
    0 should be entered.  The horizontal axis describes the number of containers - greater than 25,
    11-25,  or 10 or less. The vertical axis describes the container size - 55 gallons, 1-55 gallons, or
    less than 1 gallon.
NOTE: This factor is only for containers up to 55 gallons. For larger containers / tanks a score of 0 is
given.
                                      NUMBER OF CONTAINERS
                                               11-25
>25
10 or less
                Table 28:  Risk Score/Rank, NAM, Container Additive Matrix
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•   Risk Score/Rank, Lm  Containment Additive Matrix:  This matrix  quantifies the degree of
    containment associated  with the compliance site.  The horizontal axis addresses secondary
    containment - none,  partial containment or a floor with  drain(s), and  complete containment (at
    least 110% of the largest vessel's contents).  The vertical axis addresses the environment where
    the compliance site is located - underground, outdoors or indoors.
NOTE:  If containment is not an appropriate factor for this compliance site, enter 0.  In general, this
factor applies to tanks, containers and process operations.
                                      SECONDARY CONTAINMENT
                                NONE
PARTIAL
FULL
               Table 29: Risk Score/Rank, LAM,Containment Additive Matrix
•   Risk Score/Rank, Score: This is the comparative risk score calculated according to the following
    equation.
Risk Score/Rank, Score = CWE * FWF - HWF - MWF - PWF * RWF * EWM * ((OAM + NAM + LAM)/S)
•   API 32-7080 Reporting, Hazard Percentile (%): This is the percentile for the site's comparative
    risk score calculated within the table. As the percentile increases, the comparative risk increases.
•   API 32-7080 Reporting, Risk Level: The table divides the risk rankings into quartiles from top to
    bottom and assigns extremely high, high, medium, or low rankings as shown in the following table.
                           Hazard Percentile       Risk Level
                                               Extremely High
                                                    High
                                                   Medium
                         	|     Low
                       Table 30:  AFT 32-7080 Reporting Risk Levels
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                                     Appendix D
                    SAMPLE STATEMENT OF WORK (SOW) FOR CONTRACTOR

                  SUPPORT IN CONDUCTING PROCESS SPECIFIC OPPORTUNITY
                                      ASSESSMENTS (PSOA)
  1.1 Resources:
  1.2 The contractor shall provide  all  resources, e.g. materials,  labor,  tooling, equipment and
      facilities necessary to fulfill  the requirements of this Statement of Work (SOW), except  as
      otherwise specified.
  1.3 Applicable Documents/Information:
  1.4 Air Force Instruction 32-7080, "Compliance and Pollution Prevention," draft, 26 May 2000
  1.5 Air Force Materiel  Command  (AFMC)  Compliance Through Pollution Prevention (CTP2)
      Implementation Guide (May 2001)
  1.6 Purpose and Background:
  1.7 The PSOA is an important phase of the Air Force's Compliance Through Pollution Prevention
      approach to reduce  environmental compliance cost and risk (burden) at its installations. The
      goal is to reduce the installation's compliance burden by focusing on the burden associated
      with individual compliance sites. Sites are then ranked ordered according to their burden and
      bundled together to form logical groups or processes. These processes are then assessed to
      identify changes to reduce the compliance burden and/or improve operating efficiencies.
  1.8 This SOW covers contractor efforts required to  assist with the execution of the  PSOA(s) of
      the following process/processes:  (insert process(s)) at (insert installation  name) Air  Force
      Base (AFB).
  1.9 Specifically  the contractor will  assist   (insert  installation  name) AFB's  Environmental
      Management function and  members of the PSOA  team(s) to  conduct PSOA(s)  of the
      identified functions in accordance  with the latest AFMC PSOA guidance. This assistance will
      include facilitating the PSOA(s), performing much of the work associated with the steps in the
      PSOA(s) and completing the final report. It could also include support for any briefings and
      discussions conducted with the process owner(s) and decision maker(s).
  1.10       The contractor will be provided access to the available input/output data associated
      with the process(s)  to be  studied.   This will include information such as compliance site
      inventory data, hazardous  material (HAZMAT)  use,  hazardous waste   (HAZWASTE)
      generation, air emissions generated,  compliance site inventory data, utilities, labor, supplies,
      production schedule/reports, etc. This information may be in the form of past studies, reports,
      or queries/retrievals  of management  information systems or access to  individuals who have
      this information or  knowledge of it.  The  contractor can expect that some  of the this
      input/output data will include summary reports,  studies, management  information systems,
      etc. for all of (insert the installation's name) AFB and that some effort will  be required  to
      extract the data specific to the process(s) being studied. The contractor should anticipate that
      not all of the data outlined in the PSOA guidance might be available.  This does not excuse
      the contractor from completing the required PSOA(s).
  1.11       The contractor will also be provided information on previous opportunity assessments
      accomplished at the installation related to the process(s).  The contractor should expect to
      perform some research on studies, assessments, reports, etc. accomplished in the Air Force,
      Department of  Defense, Federal Government  and  industry on  the  process(s) or related
      process(s) being assessed as indicated in the PSOA guidance. Some additional research will
      be necessary to determine the capital investment cost, operating and maintenance costs and
      estimated impact on the process  operating  costs and environmental compliance burden for
      the solutions/process alternatives identified.
  1.12       The final PSOA  report includes an Executive Summary, a Microsoft Excel workbook
      including the numerous worksheets documenting the data collected and developed during the
      PSOA and any other information as indicated in the PSOA guidance.
  1.13       Deliverables/Milestones:
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  1.14       PSOA Execution Plan/Schedule for process(s) - Insert Date
  1.15       PSOA Progress Report(s) - Insert Date
  1.16       Draft Process Diagram Worksheets for process(s) - Insert Date
  1.17       Draft PSOA Report for process(s) - Insert Date
  1.18       Final PSOA Report for process(s) - Insert Date
  1.19       Price:
  1.20       The terms of this SOW will be firm fixed price.
  1.21       All invoices shall be mailed to the following address - (Insert Billing Address)
  1.22       The contractor will submit the invoice for the full amount will be submitted at the end
      of the project. Payment will be made within thirty calendar days of receipt of invoice.
  1.23       Materials, Equipment and Facilities Used by the Contractor:
  1.24       The contractor is expected to provide all resources to support this SOW.  However,
      some data will be provided to the contractor when performing the PSOA.  Any data provided
      to the contractor for use in performing this SOW will be returned to (insert name of individual
      and organization) within two workdays of completing the final deliverable detailed in Section 4.
      Any equipment or facilities  used by contractor will be returned in working  order or in the
      condition received by the contractor at the completion of the SOW.
  1.25       Requirements:
  1.26       The  contractor will be responsible for completing the PSOA(s) for the process(s)
      identified in Section 3 following the deliverable schedule in Section 4.
  1.27       The PSOA(s) will be  accomplished in accordance with AFMC PSOA guidance.
  1.28       The contractor will accomplish any research needed to accomplish the PSOA(s).
  1.29       The  contractor will  accomplish any data collection  required to  accomplish the
      PSOA(s).
  1.30       The contractor will obtain any coordination by  the applicable process owner(s) and
      decision maker(s) necessary on the PSOA product(s).  The contractor will obtain appropriate
      approval before obtaining this coordination.
  1.31       Each PSOA final report will include an Executive Summary, Microsoft  Excel workbook
      and any other supporting data as outlined  in the AFMC PSOA guidance.  The contractor is
      responsible for developing the various elements of the PSOA final report
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                                       Appendix E
                                  PSOA SOLUTION SELECTION TOOL
The objective of this solution selection process is to assist installations in determining the  most cost
effective P2 alternative(s) that will eliminate or minimize the risk and lower environmental compliance
costs at their installation. The following sub-objectives will also be met:
•   Balance costs and risk when evaluating alternative P2 solutions
•   Minimize the amount of financial analysis necessary to make an implementation decision
•   Include environmental costs in the financial analysis
    E.1 PROCESS/METHODOLOGY
The solution selection process uses a three-step methodology in conjunction with a Solution Selection
Tool.  This methodology uses existing data collected and/or calculated  during the previous  phases of
the CTP2 process for the baseline process and any alternatives under consideration. The three steps
of the solution selection process are:
•   Step 1 - Prepare the Solution Selection Tool for use at the installation;
•   Step 2 -  Load the data associated with the P2 alternatives/solutions in the Solution Selection
    Tool; and
•   Step 3 - Rank the P2 alternatives/solutions using the Solution  Selection Tool.
The methodology uses CSI, PSG and PSOA information as inputs to a  computerized tool to rank and
select the best alternative(s)/solution(s).  This  enables  the user to make a final selection  with  a
minimum number of data inputs and limited financial expertise.
The data used in the tool and for the solution selection process includes existing:
•   Environmental compliance (EC) cost and risk information associated with the process,
•   Capital cost associated with the alternatives/solutions,
•   Projected operating and maintenance costs associated with the alternatives/solutions,
•   Savings to the baseline process cost resulting from the alternatives/solutions and
•   EC cost and risk reductions resulting from the alternatives/solutions.
    E.2 SOLUTION SELECTION TOOL
The Solution  Selection Tool included with this guidance document uses  the four worksheets listed
below to select the best alternative(s)/solution(s).
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        Worksheet
                                                    Purpose
       Instructions    This worksheet is the "Start Menu" for the tool.  It provides the user
                      with easy-to-use  buttons  to  access  the  other worksheets  and
                      background information about the tool and its use.
          Inputs
      Solution Rank
       Work  Data
                       This worksheet allows  the user to  load  data  associated  with  the
                       alternatives/solutions into the tool.  This worksheet is accessed from
                       the "Start Menu" by clicking on the "Load Solution Data" button. This
                       worksheet also includes instructions on loading the data.

                       This worksheet  provides the  user with several options  to  rank  the
                       alternatives/solutions. These options include Payback and EC Risk, Cost
                       or Burden Reduction  Scores.   This worksheet is accessed from  the
                       "Start Menu" by  clicking  on the "Solution Ranking" button.   This
                       worksheet   also     includes   instructions    on    ranking    the
                       alternatives/solutions.

                       Most of the tool's calculations are performed in this worksheet.  Users
                       need only access this worksheet one time to prepare the tool for use
                       at their  installation.  Caution should  be used when making changes to
                       this  worksheet - any  changes to the formulas in the  cells will impact
                       the operation of the tool.  This worksheet is accessed  from the "Start
                       Menu" by clicking on the "Work Data Sheet" button.
                      Table 31:  PSOA Solution Selection Worksheets
    E.3 STEP 1: SOLUTION SELECTION TOOL PREPARATIONS
The Solution Selection Tool was developed in conjunction with the AFMC PSOA Guidance through a
series of field tests of the PSOA concept.  The tool is designed for use with the installation's CSI.
(The sample tool supplied with this guidance is designed to be used to evaluate Robins Air Force
Base (AFB) PSOA solutions and, therefore is linked to that installation's  CSI) . The first and key step
in the solution selection process is to personalize the tool for use at the installation of choice.

    E.3.1 CSI Table Link Changes
The calculations  performed in the  Solution Selection Tool are incorporated in  the  "Work_Data"
Worksheet  of the tool.   This  worksheet  contains  the links to the installation's  current  CSI.   To
accomplish this change the user should:
    •   Open the Solution Selection Tool - Microsoft Excel workbook file, PSOA SST.xls
    •   Click on the "Enable Macros" button (see Figure 3)
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               Figure 3:  PSOA Solution Selection Tool Macro Warning Screen
The file will open.  The user will be asked to select whether you want to update all linked information
(Figure 4).  For  now, click on the  "No" button.   When  actually  using the tool  for selecting
alternative(s)/solution(s), click on the "Yes"  button.
                           I . t»r^vi«*l^irap«THr1.*7ii3rm r^tdwriBfe^ittai^fr*
          Figure 4:  PSOA Solution Selection Tool Automatic Links Selection Screen
The file will open at the tool's "Start Menu."  Click on the "Work Data Sheet" button on the menu (see
Figure 5).  The  user will then be taken to the "Work_Data" Worksheet of the tool.  Clicking on the
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button actually takes the user to the instructions/information section of the worksheet.  Simply use the
scroll bars on the side and bottom of the screen to view the worksheet data cells. Again, remember
all of the calculations on the data that the user enters into the tool are performed here.  Be careful
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when making changes to the various formulas in the cells of this worksheet - any changes will impact
the operation of the tool.  Preparing the tool for use at the user's installation should be one of the few
times necessary  to access  and make  changes to this worksheet.   You will also notice  that the
worksheet tabs are not visible in the tool (the Excel workbook). This was done to encourage use of
the functional buttons  and their associated macros that were built into the tool. If you prefer to see the
various worksheet tabs, simply click the "Tools" menu at the top of the Microsoft Excel window and
select "Options."   When the "Option Screen" opens, click the "Sheet tabs"  checkbox on the  View
menu and then click the "OK" button. The worksheet tabs (Instructions, Inputs,  Solution_Rank, and
Work_Data) will then  be visible.  Then the user can move to any worksheet of the tool by clicking on
the respective tab.
                     Figure 5: PSOA Solution Selection Tool Start Menu
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Scroll up and over in the "Work_Data" Worksheet until Column Q, Current Group Hazard Percentile,
is visible in your window.  Click on Cell Q2 (see Figure 6). This cell contains the first link to the CSI
file:
'C:\My Documents\PSOA\[Robins CSI Dec99.xls]CSI'!$AG$3:$AG$2770
It will be necessary to change this CSI reference and all others in the worksheet.
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Current Cell Q2:
       =IF(A2>"", IF(C2>AP2, 1, PERCENTRANK('C:\My Documents\PSOA\[Robins CSI
       Dec99.xls]CSI'!$AG$3:$AG$2770,C2,2)),"")

       New Cell Q2

       =IF(A2>"", IF(C2>AP2, 1, PERCENTRANK('C:\CTP2\CSI\[Edwards CSI
       Dec99.xls]CSI'!$AG$3:$AG$3090,C2,2)),"")
After making the  change, highlight and  copy the contents of the new Cell Q2.  Then click on  or
highlight Cells Q3 through Q26  in the same column.  Click on the "Edit" menu  at the top of the
Microsoft Excel window. Then click on the "Paste Special" option.  The "Paste Special" menu will
appear (see Figure  7).  Click on the "Formula"  option  button and then the "OK"  button.  This will
update all of the formulas correctly in the Current Group Hazard Percentile column of the tool. We
recommend users not use Excel's "drag  and copy" method to update the information in these other
cells because this method will also change/update the formatting in these cells.
             •: ^ H it "i r  t. :& B ••»  •- •    •, €
                 Figure 7:  PSOA Solution Selection Tool Paste Special Menu
There are several other  CSI references in the Work_Data Worksheet that will also have to be
changed for the user's installation. The specific columns that include these references are:
    •   Current Group EC Cost Percentile (Column T)
    •   New Group Hazard Percentile (Column AE)
    •   New Group EC Cost Percentile (Column AH)
    •   Max CSI Site EC Risk Score (Column AP)
    •   Min CSI Site EC Risk Score (Column AQ)
    •   Max CSI Site EC Cost Score (Column AR)
    •   Min CSI Site EC Cost Score (Column AS)
Table 32 will help the user identify the changes needed to CSI reference components to customize the
tool for use at their installation.  The information Table 32 is based on the standard CSI originally
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developed at AFMC installations.  If the number of compliance sites in these files has changed, the
user will need to adjust the listed data ranges.

      Installation
                            CSL File Name
                  CSI Reference Change

                               CSI Site Data Range
      Tool Default
       Arnold AFB
       Brooks AFB
      Edwards AFB
        Eglin AFB


      Hanscom AFB

        Hill AFB

      Kirtland AFB


    Los Angeles AFB

       Robins AFB


    Rome Laboratory

       Tinker AFB
       Columns              Columns           Columns
Q. T. AE. AH. AP-AS   Q.  AE. AP. AQ    T. AH. AR. AS


 Robins CSI Dec 99.xls   $A
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c (2 a
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    Figure 8:  PSOA Solution Selection Tool "Work Data" Worksheet Start Menu Return
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    E.4 STEP 2: LOAD SOLUTION DATA
    E.4.1 Getting Started
After the Solution Selection Tool has been customized for an installation, it can be used to evaluate
solution alternatives. The tool uses the solution data collected during the PSOA. To get started, click
on the "Load Solution Data" button on the "Start Menu" (see Figure 9).
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                    Process Spec/fie
                  Assessment fPSOA}
                Solution S&tectian Tool
                          Click Here
         Figure 9:  PSOA Solution Selection Tool: Loading Solution Data (Start Menu)
The tool will take the user directly to the instructions section of the "Inputs" Worksheet.

    E.4.2 Description of Solution Data Used
The tool uses the following solution information collected during the PSOA on solution alternatives:
    •   Initial capital cost such as the cost of any new equipment to implement the solution,
    •   Installation cost (i.e., new facilities, new utilities or other infrastructure, etc.) to implement the
       solution,
    •   New operating costs (i.e., utility charges, new materials, etc.) associated with the solution,
    •   New maintenance costs (i.e.,  recurring  training  requirements,  equipment  maintenance
       requirements, replacement components, etc.) associated with the solution,
    •   Changes in the process operating costs (i.e., labor, HAZMAT use,  HAZWASTE generation,
       etc.) resulting from implementation of the solution,
    •   Current EC recurring cost and risk score associated with the process and
    •   Any change to the EC recurring cost and risk score resulting from the solution.
All of this information is available  in the PSOA Opportunity Selection/Definition  (WS-4),  Individual
Solution (WS-6C) or Solution Summary (WS-6D) Worksheets
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    E.4.3 Loading Solution Data
By scrolling up the "Inputs" Worksheet, sample data from one  of the PSOA field test installations
loaded in the data cells will appear (Figure 10)

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                Figure 10: PSOA Solution Selection Tool  "Inputs" Worksheet
To clear this data, simply scroll down the screen using the scroll bar and click on the "Clear Input
Data" button (Figure 11).  This button runs a pre-programmed macro to clear all of the data fields.
The user can load information on up to 25 different solutions to compare/rank them.
The tool is configured to compare/rank solutions from more than one  PSOA at a time; note there is an
existing group/process EC recurring cost and risk score  data entry for each solution.  However, if
using the tool to compare solution options from the same PSOA, there is  no need to re-enter the
same existing EC cost and  risk score for each solution.  Just scroll down  the "Inputs"  Worksheet.
Notice the two data entry fields for the "Group EC Cost" and "Group EC Risk." Click on each of these
fields and make the  appropriate entries.  Then click on the "Load Group EC Cost/Risk Data" button
(Figure 12).  This button  runs a  pre-programmed macro to load this data into the applicable EC
recurring cost and risk score fields for all 25 solutions.
To load the  other data for each  solution option, either type in the data or use  a copy and paste
procedure from the data in the PSOA worksheets.
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                                                  IBH
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                                   Click to Clear
                                    Data Entries
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            Figure 11 PSOA Solution Selection Tool Clear Solution Data Option
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       Figure 12 PSOA Solution Selection Tool Loading Common EC Cost and Risk Data
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Unless evaluating solution alternatives from several PSOAs, it is possible to copy all of the other data
needed from the PSOA Worksheet WS-6D, Solution Selection Worksheet.  The data needs to be
copied in  three steps.   First, open  the  applicable  file for the  PSOA data,  then  move to PSOA
Worksheet WS-6D.  Click on the solution titles (column A of the worksheet) to be evaluated and copy
them  (Figure  13).  Unless the cost  associated with solutions in the  Demonstration/Validation  and
Research & Development solution categories was  estimated, the titles  copied will only be associated
with solutions in the Best Management Practice, Process Change and  Commercial/Government Off-
The-Shelf categories.

             • • • •
                 •             '«^«JjOi?»a*ji,

                Figure 13 PSOA Solution Selection Tool Copying Solution Titles
                               from PSOA Worksheet WS-6D
Now return to the "Inputs" Worksheet of the Solution Selection Tool.  Then click on Cell A3 of the
empty worksheet. Click on the "Edit" menu at the top of the Microsoft Excel window.  Then click on
the "Paste Special" option.  The "Paste Special" menu will appear. Click on the "Values" option button
and then the "OK" button (Figure 14). This will paste all of the solution titles in the "Proposed Solution
(Title)"  column of the tool.  It is recommended that users not use the paste only (or paste button)
method to update the information in these cells because these methods will also change/update the
formatting in these cells.
Now repeat the process by returning to the  PSOA Worksheet WS-6D.  Click on the cells containing
the solution related costs for those solution titles and copy the information  (Figure  15). Return to the
"Inputs" Worksheet of the tool and click on  Cell B3 (Figure 17).  Use the "Paste  Special" option as
described  above to  paste the data into the  tool.  This will  paste  the solution cost data into the
applicable fields of the tool.
Return  to the PSOA Worksheet WS-6D. Click on the  cells containing the related Revised EC Cost
and Risk Score data and copy the information (Figure  15). Return to the "Inputs" Worksheet of the
tool and click on Cell  13 (Figure 16). Use the "Paste Special" option as described above to paste the
data into the tool.
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               t* W*>
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    Figure 14 PSOA Solution Selection Tool Pasting Solution Titles in "Inputs" Worksheet
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                   *» Iff*1 "sr^n
             S yrHcJ SL'IT  *
Click Cell 13 to Paste
EC Cost & Risk Data
   Figure 16 PSOA Solution Selection Tool Pasting Other Solution Data in "Inputs" Worksheet
When comparing solution alternatives from several different PSOAs, follow the same procedures as
outlined above except enter or copy the solution information from several PSOA WS-6D Worksheets
(one for each PSOA involved).  In addition, since  there will also be several different processes
involved, enter the Existing EC Recurring Cost and Risk applicable  to each process and the solution
options for that process.  This information is available in the  PSOA Opportunity Selection/Definition
Worksheet, WS-4.  Follow the same  copy and  paste method  described above when loading this
information in the Tool.

    E.4.4 Completing the Data  Loading Process
Once alternative solution data  has been entered or copied in to the tool, alternatives can be evaluated
and ranked.  Scroll down the  "Inputs" Worksheet and click on the "Start Menu" button. This button
and the associated pre-programmed macro will link back to the opening screen for the Tool.
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    E.5 STEPS: RANK SOLUTIONS
    E.5.1 Getting Started
To begin the final step of the solution selection process, click on the "Solution Ranking" button on the
"Start Menu" (Figure 17).
The tool will take you directly to the instructions section of the "Solution_Rank" Worksheet.
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    •   EC Burden Reduction Score.  This option considers the EC burden reduction achieved  by the
       solution.  It also considers the existing process EC burden prior to implementing the solution.
       When selecting this option, solutions with the highest overall scores move to the top.
To  compare/rank solution  alternatives, simply click on  the  "Rank"  button in  the  column of the
worksheet corresponding to the preferred option.
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                                                                                Click to Restore
                                                                                 Original Order
                             *- dt-
                                                     ="- 5
             Figure 18 PSOA Solution Selection Tool "Solution_Rank" Worksheet
A pre-programmed macro will sort the appropriate data and re-arrange the solutions in the applicable
ascending or descending order based on the option selected.
To restore the solutions to the order entered, click on the "Restore" button at the top of the column
marked "Solution Number" (Figure 18).

    E.5.3 Ranking Considerations
The ROI  Payback in Years option, that considers the process cost savings, EC cost savings and the
cost for implementing the solution is recommended option for ranking solution alternatives.  However,
the amount and type of information collected during the PSOA may lead one to consider the other
ranking options.
If little information was available on the  process and solution implementation costs during the PSOA,
or if this  information does not vary much between solutions, the user should  consider ranking the
solutions  by the EC Risk, Cost, or Burden Reduction Score options. The overall impact of the majority
of the solutions (i.e.,  it is likely that your PSOA solutions will not impact the overall burden significantly,
but instead more readily impact one of the burden components - cost or risk) will determine which of
these options to use. The recommended priority of these options is burden, cost and then risk.

    E.6 OTHER TOOL TIPS


    E.6.1 Background on CSI Links
Step 1 of this guidance customized the tool for use at your installation.  That procedure established
links between the Solution  Selection Tool and  your installation's CSI. These CSI links enable the tool
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to compare the existing EC cost and risk of the process on which you accomplished a PSOA to EC
cost and risk data in the CSI.   The links  also enable similar comparisons of any changes to the
process EC cost and  risk  resulting from  your solution  alternatives.   More details  on  how this
comparison actually works are contained in Appendix F. At this point, these comparisons are "artificial
or pseudo" comparisons because process data is not currently stored in the CSI.  The tool actually
compares the process  EC cost and risk data entered to the corresponding compliance site data.
However, as the CTP2 process evolves in AFMC, CSI grouping exercises will be accomplished at the
installation to identify candidate processes for PSOAs.  The resulting data from these exercises will
likely be added to the CSI or stored in some related  file.  At that time, the links in the tool will need to
be re-established.

    E.6.2 CSI  Link Updates
As explained in Step 1 the tool actually looks at the range of compliance  site EC risk scores and cost
data in Columns  "AG" and "O" of the CSI file. When the CSI  file is changed to incorporate process
related data, fields will likely be added  that  include  EC cost and risk scores for the processes.  To
update the tool the user would follow the same procedures as outlined in Step 1.  Instead of entering
the  data ranges  outlined in  Table  32, the user would substitute the  new data  ranges (column
references) for the process EC cost and risk  scores in the CSI file.

    E.6.3 Making Tool Copies
As the tool is used for evaluating PSOA solution selection alternatives, the user may find it necessary
to make additional  copies.  Simply use the  "Save As" feature  of Microsoft Excel to accomplish this.
When making copies, it is recommend that each copy contain all the pre-programmed macros needed
for its operation.  To check this,  click on the "Tools" menu at the top of the Microsoft Excel window,
scroll down to "Macro" and then select  "Macros".  A window will pop open showing a list of macros
(Figure 19).  Be sure to select "This Workbook" option in the "Macros in:" drop down menu box area.
If the copy does not contain the macros, follow the "copy a  macro module to another workbook"
procedures in the Microsoft Excel Help information to copy the macros from the original copy of the
tool to any others.
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                                      OS 7
                                  il
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               Btlll
 Be Sure to Click on
"This Workbook" Here
             Figure 19 PSOA Solution Selection Tool Macro Pop Up Window
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                                     Appendix F
                      How THE PSOA SOLUTION SELECTION TOOLWORKS
The Solution Selection Tool uses the data listed below and entered by the user for each solution
alternative to calculate a ROI Payback in Years and EC Cost, Risk and Burden Reduction Scores
for that alternative. A solution can receive a maximum score of 10 points for each of the EC Cost,
Risk and Burden Reduction  Scores
•   Initial Capital Cost such as the cost of any new equipment to implement the solution
•   Installation Cost (i.e.,  new facilities, new utilities or other infrastructure, etc.) to implement the
    solution
•   New Operating Cost (i.e., utility charges, new materials, etc.) associated with the solution
•   New  Maintenance  Cost  (i.e.,  recurring   training requirements,  equipment maintenance
    requirements, replacement components, etc.) associated with the solution
•   Process Operating Cost Changes (i.e., labor, HAZMAT use, HAZWASTE generation,  etc.)
    resulting from implementation of the solution
•   Current Process EC Cost
•   Current Process EC Risk Score
•   New Process EC Cost resulting from the solution
•   New Process EC Risk Score resulting from the solution
    F.1 RETURN ON INVESTMENT (ROI) PAYBACK IN YEARS CALCULATION
The tool calculates the Payback as follows:
Payback = Capital Cost Score /Annual Savings, where:
•   Capital Cost Score = Initial Capital Cost + Installation Cost, and
•   Annual Savings = Process Operating Cost Changes - [New Operating  Cost + New Maintenance
    Cost] + [Current Process EC Cost - New Process EC Cost]
    F.2 EC COST, RISK,  AND BURDEN REDUCTION SCORE CALCULATIONS
   Weighted    EC   Cost   Reduction    Score.      This   score
    components.       The    first   addresses    the    Current
Max Score =  10
                                                                               two
                                                          	 Cost.
The second addresses the percent savings of the New Process EC Cost.
   For the first component, the Current Process EC Cost is compared to the compliance site EC
   Cost in the CSI database; the tool calculates the rank (percentile) of the Current Process EC
   Cost as a percentage of the site EC Costs. If the Current Process EC Cost is greater than the
   maximum, it automatically receives the highest percentile rank (100%).  Based on this
   percentile, the tool assigns a subjective rank (Highest, High, Medium, Low, or Lowest) to the
   Current Process EC Cost following the same procedures used in the CSI.  This component
   then receives a score as follows:
                     Current Process EC Cost Rank    Score
                                Highest                5

                               Medium                3

                                Lowest                1
      Table 33:  PSOA Solution Selection Current Process EC Cost Rank Scoring
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       Admittedly, this is an "artificial" comparison because the Process EC Cost
      represents the sum of the EC Cost of all the sites in the process. Later when
   Process EC Costs are included in the CSI, this comparison can be changed and will
   represent the true ranking of the subject process. To avoid calculation errors in the
       artificial comparison, the tool also checks the maximum EC Cost in the CSI.
                                                                              Score
      For the other component, the tool calculates the percent savings in Process EC Cost.
•         Percent Savings = [Current Process EC Cost - New Process EC Cost] /
                              Current Process EC Cost
                                     > or = 66%
                                > or = 33% and < 66%
                                  > or =0 and < 33%
                                        = 0
                Table 34:  PSOA Solution Selection Percent Savings Scoring
The scores for the two components are then combined to make up the Weighted EC Cost Reduction
Score. The maximum Weighted EC Cost Reduction Score is 10.
•  Weighted  EC  Risk Reduction Score.  This score  is based on two  components.   The first
  addresses
  addresses
  Score.
                the
                the
Current
percent
Process
reduction
EC
 in
 Risk
the
Max Score =  10
second
  Risk
     For the first component, the Current Process EC Risk Score is compared to the compliance
     site EC Risk Scores in the CSI; the tool calculates the rank (percentile) of the Current Process
     EC Risk Score as a percentage of the site EC Risk Scores. If the Current Process EC Risk
     Score is greater than the maximum, it automatically receives the highest percentile rank
     (100%). Based on this percentile, the tool assigns a subjective rank (Extremely High, High,
     Medium, or Low) to the Current Process EC Risk Score following the same procedures used in
     the CSI. This component then receives a score:
                    Current Process EC Risk Score Rank    Score
                               Extremely High                 5
                                   High                     4
                                  Medium                    3

      Table 35: PSOA Solution Selection Current Process EC Risk Score Rank Scoring
        \dmittedly, this is an "artificial" comparison because the Process EC Risk Score
      represents the sum of the EC Risk Scores of all the sites in the process. Later when
       Process EC Risk Scores are included in the CSI, this comparison can be changed
        and will represent the true ranking of the subject process. To avoid calculation
      errors in the artificial comparison, the tool also checks the maximum EC Risk Score
                                       in the CSI.
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      For the other component, the tool calculates the percent reduction in Process EC Risk Score.
        Percent Reduction in Process EC Risk Score = [Current Process EC Risk    Score
         Score - New Process EC Risk Score] / Current Process EC Risk Score
                                     > or = 66%                                   5

                                   > 0% and < 33%                                 1
                                        = 0%                                      0
    Table 36:  PSOA Solution Selection Percent Reduction in Process EC Risk Score Scoring
The scores for the two components are then combined to make up the Weighted EC Risk Reduction
Score. The maximum Weighted EC Risk Reduction Score is a score of 10.
•  Weighted   EC  Burden  Reduction  Score.    This  score  is  based   on two  components:
   The     Current      Process     EC      Burde
   Process EC Burden resulting from the solution.
Max Score = 10
                      change
in
      The Current Process EC Burden is calculated using the same procedures for calculating the
      compliance site EC Burden in the CSI table. The tool uses the Current Process EC Cost rank
      (Highest, High, Medium, Low, or Lowest), Current Process EC Risk Score rank (Extremely
      High, High, Medium, or Low) and the guidelines in the draft API 32-7080 to determine a
      Current Process EC Burden rank (Extremely High, High, Medium, or Low). Both the Current
      Process EC Cost and Risk Score ranks are calculated as indicated in previous paragraphs.
      This component then receives a score as follows.
                       Current Process EC Burden Rank   Score
                                Extremely High


                                   Medium
                                     Low
         Table 37:  PSOA Solution Selection Current Process EC Burden Rank Scoring
      For the other component, the  tool first determines the New Process EC Burden rank by first
      calculating the New Process EC Cost and Risk rankings resulting from the solution (i.e., the
      New Process EC Cost and Risk Score is compared to the cost and risk scores in the CSI
      database). Then these rankings are used to calculate the New Process EC Burden for each
      solution. The tool then calculates a score for that New Process EC Burden as follows:
                        New Process EC Burden Rank  Score
                                Extremely High             5


                                   Medium                3
                                     Low                  1
                         If all compliance sites eliminated      0
          Table 38: PSOA Solution Selection New Process EC Burden Rank Scoring
      Then the tool makes the computation below to determine the score for the change in the
      Process EC Burden  component. A  maximum score of 5 is possible for this component (i.e., all
      compliance sites for a process with  an Extremely High burden were eliminated)
                             Change in Process EC Burden Score =
               [Current  Process  EC Burden Score - New Process EC  Burden Score]
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The scores for the two components are then combined to make up the  Weighted EC Burden
Reduction Score. The maximum Weighted EC Burden Reduction Score is a score of 10.
    All calculations to support the Return on Investment Payback and Weighted EC Cost,
    Risk, and Burden Reduction Scores are accomplished in the "Work_Data" Worksheet.
    Therefore, care must be used when making any type of changes to this worksheet -
                      changes will impact the tool's operation.
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United                                      States
AIR FORCE MATERIEL COMMAND

     Compliance Through Pollution Prevention
                       (CTP2)
                       Appendix G
             PROCESS SPECIFIC OPPORTUNITY ASSESSMENT (PSOA)
                         GUIDANCE MANUAL
           Prepared for.
           311 HSW/XPE
           Brooks AFB, TX
                      31 January 2001
                          GSA contract:
                         GSOOTOOAC4131
  Prepared by:
MELE Associates, Inc.
  Brooks AFB, TX
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AFMC has conducted "fence-to-fence" P2 Opportunity Assessments (OA) for several years in order to
reduce hazardous waste production, cut costs, and/or meet environmental compliance objectives.
Fence-to-fence P2  OAs typically covered an entire installation in  an  attempt to  identify obvious P2
opportunities that could be easily addressed.  In addition to the  fence-to-fence OAs, a number of
focused studies were done, for instance, on an installation's solid waste or on types of processes.
The fence-to-fence  approach was done to comply with existing Department of Defense (DoD) and Air
Force (AF) P2 requirements to reduce the pounds of hazardous waste generated. Although many of
the P2 OAs that were done in the past contain valuable technical information, there was no focus on
compliance burden, nor on return on  investment; and many  P2 projects were implemented without
evaluating or documenting their effectiveness.

   G.1 OVERVIEW

To address  these  shortfalls,  AFMC  developed  the PSOA  methodology that  applies opportunity
assessment  methodology  in a  focused manner to minimize costs while  maximizing return on
investment. The methodology works best on an industrial process  although it is flexible enough that it
can be applied to other groups.  The methodology has been developed from standard techniques that
have proven to be effective within industry and government. It is consistent with the methodology that
will be described in  the new USEPA guidance. It is an improvement over the current system because
it is focused, standardized, reproducible, and  results-oriented.  In addition, it is structured  to first
search available AF and DoD resources to determine what has been done or is being done to address
the issue.  It is designed to be facilitated or conducted by either installation personnel or a contractor-
someone who has been trained to perform the methodology.  The methodology allows for input from
any prior successful P2 projects;  however, it also promotes new,  "out of the box" thinking and
solutions.
PSOAs produce prioritized lists of potential solutions that fall into one of five categories.
•  Best Management Practices (BMPs), things that are very easy
   and quick to do
•  Process   Change   (PC),  usually  not  requiring  a  capital       pc
   expenditure                                                       \M
                                                                     **» Process
•  Commercial    Off-The-Shelf   Technologies    (COTS)   or            improvement
   Government Off-The-Shelf Technologies (GOTS)
•  Demonstration/Validation (DEM VAL)                              DEM
•  Research and Development (R&D)
Solutions within  each of the five categories are ranked according to
effectiveness, ability to implement and cost.
A cost analysis  is accomplished on all potential solutions in the first three categories.  This analysis
considers the reduction in environmental compliance costs and risk as well as Total Ownership Cost
(TOC) to the greatest extent possible. Emphasis is placed on capturing those costs that will change
because of solution implementation.
Solutions are sufficiently documented to  provide the appropriate decision maker all the information
necessary to make  an  informed decision as to whether or not to implement any solution and what its
overall impact will be upon the subject process.
 Each step of the methodology is documented electronically in a worksheet that is stored in a master
 file (Microsoft Excel workbook) for that particular PSOA.  Copies of the worksheets are presented in
               Appendix G1. All PSOAs are in turn stored in the AFMC PSOA file.

This methodology also includes a process characterization tool that can be used to document process
specific information.  Most of the process, material and cost information is collected during the
process-diagramming phase. This information can be invaluable to overall process operation.
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At the end of the PSOA, and with the concurrence of the process owner, any recommended solutions,
together with all supporting data should be transmitted to the CTP2 team for further action.  The
completed PSOA should also be added to the AFMC PSOA file.


    G.2 PLAN AND SCHEDULE PSOA's

The CTP2 coordinator should work to plan and schedule PSOAs. The CTP2 team approves the plans
and schedule for the individual PSOAs and oversees the PSOA process. Some of the questions that
should be asked during the planning and scheduling process include:
•   Which PSG has the greatest compliance burden?

•   What are the financial and technical resource requirements for the PSOA?
•   What are the available financial resources?
•   Is the  in-house  expertise  adequate to  generate  compelling  sets of  P2
    opportunities?
•   Is there a need for external contractor engagement?
•   Will the PSOA be completed within the time schedule?
•   Can a complicated PSOA  be conducted  by a  subcontracting organization within the available
    budget?
•   What are the PSOA team member availability constraints?
                                         PSOA Steps
     A full PSOA consists of the following seven sequential steps.
     •   Develop background information.  Find out as much as possible about the selected process and
        related processes and historic P2 activities.
     •   Form the PSOA team, a team  of individuals that know and understand how the process runs
        and other experts such as individuals from the  installation's Environmental Management (EM),
        Bioenvironmental Engineering, and Unit Environmental functions.
     •   Characterize the process using  process diagrams.
     •   Select a process step, or steps, that have a significant opportunity for improvement.
     •   Conduct a root cause analysis to determine the underlying cause of the opportunity.
     •   Develop a list of potential solutions.
     •   Draft an Action Plan for each potential solution.
    G.3 STEP 1:  PSOA BACKGROUND DEVELOPMENT

In  preparation for the PSOA, the CTP2 team first prepares worksheet WS-0 (see Appendix G1),
Process Description Information, for the selected process(es).  This worksheet is used to define the
process and the related compliance sites being considered for the PSOA.
The  CTP2 team  then  identifies  completed, ongoing and planned studies that include previously
accomplished P2  OAs for the selected process(es). The information sources for this research fall into
two categories: (1) those that must be checked, and (2) those that should be checked.

    G.3.1 Must Check Resources

       Certainly, the first place to begin is within the facility itself. For example at Air Logistics
       Centers (ALCs), several organizations will likely have evaluated P2 alternatives for many of
       the compliance site groups (or processes). At every installation, there exists a myriad of
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      organizational resources to find the past work conducted on a given process.  One place to
      look is previous P2 OA efforts and P2 Management Action Plans.  For example, if aircraft
      depainting is being considered for a PSOA, the first organization to approach is Logistics.
      That is, find the organization responsible for the process; they are  most likely accountable for
      P2 improvements or have specific and viable ideas on how the process can be revised to
      reduce costs. Again, look for information on past OAs or alternatives for the process. Even
      though some facilities adopted the fence-to-fence approach to generate an array of P2
      options, many specific studies were completed that may essentially represent a PSOA for the
      process being considered.

      It is also critical to canvas other organizations that may have undertaken various pertinent
      studies on improving the process, without directly conducting a PSOA. These include
      process evaluations conducted  by installation Technology & Industrial Support (Tl) functions,
      the Air Force Center for Environmental Excellence (AFCEE), Special Program Offices,
      Integrated Product Teams, System Managers, Weapon System transition teams, or special
      task force groups that have gathered specific data on the process  (e.g., Coating Technology
      Integration Office). In addition, the HQ AFMC/CEV CTP2 Coordinator should  be aware of the
      findings of several Air Force organizations that may have previously examined the process in
      detail. HQ AFMC/CEV media specialists may also be aware of viable and proven methods,
      process changes and material substitutions that have worked for the process or similar
      processes. The AF, Army and Navy have compiled a series of Model Shop reports, which
      cover many types of waste generating processes and activities and include P2 alternatives.

      More information about these and other "must check" sources are listed in Appendix G2

  G.3.2 Should Check Resources

      An extensive array of external sources also exists which should be examined during the
      PSOA background development. These include the USEPA, Department of Energy (DOE),
      the National P2 Roundtable and others. These resources can provide some indication of
      performance and the overall success of certain implemented options, and document state-of-
      the-art technologies and  methods appropriate to specific processes and operations.

      More information about these and other "should check" sources are also listed in Appendix
      G2.

  G.3.3 Go/No Go Decision on Need  for PSOA

      After examining the P2 OAs and other studies related to the process that have been
      documented either in the AF, other agencies and departments of the government or by a
      relevant industrial operation, the CTP2 team may determine that these prior studies provide
      workable  solutions.  In such cases, a PSOA may not be required.  However, the CTP2 team
      should bring this information to the  attention of the appropriate process owner.

  G.3.4 Preliminary Data Collection

      If a PSOA is required, the CTP2 team should next collect some preliminary data on the
      process.  Here, other organizations having information about the process or the relevant
      compliance sites should  be contacted. Again, if aircraft depainting is being considered for a
      PSOA, the first organization to approach might be Logistics. At this point, the data has to do
      only with establishing the magnitude of the waste generation, air emissions, HAZMAT use and
      other issues such as worker safety. The installation HAZMAT Management Process (HMPP)
      team can  help in collecting this preliminary data on the process. You should also look at the
      base wide multi-media studies that were done in the early 1990s to document the initial P2
      baseline data. Organizations like Bioenvironmental Engineering, Safety, and the HAZMAT
      Pharmacy should be contacted; and individuals such as the EM media specialist should  be
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      interviewed. The purpose of these contacts is to: collect the relevant process data and
      identify potential team members for conducting a PSOA.

      Existing environmental reports and management information system(s) should  be queried for
      any information on the installation's Toxic Release Inventory (TRI) and targeted chemicals, air
      emissions, and hazardous waste generation related to the process or applicable compliance
      sites.  This information should be available in the EM or P2 organizations or from the
      individuals responsible for compliance with the respective media of concern. Many times,
      time-consuming review of individual files or manifests can be avoided by asking the media
      specialist to query the information management system they use to produce regulatory
      reports.

      Appendix G3 contains some suggested sources for background data related to typical
      processes that may be looked at under a PSOA.

      It is a judgment call by the CTP2 Team to determine how much data is enough for this
      preliminary data collection effort. During the step where the team characterizes the process
      in the  PSOA, more detailed data can be collected. The review of past OAs, study efforts and
      related process data is not intended to restrict thinking "beyond the envelope", but  rather to
      ensure that previous work of others and existing information is incorporated into the PSOA.

  G.3.5 Background Information Documentation

      All of the background information about the process should be documented in worksheet WS-
      1, Process Background Information. Data sources should also be documented in worksheet
      WS-Data, Data Sources/Assumptions.

  G.3.6 Meet with Decision Maker (DM)

      This sub-step presents the PSOA process to the decision maker(s) for the selected process.
      It also defines the scope and expectations of the program and  establishes the resource
      commitments by all to the PSOA.

      First, the CTP2 team meets to:
  •   Identify the DM(s) for that process. The DM  is the individual who has the authority to commit
      personnel and resources to the assessment and to any resulting process related projects that
      the assessment identifies.  It is not unusual to have multiple DMs for a particular process. For
      example, one DM could be  responsible  for operation and  maintenance (O&M) while an
      entirely separate DM could  be responsible for the capital improvements in a facility.  Often
      times  a Weapon System Single Manager is a key DM.  The identification of the DM(s) (e.g.,
      position, name, telephone number as available, etc.) should also be documented in worksheet
      WS-1.
  •   Develop a strategy for presenting the proposed PSOA program to the DM(s).
  •   A presentation is made to the DM to sell the PSOA process and to obtain buy-in. A sample
      Microsoft PowerPoint presentation is included in Appendix G4.  Suggested topics/discussion
      items  (others should be added as needed)  include:
  •   Overview of PSOA process and the specific steps of the process
  •   Benefits to the DM
  •   Success stories
  •   Review of the "opportunity selection" hierarchy
  •   Identification of type/format of final report to maximize its value to DM
  •   Review of resource needs  and commitments/assignments,  including  use  of outside
      resources.
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    •   Proposed schedule for the PSOA

    G.4 STEP 2: FORM PSOA TEAM

The PSOA can be conducted with installation level personnel only, through contract resources, or a
combination of in-house and contract resources.  Because of the need to involve those individuals,
who know most about the subject process, a new team may be needed for each PSOA.  Additional
"experts" from the installation (such  as members  of the HMMP team) can supplement the team  as
needed.  The installation EM function director/manager determines how and by whom (e.g., CTP2
team/coordinator, P2 division  chief, etc.) the PSOA team members will be selected.  Some issues,
including the suggested skills and qualities  of the team members, to be considered are outlined below.

    G.4.1 Team Selection Considerations
    •   Determine  if the  PSOA  will be  conducted with  installation  resources only  or with the
       assistance of contract resources.
    •   Attempt to  limit the team to six individuals.  Large teams often have  trouble  in reaching
       consensus.
    •   The following representation should be considered.
       -   The installation CTP2 coordinator to provide a consistent PSOA approach across the
           installation
       -   The process owner or a designated representative. No one knows the process better.
           Unless this individual is part of the team, any solutions that result from the PSOA could  be
           difficult to implement.
       -   An experienced senior operator for the specific process. He/she understands the details
           of daily operation and how things are "really done."
           For ALC industrial shop type processes (e.g., plating shops), the process engineer can
           provide valuable information on how the process is supposed to run.
       -   The EM function media manager(s)/specialist(s) can provide information on waste
           generation and any environmental regulatory considerations that may impact solutions.
           Bioenvironmental  engineering personnel can provide information on occupational health
           considerations related to the process that may impact potential solutions.
    •   Depending on the number and type of PSOAs planned, some installations may find it more
       efficient to identify a few individuals that will comprise the "core" for all PSOA teams.
    •   Other qualities to consider in  selecting team members include:
           Commitment to the program
       -   Ability to participate effectively  in a team environment
           Creative thinking
           Receptive to new ideas and possible changes in the process
       -   Availability
           Positive attitude toward/interest in the PSOA program

       Besides conducting the actual PSOA, an important role of the team is to establish the "ground
       rules" for the assessment. The following are some of the issues to be considered when
       developing these "ground rules."

    G.4.2 PSOA Ground Rules Considerations
    •   Decide on how meetings will  be scheduled, run, documented, communicated, etc.
    •   Estimate time/resource requirements of all team members. Estimates can be refined as team
       members gain experience.
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    •   Establish the schedule and duration for each step of the PSOA.
    •   Define how team consensus will be  reached for decision items surfacing during the PSOA
       (e.g., simple majority, super majority,  unanimous vote on issue, etc.).

    G.4.3 PSOA Team Documentation

       The PSOA team membership and established "ground rules" should be documented in
       worksheet WS-2, PSOA Team Information.

    G.5 STEP 3:CHARACTERIZE PROCESS

Once  a decision has been made to conduct a particular PSOA and a team of process experts has
been formed, it is time to draw upon everyone's expertise to characterize the process.

    G.5.1 Review of Process Description/Background Information
The PSOA team starts with worksheet  WS-0, Process Description Information, which should be
provided by the installation CTP2 team or EM function.  The PSOA team then collects any information
not provided on the worksheet.  Start with the list of all associated compliance sites and their pertinent
information.  Add and subtract sites from the group as appropriate.  It may be necessary to make
"adjustments" to the  environmental compliance (EC) cost  and/or risk (compliance burden).  For
example, some compliance sites (e.g., those related to the installation's water distribution  system or
Treatment, Storage and Disposal Facility) are likely to be applicable to many of the processes being
assessed.  However,  the associated EC costs or risks for these sites may need to be prorated by
some  factor  (e.g.,  process water  usage/total  water consumption,  process  HAZWASTE/total
HAZWASTE generated).  Any changes or adjustments made should be documented on worksheet
WS-0. Since worksheet WS-1, Process Background Information, was created prior to the forming of
the PSOA team, it is also advisable to review the  information on this worksheet and make any
additions or revisions as needed. Some valuable input on past/current initiatives may be provided by
senior operator(s) on the PSOA team.

    G.5.2 Develop the Process Flow Diagram
Next,  a process diagram is developed using the procedure detailed below.  The team may want to
consider  assigning  one member of the team the task of developing this process diagram.  That
member would work with an individual most familiar with the process (e.g., floor supervisor, senior
operator, process engineer,  etc.) to accomplish this task.  The rest of the PSOA team would get
involved later in reviewing and identifying needed revisions to the diagram.
The process diagram  is actually developed through a series  of worksheets.  The process  diagrams,
which  are schematic (block flow) depictions,  should be developed using the conventional left-to-right
"input  - process - output" model techniques.
The selected process should first be broken down  into 3 to  6 steps in a top-level  process diagram
using  boxes to depict  the  series of steps through which inputs  must pass in the course of
transformation into a product.  The sequence is from left to right, with at least three but no more than
six steps in the sequence.  Draw lines to represent throughput.  Be sure to identify all the key steps of
the process. The steps are numbered sequentially (1 through 6). Be sure to define the boundaries of
the process in the diagram - where does it begin,  where does it end.  Where  necessary, provide
supporting text describing each step.  This top-level diagram (see Figure 20) should be documented
on worksheet WS-3, Process Diagram - Top Level.
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3
Upholstery
Shop


4
Tire Shop


5
Body
Shop


6
Quality
Assurance
                Figure 20 Block Flow Diagram (Top-Level), Vehicle Maintenance
For each step in the top-level that can be further broken down to more specific steps (3 or more),
create  a sub-level diagram  (see  Figure 21).   Detailed lower levels  should only be  used when
necessary.  When you cannot come up with at least three sub-steps, you probably do  not have to
break down the step to another sub-level.  Here again the steps are numbered sequentially, but use a
numbering convention to clearly link the sub-level back to the appropriate step in the top-level diagram
(e.g., 2.1 through 2.6). Steps, which represent ancillary or intermittent operations, should be clearly
identified (with an "A" or "I" designator and different border type).
Ancillary operations are done in support of the main process and  include cooling towers,  boilers,
compressors, water treatment, machine shops, wastewater treatment, laboratories, etc.
Intermittent operations are support operations, done intermittently and  include tank cleanings, fluid
changes, system start-up/shut down, etc.
Capturing these operations can later aid in  identifying contributing causes to the PSOA  opportunity.
Where necessary, always provide supporting text describing each  step.  Use worksheet WS-3A,
Process Diagram - First Sub-Level, to document any first sub-level diagrams (a separate worksheet
for each).
2.1
Steam Clean


2.21
Clean Out
Steam Pit


23
Inspect &
Diagnostics


2.41
Oil Analysis


2J
Repair, Replace,
Service
              Figure 21 Block Flow Diagram(First Sub-Level), Vehicle Maintenance
                                Step 2 (Maintenance Shop)
For some processes, it may be necessary to continue with subsequent sub-levels until the process
cannot be broken down further.   The same techniques  are  used as in  previous levels; again a
numbering scheme is used to clearly link the sub-level to the appropriate step (see Figure  22).  Use
worksheet WS-3B to document these sub-level diagrams (a separate worksheet for each).
1.2.1
_ _ , . . _. , .
Mechanical Blasting



12.2
r\ L. • I r^x •
Chemical Stripping
(Tanks 203,302)



12.3

Bake
               Figure 22 Block Flow Diagram (Second Sub-Level), Chrome Plating
                           Step 1.2 (Strip Old Plating From Part)
The entire process is then captured on worksheet WS-3C, Process Diagram - Summary.  You should
be sure the diagram  shows the interdependency  between  the various steps of the  process and  it
should set the sequence and relationship of material flow through the process (see Figure 23).
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                J   '^-^T,,,,,,,   j
                                                ,....,,.       ,,
                  Figure 23 Block Flow Diagram (Summary), Chrome Plating
Now go back to the top-level process flow diagram (worksheet WS-3) and develop a flow diagram
showing how the process  fits in the next highest level process(s) (see Figure 24).  Doing so often
helps identify the relevancy of the process being assessed to the installation mission and will assist in
identifying  other relevant decision maker(s).  Document this diagram in worksheet WS-3D, Process
Diagram - Predecessor Level.
The series of worksheets used to capture the flow diagrams for the process are not self-generating.
However, they are easily created using the spreadsheet cell formatting options, drawing tools and the
copy and paste features available in the standard Excel software.
         Figure 24 Block Flow Diagram (Predecessor Level) Chrome Plating Operations
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Now that the process flow has been identified, the PSOA team needs to identify the resources, inputs
and outputs (both product and non-product) associated with each of the steps in the process. This
information helps the team identify the potential opportunities  in the  process, their causes  and  in
selecting alternatives/solutions.  Here  the preliminary  data  collected during Step 1  will be used.
However, it is likely that the PSOA team will want to collect additional information after diagramming
the process workflow to get an even better understanding of the process.  Again, the team may want
to consider assigning one or two member(s) of the team the task of collecting this data.  The type  of
data sought includes labor,  materials  (HAZMAT and other  supplies), utilities,  personal  protective
equipment, HAZWASTE, solid waste, air emissions and the associated costs.  It is also very important
to capture any  unit  environmental  related  cost  (e.g.  unit environmental  coordinator efforts,
HAZWASTE handling labor, etc.).  Where actual data is  not available,  estimates are acceptable.
Possible information  sources include the  process owners/operators,  planning/scheduling functions
associated with the process, Base Safety, Base Supply, Bioenvironmental Engineering, Civil Engineer,
Contracting, EM function, Financial Management, HAZMAT Pharmacy, and the installation's Medical
Facility. Appendix G3 also contains some suggested source  documents for this data.  A block flow
diagram is also  used to graphically depict this information (see Figure 25).  The standard features  of
the Excel software are again used to create the block  diagrams. These diagrams begin to visually
focus in on the total ownership costs (TOC) associated with the process. The diagrams also clearly
identify the compliance sites and any directives (e.g., Technical Orders, Military Specifications, AF
Instructions, etc.) that are associated with the  process.  A separate diagram is developed for each  of
the lowest  level  steps.  The diagrams are documented  using worksheet WS-3E, Individual Step
Detailed Process  Diagram.  Here again it may be necessary to prorate some of the data  collected
(e.g., HAZWASTE generated, air emissions, etc.) using some  factor across several of the steps in the
process. For example, electrical usage might  be distributed across all of the process steps based on
the labor  hours for  the step.   Any data sources and  adjustments/allocations made should  be
documented in worksheet WS-Data.
              Figure 25 Process Step Details Vehicle Maintenance Step 5.4 (Paint)

    G.5.3 Review of the Process Diagram
The last and most important phase of this step is to verify the worksheets.  This should be done with
the rest of the PSOA team, other process supervisors,  operators or engineers and if possible the
decision maker(s).  The following questions should be considered to ensure the process diagram is
complete:
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    •   Have all of the steps of the process been identified?
    •   What are the directives governing the process (e.g., Technical Orders, Military Specifications,
       etc.)?
    •   What are the ancillary and intermittent operations?
    •   What are the product/non-product inputs and outputs?
    •   Have environmental, health and safety issues been  identified?
    •   Have the applicable compliance sites been identified?
    •   Has all available data including cost been collected?
The PSOA team then makes any additions/corrections to  the worksheets. The review is  continued
until all involved parties agree that it is accurate.

    G.6 STEP 4:  SELECT OPPORTUNITY

Using the information  collected in  worksheets  WS-3E, the team then selects one  or more of the
lowest level steps for further study.  This selection is based on risk, cost, complexity, HAZMAT use,
HAZWASTE generation, air emissions or other criteria. The intent is to focus in  on  a portion of the
process where a change  would  have the  greatest possible  positive impact (environmental burden
reduction, cost savings, labor reduction, etc.).  If the selection criteria have not been  pre-established
by the installation and/or AFMC, the PSOA team can consider the following hierarchy when making its
selection:
•   Environmental compliance risk (risk of non-compliance)
•   Environmental compliance cost
•   Occupational health and safety concerns
•   Operating cost
•   HAZMAT used
•   HAZWASTE generated
•   Air emissions generated
•   Greatest number of inputs/outputs
This suggested list is not all-inclusive and should be revised by the PSOA team to fit the needs of the
installation.  The hierarchy should  also be modified  to include process  specific issues from the
process owner/decision maker.  The PSOA team  makes its selections, which become the process
"opportunities", using the ground rules previously established and documented in worksheet  WS-2.
The selection  is documented on worksheet WS-4, Opportunity Selection/Definition.   A separate
worksheet should be  used for each opportunity selected.  Each worksheet should include a simple
block diagram showing where the opportunity fits in the process. The worksheet also includes a list of
the compliance sites applicable to the opportunity  (e.g., most likely a subset of the sites identified  for
the process in worksheet WS-0) and any adjustments made to the compliance site data.

    G.7 STEP 5:  ROOT CAUSE ANALYSIS OF  SELECTED OPPORTUNITY

The PSOA team then uses root cause analysis to  examine  the opportunities.  The team identifies the
specific problem/issue for each opportunity to be  addressed.  The issue/problem is  the "effect" the
team will focus on.  The  team then identifies the "causes" behind the effect. A cause and effect
(fishbone) diagram may be used  in the process.  It is extremely important that the team explores all
possible causes. After identifying the causes, they should be reviewed and grouped where similar.
The following discussion  illustrates the thought process to  use in this analysis. All PSOA team
members should participate in this step.
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    G.7.1 Identifying the "Effect"
A clear definition of the problem/issue that the team will focus on is critical.  Take time to clearly
articulate the  problem/issue.  Take time to  review the process diagram worksheet(s) and selection
criteria that were used to identify the opportunity.  Then re-state the problem/issue as a specific effect.
Some  examples include "using too much solvent", "generating  too much waste",  "labor-intensive
operation", "too much time spent on clean up", "repetitive/fatigue causing operation", "too much
rework required on the process products" and "long exposure to HAZMAT".

    G.7.2 Identifying "Causes" for the Effect
Next, the team will identify the specific drivers or what is known  as the "causes" behind the effect.
Team  members should  first consider some general  open-ended questions.   What  caused the
problem/issue?  Why does it exist?  Where did it start?  Why is it tolerated?  The answers to these
questions will  help the team to start focusing in on the "causes".  Following the same pattern, the team
should then consider and develop the answers to more specific questions related to the effect.   To
help in this effort the team should look at four general cause categories:
    •   People, (including surroundings),
    •   Materials,
    •   Methods, (including directives/procedures) and
    •   Tools & Equipment.

    G.7.3 The "People" Cause Category
Here the  team and questions should focus on the process workers. Do they follow standards?  Are
they experienced?  Are they adequately trained to do their assigned tasks? Are they receiving on-
going training? How is their performance measured? Are they aware of any problems? What is their
rework rate? Who is accountable for the process?

    G.7.4 The "Tools & Equipment" Cause Category
Here the  team and questions address the tools, equipment and facilities associated with process.  Do
they meet production requirements?  Is the latest technology employed? Are there unscheduled down
times? Is the layout adequate?  Are the temperature and humidity adequate? Are the lighting and
ventilation adequate? Are there enough mechanics? Is preventative maintenance being used?

    G.7.5 The "Materials" Cause Category
Here the team and questions focus on  the  process materials.   Are there problems with grade or
purity? Are there unacceptable impurities? Is the inventory level adequate? Are there problems with
material acquisition? Are there any problems with the brand name?  Is there any waste in material?
Are issue quantities a problem? Is material  handling adequate?  Is the quality standard adequate for
the  process?  Is the material regulated?  Are there published substitutes for the material?

    G.7.6 The "Methods" Cause Category
Here the team and questions  address the methods used in the process.  Are the work standards
easily  understood?   Are the  standard  operating   procedures  verified   and  utilized?    Do
standards/directives  preclude implementing better procedures?  Does the method  ensure  a good
product?   Is it an efficient method?  Is the sequence of work adequate? Are the setup procedures
adequate? Are there safety concerns? Is inspection adequate?

    G.7.7 Completing the Cause Identification Process
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Team members should continuously ask "why" with respect to the identified effect.  After each why
question is answered, ask why again.  It is only with this type of repetitive questioning/discussion that
the true "causes" or drivers behind the process and the problem/issue can be ascertained. There may
be technical  reasons that mandate the process, but even these should be questioned, relative to the
possibility  of alternative processes and/or chemical inputs.  The basic four cause categories can  be
modified and may even branch into sub-categories where specific issues (e.g., Technical Orders or
Military Specifications) are examined and analyzed. The PSOA team should strive to identify at least
20 or so causes for the effect(s) selected.  The team should group similar causes where applicable.
Clearly stating the  cause is also extremely important.  The team will use these causes to identify
potential solutions/alternatives in the next step.

    G.7.8 Analysis Documentation
Worksheet WS-5, Root Cause Analysis, is used to document the analysis efforts.  The worksheet
provides areas to identify the "effect", a fishbone diagram to identify causes in the four categories and
any grouping of the "causes" decided on by the team.

    G.8 STEP 6: DEVELOP POTENTIAL SOLUTIONS

The root cause analysis provides the ideal lead-in to developing solutions.  After thoroughly analyzing
the opportunity, identifying the problems/issues/effects and discussing/consolidating causes, the team
should  move right into solution generation from the root cause analysis. Here again all of the  PSOA
team should participate.  The team may also consider having  other individuals participate, who may
be more  familiar with  the details of some of the  causes  identified during the previous step (e.g.,
technical  orders, standard operating procedures, process worker training, process equipment, etc.).
The team  should consider conducting this solution identification phase near or in the  process location
to encourage participation by those most familiar with the Process.

    G.8.1  Identifying  Solutions
There are  many ways to develop a list of potential  solutions in a group/team environment.  Probably
the most familiar is "brainstorming", where  participants call  out solutions that are written down by a
group recorder.  Later these ideas are reviewed, modified, deleted or grouped  together  by the
participants.   Large sheets of paper or "post-it" notes can be used to facilitate these brainstorming
sessions and capture the ideas that surface. Brainstorming is probably the most common and fastest
technique  for collecting ideas from a team/group.  Other techniques, however, are available such  as
those where team members anonymously write down ideas on paper slips, which are  later reviewed
and consolidated by the other members. This method may encourage individuals to participate who
may have  reservations about verbally  identifying solution ideas in front of other team members. The
PSOA team should use the procedure that best suits its team members.
The basic objective of whatever method selected is to facilitate total team participation and creative
thinking.  Team members should continuously refer back to the "effect and causes" identified  in the
previous  step during  this solution identification  phase.    No  idea  is too  far "bizarre" for initial
consideration. Concepts such as the following should be considered:
    •   Material or chemical substitutions
    •   Changes in material specifications
    •   Eliminating the process entirely
    •   Significantly changing the process
    •   Outsourcing the process
    •   Health protection and safety procedures
    •   Purchasing procedures
    •   Personnel requirements
    •   Equipment  changes


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    •   Facility modifications
    •   Process utility usage changes
The  list of solution ideas from the team  should  be documented on  worksheet WS-6,  Solution
Development.   Each worksheet includes space  for ten (10) solutions;  additional copies of the
worksheet should be used as necessary.

    G.8.2 Solution Categories
The team should next group the solutions into the following five categories:
    •   Best Management Practices (BMPs):  These solutions are administrative in nature, involving
       changes in procedures under process owner control.  There is generally no need to take
       these beyond the process supervisor for approval. They will usually be short term and easy to
       implement. Typically, these solutions  involve little or no cost. These solutions also normally
       have minimal impact on environmental compliance cost/risk (burden).
    •   Process Change  (PC):  These solutions can be as simple as changing a valve or pump,
       changing or eliminating a fluid or adding a piece of equipment such as a filter.  The capital
       expenditure for this type of solution is generally low in comparison with the capital cost of the
       process itself.  There are four  general types of process changes  depending upon the
       decision-making level  required for implementation.  The appropriate type should be noted
       along with the process change.
           Process owner
           Installation
       -   Major Command (MAJCOM)
       -   Air Force
    •   Commercial or Government Off-The-Shelf Technologies (COTS/GOTS): These solutions are
       generally available as vendor packages and  good cost information about them should  be
       readily available.  The probability of success should also be well known from their use at other
       installations or prior demonstrations unless the technology is "brand new". If the past success
       of the solution is not well known,  it should probably be put into the Demonstration/Validation
       category.
    •   Demonstration/Validation (DEM/VAL):  These solutions are usually not available  off-the-shelf
       and are in some sort of developmental stage. Typically, some sort of  laboratory and/or pilot
       scale simulation or test run must be performed to demonstrate the viability and economics of
       the solution.  The potential savings from these solutions can be estimated, but normally
       sufficient information is not available to determine return on investment.
    •   Research  and Development (R&D): These are solutions that impact the installation mission
       or Air Force or have DOD-wide applicability, probably require  considerable R&D beyond
       environmental considerations and likely require approval at the highest level even to pursue.
       Solutions  of this type  should be reviewed for a  possible base request for Strategic
       Environmental Research and Development  Program  (SERDP)  or Environmental  Security
       Technology Certification Program  (ESTCP) funding or forwarded to AFMC for command-wide
       action.  Generally, a review/analysis will be performed at headquarters to identify common
       issues/solutions for any future evaluation.  As with the DEM VAL category, potential savings
       can be  estimated  but normally sufficient information  is not available to determine any return
       on investment.
The team documents the associated categories for the various solutions in worksheet WS-6A, List of
Potential Solutions.

    G.8.3 Initial Prioritization of Solutions
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After all solutions are grouped  in the five categories, the  team then accomplishes a preliminary
ranking  of the solutions within their respective categories  based  on the  solution's impact  on the
process and environmental compliance burden and the ease of implementing the solution. The team
should consider the following when prioritizing the solution ideas.
    •   Process Impact:  Does the solution resolve or mitigate  the process problem/issue originally
       identified?
    •   Burden Impact: Does the solution result in eliminating compliance site(s)?  Does it lower the
       environmental compliance risk?
    •   Compliance Cost  Impact: Does the solution lower the cost of compliance and by how much?
       Any cost analysis here will be for screening level purposes only.  Use readily available cost
       data known to those on the team. If available data is insufficient to make a determination, set
       aside the ranking process until the appropriate "comfort level" of cost data can be obtained.
    •   Implementation Concerns: How long will implementation take? Has a similar solution been
       implemented successfully at other installations?  What are the resource requirements needed
       to implement the  solutions?  What are the mission implications?  What are the  engineering
       requirements?       Are    there    infrastructure     (facility   renovations/requirements,
       utility/communication  issues, security requirements, etc.) implications  associated with the
       solution? Does the solution require item manager approval or a Technical Order change?
By discussing the benefits of each solution, the team should  be able to  rank the solutions in the
respective categories.  The team  documents  the  results  of  this ranking in  worksheet  WS-6B,
Prioritized List of  Solutions.   Note  any information used to prioritize  the  solution  (e.g.,  cost,
implementation schedule,  resource requirements, etc) and any  impact upon the process (e.g., staff
reduction, different materials usage, shorter processing time,  etc)  in the  comment column  of the
worksheet.  The team should also note in the comments those  solutions that are not recommended
for implementation and the reason why. Be as specific as possible when entering comments on the
worksheet.
The worksheet WS-6B is not self-generating.  However,  this worksheet is easily created from the
information already entered in worksheet WS-6A using the copy and paste features available in the
standard Excel software

    G.8.4 Follow-on Actions for Recommended Solutions
The team then completes  worksheet WS-6C,  Individual Solution  Worksheet,  for  each  solution
recommended for implementation.  When describing the solution, the team should include on the
worksheet any impacts on other processes, sub-processes or  compliance sites resulting from the
solution. The team accomplishes a  revised environmental compliance cost and risk estimate for all
solutions in the BMP, PC and COTS/GOTS categories. Where possible and feasible, this calculation
should also be done for any recommended solutions in the DEM  VAL and R&D categories. The team
may find  the Decision Tree  Diagram  in Appendix G5  helpful  when  considering the  revised
environmental compliance cost and risk for a solution.  The team should consider all of the changes to
compliance sites  associated with the opportunity  selected when recalculating the  environmental
compliance  burden  realized  from implementing  a solution.  It may be  necessary  to recalculate
compliance site(s) risk factor(s) using the Compliance Site Inventory risk algorithm for a solution. The
team also documents the results of the environmental compliance cost and risk analysis on worksheet
WS-6C.
In addition, some additional cost information should be generated for each solution in the BMP, PC
and COTS/GOTS  categories.  This information includes the  capital investment needed to implement
the  solution  (including any installation  costs), any operation and maintenance cost (e.g., recurring
inspection costs, equipment maintenance costs, etc.)  associated with implementing the solution and
any changes in the annual process operating costs resulting from the solution  (e.g., reduced labor,
reduce material cost,  etc.). The  cost information should be obtained from the best available sources
including the following:
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    •   Vendor quotations
    •   Information available in other OAs/studies about similar solutions
    •   Air Force financial management data
    •   Air Force environmental data sources
    •   Literature data, including public and military Internet sites
    •   Industrial studies
This cost information and the sources used should be  documented in  worksheet WS-6C.   Use
worksheet WS-6D, Solution Summary, to summarize the information from the  individual WS-6C
worksheets

    G.9 STEP 7: DRAFT ACTION PLAN FOR SOLUTIONS

The worksheets prepared during the PSOA process should be  assembled into a package with any
other forms, documents, etc., used.  It is very important that all data sources and/or assumptions are
documented in worksheet WS-Data. It is also helpful to create a Table of Contents worksheet, WS-
TOC, to identify the worksheets included in the package.  Using the Excel standard tools, you can
hyperlink the various worksheets to worksheet WS-TOC. This  enables the reader/reviewer to move to
any worksheet in the package quickly.  The team  should then  prepare a short (approximately two
page) executive summary for the PSOA. The executive summary should include the following areas:
•   PSOA Background.  This section summarizes the  rationale for the  selection  of the subject
    process for a PSOA.  It lists the organizations involved,  PSOA Team Chief, and any Process
    points of contact (POCs).  It also includes any relevant issues encountered during the PSOA (e.g.,
    assumptions, data collection issues, rationale for limiting scope of PSOA, etc.).
•   Process Overview.  This section presents a brief description of the subject process including its
    annual operating  cost, environmental compliance burden impact, etc.
•   PSOA Findings. This section summarizes the opportunities selected by the team, rationale for the
    selection, causes behind the opportunities and potential solutions/alternatives.
•   Recommendations.   This section  summarizes the recommended solution(s) identified by the
    team.  It also  includes a summary of proposed follow-on actions and benefits from implementation
    of the solution(s).
The executive summary with the worksheets and any other documents used becomes the final PSOA
report.

    G.9.1 Decision Maker Coordination
After completing the PSOA report, the team should  present the results to the DM to determine which
recommendations, if any, should be  pursued.  DM concurrence should be attained before any
recommended solutions are presented to  the CTP2 Team.   If the DM rejects all the solutions, the
PSOA team can either re-accomplish the PSOA process to generate additional solutions, modify the
PSOA to reflect the DM's input or drop the PSOA.  The DM  may also identify additional processing
requirements that are needed  for implementing some of  the solutions.  For example,  some could
involve changes to Air Force directives  or Technical Orders, which may require special forms such as
AFTO Form 22 for approval.  Any information such as  this  should  be entered  in  the appropriate
solution worksheet for the PSOA. Where possible the team  should also draft any required form(s)
and include them  in the PSOA report.
After obtaining DM coordination, the team should forward the  resulting  package(s) to the CTP2 team
with a transmittal  letter showing the recommendation(s) for each category signed by the PSOA team
leader.

    G.9.2 Follow-on Actions
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The CTP2 Team has the overall responsibility of taking action on the potential solutions.  Some will be
subjected  to a more detailed  cost/return on investment  analysis and eventually  funding through
AFMC's P2 program using the Pollution Prevention Program Narrative (PPPN) process or through an
alternative funding source. The purpose of the analysis is to determine which solutions offer the best
return on  investment when considering operating cost  savings,  environmental compliance burden
savings and overall payback. Some members of the PSOA team may be asked to participate in this
analysis effort and in the preparation of any needed PPPN(s). Others solutions may be forwarded to
specialized working groups/offices for action such as the Coating Technology Integration Office. DEM
VAL and R&D type solutions validated  by the CTP2 team will be forwarded to AFMC to be considered
for technology requirements calls for follow-on work by research agencies such  as AFRL.
          All identified solutions are included in the PSOA Solutions information. Those
            solutions that the installation wishes to pursue are identified with a valid
                                    Selected Solution FY.
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                        APPENDIX G1
                       PSOA Worksheets
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PSOA Process:
Building No(s)./Location:

Installation:
                                                      Project No.:
                                                      Prepared by:
                                                      Checked by:
                                                      Page:
                                             Date:
                                             Date:
TABLE OF CONTENTS

         Worksheet

         PSOA WS-0
         PSOA WS-1
         PSOA WS-2
         PSOA WS-3
         PSOA WS-3A
         PSOA WS-3B
         PSOA WS-3C
         PSOA WS-3D
         PSOA WS-3E
         PSOA WS-4
         PSOA WS-5
         PSOA WS-6
         PSOA WS-6A
         PSOA WS-6B
         PSOA WS-6C
         PSOA WS-6D
         PSOA WS-Data
                                                  PSOA WS-TOC
           Title

Process Description Information
Process Background Information
PSOA Team Information
Process Diagram - Top Level
Process Diagram - First Sublevel
Process Diagram - Subsequent Sublevels
Process Diagram - Summary
Process Diagram - Predessesor Level
Individual Step Detailed Process Diagram
Opportunity Selection/Definition
Root Cause Analysis
Solution Development
List of Potential Solutions
Prioritized List of Solutions
Individual Solution Worksheet
Solution Summary
Data Sources/Assumptions
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PSOA Process:
Building No(s)./Location:

Installation:
                                                        Project No.:
                                                        Prepared by:
                                                        Checked by:
                                                        Page:
                                                        Date:
                                                        Date:
PROCESS DESCRIPTION INFORMATION

Process Operation:	
                                                                PSOAWS-0
Operation Type:
(circle one)
Batch/Semi Batch
Continuous
                                               Discrete
                                               Other
Describe the process:
List all associated compliance sites:
Site Number  Site Owner
                      Type
                                                          EC Risk
                                                                        Adjusted

                                                                   EC Cost    EC Risk
            Calculate "process" compliance cost and risk:

                        Calculate adjusted "process" compliance cost and risk:

Explain any adjustments made:
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PS OA Process:                                        Project No.:
Building No(s)./Location:                                  Prepared by:        Date:
                                                     Checked by:        Date:
Installation:                                            Page:
PROCESS BACKGROUND INFORMATION                                           PSOAWS-1

  Process:

Decision Maker(s):             Name             Organization        Phone
    Single Manager:
  Capital Investment:
             O&M:
            Other:
Must Check Resources:                  Results
Installation:
Prior P2 OAs
Existing P2 MAPs
Basewide multi-media baselines
Owning organization studies/reports
SGB
Safety
HAZMAT Pharmacy
EM media specialists
EM information system

 External:
HQ AFMC/CEVV
AFCEE
AFRL
AEC field reports
DoD
ESOHTPIPT
ESTCP
NDCEE
PEWG
SERDP

Additional Resources Checked:
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PSOA Process:
Building No(s). /Location:
Installation:
PSOA TEAM INFORMATION
Project No.:
Prepared by: Date:
Checked by: Date:
Page:
PSOAWS-2
PSOA Team Members
Name Organization E-l*








i/lail Phone Fax








Team Ground Rules:
Document team ground rules including how meetings will be scheduled, run and documented. How will
minutes/activities be communicated to others. Schedule blocks of time for the PSOA team members. Secure
team commitment. Document how consensus will be reached (i.e., majority, super majority, etc.). Establish
mechanism for dispute resolution should disagreements arise. Document all decisions below.

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PSOA Process:                                           Project No.:
Building No(s)./Location:                                    Prepared by:        Date:
                                                        Checked by:        Date:
Installation:                                               Page:
PROCESS DIAGRAM - TOP-LEVEL                                                     PSOA WS-3

Create the top-level of the process diagram. Use boxes to represent the worksteps in the process.  Start at the
top-level using between 3-6 boxes (steps).  Within the boxes, each work step is described by a phrase, such as
clean, paint, dry, etc. Number the boxes 1 through X going from left to right. The initial top-level diagram is only a
broad overview.

Document the top-level diagram below.
Document the supporting text that describes the function of each step.
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PSOA Process:                                            Project No.:
Building No(s)./Location:                                     Prepared by:         Date:
                                                         Checked by:         Date:
Installation:                                                Page:
PROCESS DIAGRAM - FIRST SUB-LEVEL                                              PSOA WS-3A

Create the top sub-level process diagram for each step. Start with the first step and break it down to 3-6 more
detailed steps. If you cannot identify 3 sub-steps, do not break the step down. It is at its lowest level. Create as
many first sub-level steps as appropraite. Step 1  is broken down to first sub-level steps 1.1, 1.2, ...1.6.  Step2is
broken down to 2.1, 2.2, etc. Use as many pages as necessary. Clearly annotate any ancillary or intermittent
operations (use a suffix of "A" or "I").


Document the first sub-level diagram below for: Step
Document the supporting text that describes the function of each step.
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PSOA Process:
Building No(s)./Location:

Installation:
                                                        Project No.:
                                                        Prepared by:
                                                        Checked by:
                                                        Page:
Date:
Date:
PROCESS DIAGRAM - SUBSEQUENT SUB-LEVEL
      PSOAWS-3B
Create the subsequent sub-level diagrams for each first sublevel step. Step 1.1 is broken down to second sub-
level steps 1.1.1, 1.1.2, ...1.1.6. Step 2.1 is broken down to 2.1.1, 2.1.2, etc. Continue with each step until the
lowest level has been completed for each step in the previous level. Use as many pages as necessary.  Clearly
annotate any ancillary or intermittent operations  (use a suffix of "A" or "I").
Document the subsequent sub-level diagram below for: Step
Document the supporting text that describes the function of each step.
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PSOA Process:                                        Project No.:
Building No(s)./Location:                                 Prepared by:        Date:
                                                    Checked by:        Date:
Installation:                                           Page:
PROCESS DIAGRAM - SUMMARY                                               PSOA WS-3C

Recreate a summary diagram showing the entire process for each sub-level step. To higlight the lowest levels
for each step, you may want to circle them.
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PSOA Process:                                          Project No.:
Building No(s)./Location:                                   Prepared by:        Date:
                                                      Checked by:        Date:
Installation:                                             Page:
PROCESS DIAGRAM - PREDECESSOR LEVEL                                      PSOA WS-3D

Create the predecessor level of the process diagram. Use boxes to represent the work-steps/functions in the
process.  Number the boxes 1 through X, going from left to right. The predecessor level diagram is only a broad
overview.

Document the predecessor level diagram below.
Document the supporting text that describes the function of each step.
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PSOA Process:
Building No(s)./Location;

Installation:
Project No.:
Prepared by:
Checked by:
Page:
Date:
Date:
INDIVIDUAL STEP DETAILED PROCESS DIAGRAM
                        PSOAWS-3E
Use this worksheet to create the process diagram for each step.  Include all ancillary and intermittent support
operations and all non-product inputs and outputs.

   Step
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PSOA Process:                                             Project No.:
Building No(s)./Location:                                      Prepared by:         Date:
                                                          Checked by:         Date:
Installation:                                                 Page:
OPPORTUNITY SELECTION/DEFINITION                                                 PSOA WS-4

Using the criteria in Step 4 (Select Opportunity), define the opportunity selected
for assessment.  Identify the step level in the box and recreate the process          Step
diagram to show how the step fits in process.
List all associated compliance sites:
                                                                          Adjusted

Site Number Site Owner    Type     Category   Description    EC Cost     EC Risk    EC Cost    EC Risk
                         Calculate adjusted "process" compliance cost and risk:
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PSOA Process:
Building No(s)./Location:

Installation:
    Project No.:
    Prepared by:
    Checked by:
    Page:
Date:
Date:
ROOT CAUSE ANALYSIS
                               PSOAWS-5
Use a cause/effect diagram to conduct the root cause analysis of the selected opportunity.  Define the opportunity
as an effect (i.e., using too much solvent, generating too much waste, etc.). State the effect at the bottom of the
diagram. See Step 5 for questions to ask during the analysis.
      People
Materials


                                                                                      Opportunity
 Equipment & Tools
   X
Methods
Opportunity/"Effect":
Review all candidate causes, group like ones to develop a consensus list of P2 opportunities and list them below.
AFMC
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PSOA Process:
Building No(s)./l_ocation:

Installation:
Project No.:
Prepared by:
Checked by:
Page:
Date:
Date:
Solution Development
                       PSOA WS-6
                                         10
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PSOA Process:
Building No(s)./Location:
Base:
Project No.:
Prepared by:
Checked by:
Page:
Date:
Date:
LIST OF POTENTIAL SOLUTIONS
                        PSOA WS-6A
Use this form to group the list of potential solutions after brainstorming.  Use comment field for any notes.  Use
category column for grouping the solutions into 1 of 5 categories; BMP, PC, COTs or GOTs, DEM VAL, and
R&D.
          Solution No./Potential Solution
Comments
     Category
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PSOA Process:
Building No(s)./Location:

Installation:
                                             Project No.:
                                             Prepared by:
                                             Checked by:
                                             Page:
                                            Date:
                                            Date:
PRIORITIZED LIST OF SOLUTIONS
                                                                     PSOA WS-6B
Use this form to prioritize the list of potential solutions within categories. Use comment field for any notes.
Categories are BMP, PC, COTS or GOTS, DEM VAL and R&D. For the process change category, try to
determine the responsible party: process owner, Base, MAJCOM, or Air Force.  Document this in the comment
column.
 Priority
Category
Potential Solution
Comments
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PSOA Process:
Building No(s)./Location:

Installation:
                              Project No.:
                              Prepared by:
                              Checked by:
                              Page:
                    Date:
                    Date:
INDIVIDUAL SOLUTION WORKSHEET
                                                        PSOA WS-6C
                                      Solution Type (check one)
Solution #:
BMP
COTS/GOTS
R&D
Process Change
DEM VAL
Solution Description:
Compliance site cost and risk changes associated with solution:

Site Number  Site Owner            Type      Category    Description  EC Cost
                                                                     EC Risk
                                                        Adjusted
                                                 EC Cost    EC Risk
                                         Calculate adjusted "process" compliance cost and risk:
Costs associated with solution:

Capital Investment Costs:
Solution Operating Costs:
Solution Maintenance Costs:
Process Operating Costs Changes:


Sources of Cost Information:
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PSOA Process:                                           Project No.:
Building No(s)./Location:                                   Prepared by:        Date:
                                                       Checked by:        Date:
Installation:                                              Page:
SOLUTION SUMMARY                                                            PSOAWS-6D

Summarize the information from the individual worksheets WS-6C below
                                                                          Changes to:
                   Investment
Solution Description         Cost   Operating Cost         Maintenance Cost       Process Cost   EC Cost    EC Risk
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PSOA Process:
Building No(s)./Location:

Installation:
Project No.:
Prepared by:
Checked by:
Page:
Date:
Date:
DATA SOURCES/ASSUMPTIONS
                        PSOAWS-DATA
List all data sources, assumptions and/or estimates used in developing the other worksheets during the PSOA.
Aso include Points of Contact (POCs) and POC information for the data and/or estimates used.	
  iscription             Data/Source

Process Labor for Steps
Labor Cost
Compliance Sites Data
CSI Estimated Contributions

General Utility Data
Base Water Consumption
Utility Allocations (usage & cost)

Solid Waste

Solid Waste Allocations (Ibs/cost)

Air Emissions

Air Emissions Allocations

Non-Hazardous Supplies (usage & cost)

Process HAZWASTE data
HAZWASTE Allocation (Ibs/cost)

HAZMAT Use
HAZMAT Allocation (Ibs/cost)

Personal Protective Equipment
   Amount
   Cost
                                            Unit    POC
                                                              Organization
                       Phone     Comments
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                                    APPENDIX G2
               Resources for PSOA Background Development
The following resources MUST be reviewed for background development for each process.
                                       Air Force:
•  AFMC PSOA File
•  Air Force Center for Environmental Excellence (AFCEE):  AFCEE has a variety of P2 tools and
   listings  of   success   stories   that   have   resulted   largely   from   Pro-Act   inquiries
   (http://www.afcee.brooks.af.mil/pro act/ti/technical.htm                                     or
   http://www.afcee.brooks.af.mil/pro  act/success/success.htm). It is also advisable to request Pro-
   Act to do an independent review of processes where little is documented.  PRO-ACT reviews are
   free.  AFCEE's Process and  Potential Alternatives file contains information on potential changes
   and product substitutions that may be further evaluated and  tested for use with weapon systems
   (http://209.99.117.181/papa/papa.asp').
•  Air Force Research Laboratory (AFRL):   This  site  includes information regarding former and
   current research in the Air Force (http://www.afrl.af.mil/).
•  Coatings Technology Integration Office (CTIO): The CTIO improves coating system performance
   through the  integration  and transition of environmentally acceptable materials and processes for
   aircraft depainting,  cleaning,  surface   preparation,   coating   materials,  and   applications
   (http://www.ml.afrl.af.mil/facilities/ctio/).
•  Air Force Corrosion Protection Office: http://www.afcpo.com/.
•  HQ AFMC/CEV website: https://www.afmc-mil.wpafb.af.mil/HQ-AFMC/CE/cev2/.
•  Environmental, Safety  and Occupational  Health Technical  Planning Integrated Product Team
   (ESOH  TPIPT):    Identifies  specific   needs  and  tracks  progress  towards  solutions
   (http://xre22.brooks.af.mil/).
                                Department of Defense:
•  Army Environmental Center (field reports): http://aec.army.mil/prod/usaec/et/listweb.htm.
•  National Defense Center for Environmental Excellence  (NDCEE): The Center was established to
   address high priority environmental problems for DoD, other government organizations and the
   industrial  community.   Use  the  search engine  to  look for  pollution  prevention solutions
   (http://www.ndcee.ctc.com).
•  Joint  Services Pollution Prevention Library (JSPP):  The library includes the  following: 1) P2
   Opportunity  Handbook which identifies off-the-shelf P2  technologies, management practices, and
   process  changes;  2)  PPEP Book that  provides participants with  easy access to technical
   information  on items already under contact or under solicitation for contract  by the Navy;  3)
   Environmentally  Preferred Products is a catalog under development to purchase P2  products;  4)
   Joint  Group on P2 (JG-PP) which  is a repository for technical reports on P2  alternatives
   (http://enviro.nfesc.naw.mil/p2librarv).
•  Joint Group  on Pollution Prevention (JG-PP): (www.jqpp.com).
•  Propulsion  Working Environmental Group (PWEG):   Site addresses solutions for propulsion-
   oriented issues (http://www.pewq.com).
•  Strategic Environmental Research &  Development Program (SERDP):  This site  is the DoD's
   Corporate R & D program, which is planned and executed with the DOE and EPA. The program
   focuses  on  pollution   prevention,  cleanup,  compliance  and   conservation  technologies
   (http://www.serdp.org).
•  Environmental Security Technology Certification  Program  (ESTCP):   The site is  the  DoD's
   demonstration and validation program for promising new environmental  technologies.  The site
   includes a list of ongoing and verified P2 technologies (http://www.estcp.org).
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The following resources SHOULD be reviewed for background development for each process.
                                 Government Agencies:
•   USEPA: The USEPA has a warehouse of information that can be accessed and reviewed relative
    to specific  processes.  These include the Enviro$en$e  databases on solvent substitution and P2
    Vendors, Pollution Prevention Information Clearinghouse (PPIC), P2 Resource Exchange, and the
    Regional Compliance Centers.  Information is also available on numerous programs, which have
    been identified  as P2 success stories. These include the Design for the Environment, Research
    Triangle Institute and P2/FINANCE programs.  It is also important to examine the  resources of
    State Environmental  Protection Agencies.  Ohio, for example,  has an extensive library of P2
    resources,  including  lists of consultants and vendors who  specialize in  particular process
    solutions.
       Enviro$en$e: http://es.epa.gov/
       Design  for the Environment program: http://www.epa.gov/opptintr/dfe/
       Environmental Accounting Project: http://www.epa.gov/opptintr/acctg/
       Office of P2 and Toxins: http://www.epa.gov/opptintr/p2home/
       Pollution Prevention Resource Exchange: http://www.epa.gov/opptintr/p2home/p2rx.htm
       Pollution Prevention Information Clearinghouse: http://www.epa.gov/opptintr/librarv/libppic.htm
       Project  XL: http://www.epa.gov/ProiectXL/
       Sustainable Industry: http://www.epa.gov/sustainableindustrv/
       EPA Major Industry Information: http://es.epa.gov/oeca/sector/
       EPA's Waste Reduction Resource Center (WRRC):  This site contains a searchable index of
       over 13,000 technical articles, fact sheets and case studies about waste reduction
       (http://wrrc.p2pavs.org/).
•   Ohio EPA P2 List Servers: http://www.epa.state.oh.us/opp/p2lists.html
•   DoE's Pollution Prevention Information Clearinghouse:  This site provides valuable resources on
    P2 alternatives (http://epic.er.doe.gov/epic/).
                                     Private Sector:
•   Pacific  Northwest Pollution Prevention Resource Center (PPRC): This site is a national network
    of  regional P2 information centers.  The site identifies P2 project opportunities and ways to
    overcome barriers to P2 (http://www.pprc.org).
•   P2  GEMS:  Internet  search tool for facility planners, engineers  and managers looking for
    technical, process and materials management information (http://www.p2gems.org/).
•   Printed Wiring Board Resource Center: http://www.pwbrc.org/
•   Solvent  Alternatives Guide (SAGE):   SAGE  provides P2  information  on  solvent and process
    alternatives for parts cleaning and degreasing (http://clean.rti.org).
•   American Institute of Chemical Engineers Web Resources: http://www.aiche.org/resources/
•   Automotive Compliance Information Assistance Center:  http://www.ccar-greenlink.org/
•   National Metal Finishing Resource Center: http://www.nmfrc.org/
•   National Pollution Prevention Roundtable: http://www.p2.org/
•   Paints and  Coatings Resource Center: http://www.paintcenter.org/
•   Parts Cleaning  Information Clearinghouse: http://www.partscleaningweb.com
•   Research Triangle Institute Program: http://www.rti.org/units/ese/p2/programareas.cfm
•   Environmental Cost Analysis Methodology: http://www.ndcee.ctc.com/ecam
•   Global Environmental Management Initiative: http://www.gemi.org/docs/PubTools.htm
•   Pollution Prevention Finance: http://www.sgia.org/p2finance/
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                                 Appendix G3
        Other Resources for PSOA Background Data/Information
Air Emissions Inventory Data/Reports/Permits
Air Force Work Information Management System (WIMS)
Air Force Medical Service Command Core System
Automated Civil Engineering System (ACES)
Environmental Compliance Assessment Management Programs Reports
Environmental Compliance Studies
Environmental Management Information System (EMIS)
Environmental Status of Readiness Training System (ESORTS)
Federal Facilities Compliance Agreements
Hazardous Material (HAZMAT) Management System (HMMS)
Hazardous Waste (HAZWASTE) Tracking System (HWTS)
HAZWASTEW/HAZMAT Management Action Plans (MAPs)/Minimization Plans
Interviews (with EM Media Managers, Defense Reutilization Marketing Office and other applicable
personnel)
Material Safety Data Sheets (MSDSs)
Military Specifications (MILSPECs)
Special Program Office/Integrated Product Team Reports
Past Pollution Prevention Management Action Plans
Past Pollution Prevention Opportunity Assessments
Pollution Prevention Baselines
Process Workload Planning Documents/Schedule
Technical  Orders (T.O.s)
Toxic Release Inventory Reports
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                      APPENDIX G4
    PSOA Sample Process Owner/Decision Maker Presentation
               (Insert Functional Area)
            Process Specific Opportunity
               Assessments (PSOAs)

                     (Bri
        (Insert Briefer Information)
                      Objective
                      ©f oewy USAF "C
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                    Players
        PSOATetm
        - (Ust Environmental Management P©C)
          (List any Contractors on Team)
          Rending approval the following from your
           (Ust any Frr@©tss mentors you    on tut) team)
              Background
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                 CTP2 - What is it?
           Disdfuiirri® into n
is the Compliance Site

      "	 @f I
             Compliance Sites & You
         AFMC identified its "compliance sites'* at
         major installations in CY99
         Commonly referred to as the "Compliance
         Site Inventory" or CSI
         (Base) has over (insert f)     in its CSI
         Many of these "sites'* are assooiat
         ii
           Paint booths, HAZMAT use, oil     separators
                                     ;, ete.
AFMC
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                  CTP2 Approach
         Muli-step iippmadhj that     with the
         "compliance sites"
         Continuous
' Q@ through the
then repeat the
• Measurable and oan
                                     r^sylJts ninidJ
                   CTP2 Process
                                 o
                                 Op
                          Solution \Assess
                          Selection
AFMC
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                        PSOA
         Key CTP1 step is the PSOA
         Review & analysis that fo©yses
         identification ©f ^©pp©rtynitiesw
                             ts (OAs) are NOT
          SOA is a "new variation"
                                  e^ntrol,
                      Pre-PSOA
                  Wl
• Before starti
   r©©e
• Leads
                                must dJetenrtinie
                         compliance sites'* ©r CSl
                        CSl identified several
                          for oost risk
  area) in the 1
  enlire base
          or
          iift this funotiontl
• These were used as wp©injtersw to ©andidate
AFMC
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                      Pre-PSOA
       • Follow-on discussions with EH
         personnel on the CSl dJttt UttdJ to
         possifelt candidates
           within this functional area)
         BastdJ oo environmental i
         HAZMAT, air emissions, oil      sei
         tnd inputs torn your Ooi Environmental
                                  down
                 PSCW  Candidates
       • (Insert fundionall area) Inal candidlalles
         - (UiM your final 
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           PSOA
          Process
          PSOA Basic Steps
        ChifiiolteFiis
        Dtvtlop
        Frspars
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                PSOA Step Details
                    iiniteiffliiil
             • Meet with
             Form team
               Establish groyinidJ rules
                PSOA Step Details
              Diagram
AFMC
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               Characterize Process
                  DIAGRAM PROCESS
                     DEPAINTING
         Top Level
OICOI I
1

L^cpan IL
2

oiean
3
                                     Second Level
                               Third Level
               PSOA Step Details
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                                              Interim Final
                PSOA Step Details
             * Prioritiie solutions
             Prapiir@ Adionj Pltm
             •> Cost out solutions
              Document all
              Submit to       mtmt and others
            Process Resources Needed
              Tttm
          Shop For^man/NOOlO
          ' Supported by 80-100 hours of contractor /
          facilitator effort
          Labor Cost,, Material
          May iiovoll^ contact with others wyiit^inj your
          organization
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            Benefits for Process Owner
              at "whole pi
                         irtidipate
                 -j   -j   -j     •!
         Opportunities and solutions that surface are
         not limited] to strictly "environmental*
         Provides Process Ow^er with an overview of
         the Total Owynership Costs of       or
         operation
            Proposed PSOA Schedule
        Suggested] schedule
          materials^ environmental
         - Goal i§ miiftiimiii:© tim© wy@rk@r§
          FSOA team meetings
        Finish complete          by (insert finish
        date)
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            Process Owner Comments
          D@ you have concerns
                 ©thftrr
                 major activities planned wvhidft
                 Donflict
      * Dtdista Criteria
                     Summary
         Apprediite y©yr valytble tlmt art tht

         Vvii Wok this is ao ^coitjng program that mm
         ba ¥aiyafele to yjm, tht iostaiiati©o and AFHC
         Questions ©r Comments?
AFMC
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                                    APPENDIX G5
                     EC Cost/Risk Decision Tree Diagram
                                                                 Delete site(s)
                                                                recalculate group
                                                              EC costs & risk score
                                                              on worksheet WS-6C
                                                               Recalculate site(s) &
                                                              group riskscore(s) and
                                                                 document on
                                                               worksheet WS-6C
                  Check if solution will reduce
                 EC costs associated with any
                    compliance site(s)
                                                               Recalculate site(s) &
                                                               group EC costs and
                                                                 document on
                                                               worksheet WS-6C
AFMC
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                              Appendix H
                              ALLOWABLE PSG NAMES
PSGs are named on the basis of the following codes contained in ACES.  Names consist of the
Common Activity Code with Method Code appended.  For example, mechanical depainting would be
DPT1120.
            Common Activity
                 Descriptio
                 ^^^^^^^
ABA  ABATING - ASBESTOS
ABA  ABATING - ASBESTOS
ABA  ABATING - ASBESTOS
ABA  ABATING - ASBESTOS
ABA  ABATING - ASBESTOS
ABA  ABATING - ASBESTOS
ABL  ABATING - LEAD
ABL  ABATING - LEAD
ABL  ABATING - LEAD
ABL  ABATING - LEAD
ABL  ABATING - LEAD
ABS  ADHERING/BONDING/SEALING
ABS  ADHERING/BONDING/SEALING
ABS  ADHERING/BONDING/SEALING
ABS  ADHERING/BONDING/SEALING
ABS  ADHERING/BONDING/SEALING
ABS  ADHERING/BONDING/SEALING
ABS  ADHERING/BONDING/SEALING
AD-  ASSEMBLING/DISASSEMBLING
AD-  ASSEMBLING/DISASSEMBLING
ADM  ADMINISTRATING
ADM  ADMINISTRATING
AET  TESTING - AIRCRAFT ENGINE
AET  TESTING - AIRCRAFT ENGINE
AET  TESTING - AIRCRAFT ENGINE
AET  TESTING - AIRCRAFT ENGINE
AET  TESTING - AIRCRAFT ENGINE
AET  TESTING - AIRCRAFT ENGINE
AST  STORING - ABOVE GROUND STORAGE
     TANKS
AST  STORING - ABOVE GROUND STORAGE
              Method
                Description
               ^^
1038   BLASTING
1062   ENCAPSULATING
1096   GLOVE BAGGING
1151   SCRAPPING
1161   STRIP
1191   ALL METHODOLOGIES
1038   BLASTING
1063   ENCAPSULATING
1151   SCRAPPING
1161   STRIP
1191   ALL METHODOLOGIES
1005   APPLICATION - AEROSOL
1006   APPLICATION - ALL USAGES
1007   APPLICATION - BRUSH/DOBBING
1013   APPLICATION - GUN
1016   APPLICATION - HAND TOOL
1017   APPLICATION - HAND WIPE
1029   APPLICATION - SQUEEZE TUBE
1166   TOOL - MANUAL
1167   TOOL - POWERED
1000   OTHER/NOT APPLICABLE
1180   PAPER SHREDDING
1108   APPROACH
1109   IDLE
1110   INTERMEDIATE
1111   MILITARY
1112   AFTERBURNER
1184   ALL MODES
1043   CHEMICAL

1073   FUEL - DIESEL/NO. 2 FUEL OIL
 AFMC
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Code
Common Activity
    Description
CTP2 Implementation Guide
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               Interim Final
          Method
            Description
     TANKS
AST  STORING - ABOVE GROUND STORAGE
     TANKS
AST  STORING - ABOVE GROUND STORAGE
     TANKS
AST  STORING - ABOVE GROUND STORAGE
     TANKS
AST  STORING - ABOVE GROUND STORAGE
     TANKS
AST  STORING - ABOVE GROUND STORAGE
     TANKS
AST  STORING - ABOVE GROUND STORAGE
     TANKS
AST  STORING - ABOVE GROUND STORAGE
     TANKS
AST  STORING - ABOVE GROUND STORAGE
     TANKS
                        1074   FUEL - JP-IO
                        1075   FUEL - JP-4
                        1076   FUEL - JP-5
                        1077   FUEL - JP-7
AST  STORING - ABOVE GROUND STORAGE
     TANKS
AST  STORING - ABOVE GROUND STORAGE
     TANKS
AST  STORING - ABOVE GROUND STORAGE
     TANKS
AST  STORING - ABOVE GROUND STORAGE
     TANKS
AST  STORING - ABOVE GROUND STORAGE
     TANKS
AST  STORING - ABOVE GROUND STORAGE
     TANKS
AST  STORING - ABOVE GROUND STORAGE
     TANKS
AST  STORING - ABOVE GROUND STORAGE
     TANKS
BRN  BURNING
BRN  BURNING
BRN  BURNING
CBE  COMBUSTING - EXTERNAL
CBE  COMBUSTING - EXTERNAL
                        1078   FUEL - JP-8

                        1080   FUEL - MUR (MOGAS UNLEADED
                              REGULAR)
                        1081   FUEL - NATURAL GAS
                        1082   FUEL - PROPANE (LPG)
                        H97   FUEL - PROPELLANT FUEL I (PFl)
                        1084   FUELS - AV-GAS
                        1085   FUELS - COMINGLED FUEL
                              (MIXTURE OF FUELS)
                        1086   FUELS - ISO-BUTANE
                        1087   FUELS - WASTE OIL

                        1099   HAZARDOUS WASTE

                        Ill9   MATERIALS

                        H8l   HEATING OIL
                        H29   OPEN
                        1078   FUEL - JP-8
                        H37   PROPANE
                        1072   FUEL - COAL
                        1073   FUEL - DIESEL/NO. 2 FUEL OIL
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            Common Activity
Code            Description
CBE  COMBUSTING - EXTERNAL
CBE  COMBUSTING - EXTERNAL
CBE  COMBUSTING - EXTERNAL
CBE  COMBUSTING - EXTERNAL
CBE  COMBUSTING - EXTERNAL
CBE  COMBUSTING - EXTERNAL
CBI  COMBUSTING - INTERNAL
CBI  COMBUSTING - INTERNAL
CBI  COMBUSTING - INTERNAL
CBI  COMBUSTING - INTERNAL
CBI  COMBUSTING - INTERNAL
CBI  COMBUSTING - INTERNAL
CBI  COMBUSTING - INTERNAL
CBI   COMBUSTING - INTERNAL
CBI   COMBUSTING - INTERNAL
CBI   COMBUSTING - INTERNAL
CBI   COMBUSTING - INTERNAL
CD-   CURING/DRYING/BAKING (HEATING
     PROCESS)
CD-   CURING/DRYING/BAKING (HEATING
     PROCESS)
CD-   CURING/DRYING/BAKING (HEATING
     PROCESS)
CDM  CONSTRUCTING/DEMOLISHING
CDM  CONSTRUCTING/DEMOLISHING
CF-   COOLING
CF-   COOLING
CF-   COOLING
CF-   COOLING
CFS   CASTING/FORGING/SMELTING
CFS   CASTING/FORGING/SMELTING
CFS   CASTING/FORGING/SMELTING
CFS   CASTING/FORGING/SMELTING
CFS   CASTING/FORGING/SMELTING
CFS   CASTING/FORGING/SMELTING
1081
1082
1086
1087
1181
1193
1073
1074
1075
1076
1077
1078
1080
    CTP2 Implementation Guide
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                   Interim Final
              Method
      ^^^^^^^^^H   •
                Description
      FUEL - NATURAL GAS
      FUEL - PROPANE (LPG)
      FUELS - ISO-BUTANE
      FUELS - WASTE OIL
      FUELS - HEATING OIL
      DI-METHYL ETHER
      FUEL - DIESEL/NO.  2 FUEL OIL
      FUEL - JP-IO
      FUEL - JP-4
      FUEL - JP-5
      FUEL - JP-7
      FUEL - JP-8
      FUEL - MUR (MOGAS UNLEADED
      REGULAR)
1081   FUEL - NATURAL GAS
1082   FUEL - PROPANE (LPG)
1084   FUELS - AV-GAS
H82   STARTER FLUID
1033   AUTOCLAVE
1056   DRIER
H33   OVEN

Ill7   MACHINE ASSISTED
Ill8   MANUAL
H27   NATURAL CONVECTION
H69   TOWER - EVAPORATIVE
1200   CRYOGENICS
H92   HEAT EXCHANGER
1000   OTHER/NOT APPLICABLE
1041   CASTING - INVESTMENT
1042   CASTING - SAND
1071   FORGING - DROP
1088   FURNACE - ARC
1089   FURNACE - CRUCIBLE
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                        _Page 127

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Code
CFS
CFS
CFS
CFS
CL-
CL-
CL-
CL-
CL-
CL-
CL-
CL-
CL-
CL-
CL-
CL-
CL-
CR-
CR-
CRC
CRC
CRC
CRC
CRC
            Common Activity
                 Description
     CASTING/FORGING/SMELTING
     CASTING/FORGING/SMELTING
     CASTING/FORGING/SMELTING
     CASTING/FORGING/SMELTING
     CLEANING/WASHING
     CLEANING/WASHING
     CLEANING/WASHING
     CLEANING/WASHING
     CLEANING/WASHING
     CLEANIN(5/WASHIN(5
     CLEANIN(5/WASHIN(5
     CLEANIN(5/WASHIN(5
     CLEANIN
-------
Code
Common Activity
    Description
DER  DEICING - RUNWAY/ROAD
DET  DETONATING
DEV  DEVELOPING FILM
DEV  DEVELOPING FILM
DEV  DEVELOPING FILM
DGR  DECREASING
DGR  DECREASING
DGR  DECREASING
DGR  DECREASING
DGR  DECREASING
DCR  DECREASING
DGR  DECREASING
DCR  DECREASING
DGR  DECREASING
DCR  DECREASING
DGR  DECREASING
DCR  DECREASING
DGR  DECREASING
DIC  DICGINC/EXCAVATTNG
DIG  DICGINC/EXCAVATTNG
DIC  DIGCING/EXCAVATINC
DIG  DICGINC/EXCAVATING
DIS  DISPENSING/LOADING
DIS  DISPENSING/LOADING
DIS  DISPENSING/LOADING
DPT  DEPAINTTNG
DPT  DEPAINTTNC
DPT  DEPAINTTNG
DPT  DEPAINTTNC
DPT  DEPAINTTNG
DPT  DEPAINTTNC
DPT  DEPAINTTNG
DPT  DEPAINTTNC
DRV  DRIVING
DRV  DRIVING
DSP  DISPOSING
                         1149
                         1067
                         1034
                         1118
                         1201
                         1000
                         1005
                         1006
                         1007
                         1013
                         1017
                         1026
                         1029
                         1047
                         1069
                         1100
                         1130
                         1172
                         1117
                         1118
                         1165
                         1167
                         1136
                         1139
                         1143
                         1038
                         1044
                         1045
                         1046
                         1116
                         1118
                         1120
                         1179
                         1145
                         1146
                         1040
CTP2 Implementation Guide
                29 Jun 2001
               Interim Final
          Method
            Description
   SALTTNC AND SANDING
   EXPLOSIVES
   AUTOMATIC
   MANUAL
   DIAZO/BLUELINE MACHINE
   OTHER/NOT APPLICABLE
   APPLICATION - AEROSOL
   APPLICATION - ALL USAGES
   APPLICATION - BRUSH/DOBBING
   APPLICATION - CUN
   APPLICATION - HAND WIPE
   APPLICATION - POWER WASH
   APPLICATION - SQUEEZE TUBE
   COLD DIP TANK /COLD SOAK
   FLUSH CLEANING
   HEATED DIP TANK /HEATED SOAK
   OPEN-TOP VAPOR
   VAPOR DECREASING
   MACHINE ASSISTED
   MANUAL
   TOOL - HAND
   TOOL - POWERED
   POUR
   PUMP/NOZZLE
   RACK/ARM
   BLASTING
   CHEMICAL - APPLICATION - BRUSH
   CHEMICAL - APPLICATION - POUR
   CHEMICAL - APPLICATION - SPRAY
   LASER
   MANUAL
   MECHANICAL
   CHEMICAL - APPLICATION - DIP
   ROADS (PAVED)
   ROADS (UNPAVED)
   BULK
 AFMC
                                                 _Page 129

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            Common Activity
                 Description
 Code
DSP  DISPOSING
DSP  DISPOSING
EE-   ERADICATING/EXTERMINATING
EE-   ERADICATING/EXTERMINATING
EE-   ERADICATING/EXTERMINATING
EE-   ERADICATING/EXTERMINATING
FO-   FLYING OPERATIONS
FO-   FLYING OPERATIONS
FO-   FLYING OPERATIONS
FO-   FLYING OPERATIONS
GRO  GROUNDS MAINTENANCE
HAN  HANDLING/PACKAGING/RECEIVING/SHI
     PPING
HAN  HANDLING/PACKAGING/RECEIVING/SHI
     PPING
1C-   INCINERATING

1C-   INCINERATING
INS  INSPECTING
INS  INSPECTING
INS  INSPECTING
ION  IONIZING RADIATION SOURCE
LF-   LANDFILLING
LNC  LAUNCHING
LSR  OPERATING LASER
LSR  OPERATING LASER
LUB  LUBRICATING
LUB  LUBRICATING
LUB  LUBRICATING
LUB  LUBRICATING
LUB  LUBRICATING

MCH  MACHINING
MCH  MACHINING
MCH  MACHINING
Code
                                     1050
                                     1113
                                     1015
                                     1025
                                     1028
                                     1035
                                     1115
                                     1163
                                     1164
                                     1184
                                     1000
                                     1118

                                     1120

                                     1104

                                     1105
                                     1054
                                     1128
                                     1173

                                     1000
                                     1000
                                     1043
                                     1131
                                     1005
                                     1006
                                     1007
                                     1013
                                     1014

                                     1000
                                     1051
                                     1052
CTP2 Implementation Guide
                29 Jun 2001
               Interim Final
          Method
            Description
   CONTAINER
   LABPACK
   APPLICATION - HAND SPRAY
   APPLICATION - POWER SPRAY
   APPLICATION - SPREADER
   BAITING/TRAPPING
   LANDINGS
   TAKEOFFS
   TAXI
   ALL MODES
   OTHER/NOT APPLICABLE
   MANUAL
     MECHANICAL
     INCINERATION - MULTIPLE
     CHAMBER
     INCINERATION - SINGLE
     CHAMBER
     DESTRUCTIVE TESTING
     NON-DESTRUCTIVE TESTING
     VISUAL
     I^^^H
     OTHER/NOT APPLICABLE
     OTHER/NOT APPLICABLE
     CHEMICAL
     OPTICAL
     APPLICATION - AEROSOL
     APPLICATION - ALL USAGES
     APPLICATION - BRUSH/DOBBING
     APPLICATION - GUN
     APPLICATION - HAND
     APPLICATION
     OTHER/NOT APPLICABLE
     CUT - ABRASIVE BLAST
     CUT - LASER
 AFMC
                                                             _Page ISO

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Code
Common Activity
    Description
MCH  MACHINING
MCH  MACHINING
MCH  MACHINING
MCH  MACHINING
MCH  MACHINING
MCH  MACHINING
MCH  MACHINING
MCH  MACHINING
MCH  MACHINING
MCH  MACHINING
MCH  MACHINING
MED  PROVIDING MEDICAL CARE
MED  PROVIDING MEDICAL CARE
MED  PROVIDING MEDICAL CARE
     PROVIDING MEDICAL CARE
     PROVIDING MEDICAL CARE
     PROVIDING MEDICAL CARE
     MIXING
     MIXING
     MOLDING
     MOLDING
     CHEMICAL MILLING AND MASKING
     PATROLLING
     PATROLLING
     PATROLLING
     PAVING
PC-   PAINTING/COATING
PC-   PAINTING/COATING

PC-   PAINTING/COATING
PC-   PAINTING/COATING
 Code
1053
1057
1061
1097
1102
1124
1141
1150
1152
1153
1170
1000
1004
1066
CTP2 Implementation Guide
                29 Jun 2001
               Interim Final
          Method
            Description
   CUT - PLASMA
   DRILL
   ELECTRO-DISCHARGE
   GRINDING
   HONE
   MILL
   PUNCH
   SAW
PC-   PAINTING/COATING
PC-   PAINTING/COATING
                         1103
                         1162
                         1187
                         1117
                         1118
                         1019
                         1023
                         1000
                         1036
                         1070
                         1126
                         1000
                         1005
                         1007

                         1008
                         1010
                         1011

                         1195
   SHAPING
   SHEAR
   TURN
   OTHER
   ANESTHESIA
   EXAMINATIONS/FIRST
   AID/MEDICATING
   IMMUNIZING
   SURGICAL OPERATIONS
   LABORATORY ANALYSIS
   MACHINE ASSISTED
   MANUAL
   APPLICATION - INJECTION
   APPLICATION - POUR
   OTHER/NOT APPLICABLE
   BICYCLE
   FOOT
   MOTOR
   OTHER/NOT APPLICABLE
   APPLICATION - AEROSOL
   APPLICATION -
   BRUSH/DOBBING/PAINT PEN
   APPLICATION - DIP
   APPLICATION - ELECTROSTATIC
   SPRAY - AUTOMATIC
   APPLICATION - ELECTROSTATIC
   SPRAY - MANUAL
   APPLICATION - ELECTROPHORETTC
 AFMC
                                                 _Page 131

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Code
Common Activity
    Description
CTP2 Implementation Guide
                29 Jun 2001
               Interim Final
          Method
            Description
PC-   PAINTING/COATING
PC-   PAINTING/COATING
PC-   PAINTING/COATING
PC-   PAINTING/COATING
PC-   PAINTING/COATING

PC-   PAINTING/COATING
PC-   PAINTING/COATING
PIT  PLATING/METAL DEPOSITING
PIT  PLATING/METAL DEPOSITING
PIT  PLATING/METAL DEPOSITING
PIT  PLATING/METAL DEPOSITING
PIT  PLATING/METAL DEPOSITING

PIT  PLATING/METAL DEPOSITING
PRG  PURGING/DEPUDDELING
PRG  PURGING/DEPUDDELING
PR(5  PURSINS/DEPUDDELINe
PRN  PRINTINS
PRN  PRINTINS
PRN  PRINTING
PSH  POLISHINS
PSH  POLISHING
RA-  REMEDIATING
RA-  REMEDIATING
RA-  REMEDIATING
RA-  REMEDIATING
RA-  REMEDIATING
RA-  REMEDIATING
RA-  REMEDIATING
RA-  REMEDIATING
RA-  REMEDIATING
RFR  RADIO FREQUENCY RADIATION
     EQUIPMENT
                               SPRAY
                         1018   APPLICATION - HVLP SPRAY GUN
                         1022   APPLICATION - PLASTIC FLAME
                               COATING
                         1024   APPLICATION - POWDER COATING
                         1027   APPLICATION - ROLL
                         1030   APPLICATION - STANDARD SPRAY
                               GUN
                         1031   APPLICATION - THERMAL SPRAY
                         1049   CONFORMAL
                         1007   APPLICATION - BRUSH/DOBBING
                         1008   APPLICATION - DIP
                         1009   APPLICATION - ELECTROPLATING
                         1012   APPLICATION - FLAME SPRAY
                         1020   APPLICATION - ION VAPOR
                               DEPOSITION
                         1021   APPLICATION - PLASMA SPRAY

                         1003   AMBIENT AIR PURGING
                         H38   PUMP/BLOWER/MISC
                         H35   PHOTO OFFSET
                         H48   ROTOGRAVATURE
                         H54   SILK SCREEN
                         Ill7   MACHINE ASSISTED
                         Ill8   MANUAL
                         1002   AIR STRIPPING
                         1037   BIO REMEDIATION
                         1039   BIO VENTING
                         H07   INJECTION WELLS
                         Ill4   LAND FARMING
                         H40   PUMP/TREAT
                         H56   SOIL RECLAMATION
                         H57   SOIL VAPOR EXTRACTION
                         H78   AIR SPARGING
                         1000   OTHER/NOT APPLICABLE
 AFMC
                                                 _Page 132

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            Common Activity
Code            Description
RIG  RIGGING
RR-   RECYCLING/RECLAIMING
RR-   RECYCLING/RECLAIMING
RR-   RECYCLING/RECLAIMING
SAM  SAMPLING
SAM  SAMPLING
SAM  SAMPLING
SAM  SAMPLING
SAM  SAMPLING
SAM  SAMPLING
SAM  SAMPLING
SAM  SAMPLING
SAM  SAMPLING
SHO  SHOOTING
SHO  SHOOTING
SPL  SPILLING/MISHAP/LEAKING
ST-  STORING
ST-  STORING
ST-  STORING
ST-  STORING
ST-  STORING
     STORING
     STORING
ST-
ST-
STE
STE
STE
TST
TST
TST
TST
     STERILIZING
     STERILIZING
     STERILIZING
     TESTING
     TESTING
     TESTING
     TESTING
UST  STORING - UNDERGROUND STORAGE
     TANKS
UST  STORING - UNDERGROUND STORAGE
     TANKS
UST  STORING - UNDERGROUND STORAGE
     TANKS
1000
1055
1176
1186
1000
1001
1058
1099
1144
1160
1174
1198
1189
1106
1132
1065
1043
1099
1119
1155
1159
1199
1087
1043
1134
1171
1000
1083
1099
1147
1043
CTP2 Implementation Guide
                29 Jun 2001
               Interim Final
          Method
            Description
   OTHER/NOT APPLICABLE
   DISTILLATION
   CLOSED-LOOP
   BIOMASS
   OTHER/NOT APPLICABLE
   AIR
   DRINKING WATER
   HAZARDOUS WASTE
   REMEDIATION
   STORM WATER
   WASTE WATER
   LEAD
   ASBESTOS
   INDOOR
   OUTDOOR
   EQUIPMENT
   CHEMICAL
   HAZARDOUS WASTE
   MATERIALS
   SLUDGE
   STORAGE PILES
   USED OIL
   FUELS - WASTE OIL
   CHEMICAL
   OVEN/AUTOCLAVE
   ULTRASONIC
   OTHER/NOT APPLICABLE
   FUEL/PROPELLANT
   HAZARDOUS WASTE
   ROCKET MOTOR DETONATIONS
   CHEMICAL

                                     1085   FUEL - COMINGLED FUEL
                                     1073   FUEL - DIESEL/NO. 2 FUEL OIL
 AFMC
                                                             _Page 133

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Code
Common Activity
    Description
UST  STORING - UNDERGROUND STORAGE
     TANKS
UST  STORING - UNDERGROUND STORAGE
     TANKS
UST  STORING - UNDERGROUND STORAGE
     TANKS
UST  STORING - UNDERGROUND STORAGE
     TANKS
UST  STORING - UNDERGROUND STORAGE
     TANKS
UST  STORING - UNDERGROUND STORAGE
     TANKS
UST  STORING - UNDERGROUND STORAGE
     TANKS
UST  STORING - UNDERGROUND STORAGE
     TANKS
UST  STORING - UNDERGROUND STORAGE
     TANKS
UST  STORING - UNDERGROUND STORAGE
     TANKS
UST  STORING - ABOVE GROUND STORAGE
     TANKS
UST  STORING - UNDERGROUND STORAGE
     TANKS
UST  STORING - UNDERGROUND STORAGE
     TANKS
UST  STORING - UNDERGROUND STORAGE
     TANKS
WD-  WOODWORKING

WS-  WELDING/SOLDERING/BRAZING
WS-  WELDING/SOLDERING/BRAZING
WS-  WELDING/SOLDERING/BRAZING
WS-  WELDING/SOLDERING/BRAZING
WS-  WELDING/SOLDERING/BRAZING
WS-  WELDING/SOLDERING/BRAZING
WWD WATER TREATING - DRINKING
WWD WATER TREATING - DRINKING
    CTP2 Implementation Guide
                   29 Jun 2001
                   Interim Final
              Method
      ^^^^^^^^^^i   •
 Code            Description
1074   FUEL - JP-10
                        1075   FUEL - JP-4
                        1076   FUEL - JP-5

                        1077   FUEL - JP-7

                        1078   FUEL - JP-8

                        1080   FUEL - MUR (MOGAS UNLEADED
                               REGULAR)
                        1081   FUEL - NATURAL GAS
                        1082   FUEL - PROPANE (LPG)
                        1197    FUEL - PROPELLANT FUEL 1 (PF1)
                        1084   FUELS - AV-GAS
                        1087   FUELS - WASTE OIL
                        1099   HAZARDOUS WASTE
                        1119    MATERIALS
                        1181    FUELS - HEATING OIL
                        1095   GENERAL
                        1101    HOBBIES
                        1006   APPLICATION - ALL USAGES
                        1032   ARC
                        1094   GAS
                        1098   GUN
                        1123    MIG/TTG
                        1168    TORCH
                        1043   CHEMICAL
                        1120    MECHANICAL
 AFMC
                                                _Page 134

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 Code
^^^^^^^H ^^^^^^^^^^H
WWP WATER
WWP WATER
WWS WATER
WWS WATER
WWT WATER
WWT WATER
 Common Activity
      Description
PRE TREATING - WASTE
PRE TREATING - WASTE
TREATING - SWIMMING
TREATING - SWIMMING
TREATING - WASTE
TREATING - WASTE
    CTP2 Implementation Guide
                    29 Jun 2001
                   Interim Final
              Method
                Description
1043   CHEMICAL
H20   MECHANICAL
1043   CHEMICAL
H20   MECHANICAL
1043   CHEMICAL
H20   MECHANICAL
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                                                   _Page 135

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           NSF International
Environmental Management System
       Demonstration Project

            Final Report
              December 1996

            Ann Arbor, Michigan

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Environmental Management System
Demonstration Project
Final Report

December 1996
Written by:

Craig P. Diamond
Project Manager
NSF International
2100 Commonwealth Blvd.
Suite 100
Ann Arbor, MI 48105

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                                   CONTENTS
I. Foreword 	1
      Organization of the Report	1
      Advice to Readers  	2
      Acknowledgments	2

II. Executive Summary 	3
      Project Overview	3
      Project Findings	4
      Conclusions	8

III. Introduction and Project Overview                                            9
      Project Summary	9
      Project Activities in Detail 	12
      Profile of Participating Organizations	13

IV. EMS Implementation Progress	16
      Background on EMS Assessments and Data Analysis	16
      Self-Assessment Results	17
      Findings from Independent Assessments	21

V. Findings on Key EMS Implementation Issues  	25
      Incentives for Implementing an EMS 	25
      Benefits and Costs of Implementation   	27
      Barriers and Keys to Successful Implementation	31
      Links with ISO 9000 and Health & Safety  	33
      Comparison of SMEs and Large Organizations  	34
      Recommended Guidance and Implementation Tools	36
      Participant Feedback on ISO 14001	38
      Participant Advice to Regulators  	42

VI. Conclusions 	43
      Major Lessons Learned  	43
      Remaining Questions and Areas for Future Study	44

VII. Case Studies	46
      3M Corporation	47
      Allergan, Inc	51
      Commodore Applied Technologies  	54
      Fluke Corporation  	56
      Globe Metallurgical Inc	59
      Hach Company 	62

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      KJ. Quinn & Co	67
      Lockheed Martin Federal Systems 	70
      Madison Gas and Electric Company	73
      Milan Screw Products  	76
      NEO Industries Ltd	80
      NfflCO Incorporated	83
      Pacific Gas and Electric Company 	86
      Pitney Bowes Inc	89
      TRINOVA Corporation	92
      United States Postal  Service	95
      Washtenaw County Government  	98

VIII. Bibliography                                                             101

IX. Appendices  	102
      Appendix A: Background on ISO 14000, EMS Standards, and Registration	102
      Appendix B: Questions Asked of Participants at Conclusion of Project	107
      Appendix C: Elements of the ISO 14001 Standard: A Snapshot	108
      Appendix D: Excerpts from NSF's EMS Self-Assessment Tool  	109

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I. FOREWORD
The ISO 14000 series of standards, in particular the ISO 14001 Standard for environmental
management systems (EMS), has become one of the most widely discussed developments in
environmental management in both the private and public sectors. The ISO 14001 Standard was
officially approved in September 1996, and is expected to become as pervasive in the international
marketplace as the ISO 9000  series of quality management standards. This expectation has driven
many organizations to devote significant resources into preparing for ISO 14001. Despite this
level of investment, there is still a great deal of uncertainty about the implementation of the ISO
14001 Standard. Although several organizations in Europe have completely implemented a
formal EMS based on standards (e.g., BS 7750, EMAS, IS 310), relatively few organizations in
the United States have done so. Therefore, in the U.S. there is a need for "real life" examples
from organizations about the challenges and benefits of implementing an EMS and the incentives
for doing so.

This final report on NSF International's EMS Demonstration Project conveys the experiences of
18 organizations as they attempted to implement the ISO 14001 Standard from March 1995
through June  1996.  The project was funded through a cooperative agreement from the U.S.
Environmental Protection Agency (EPA), Office of Wastewater Management. The report will be
of interest to many types of organizations interested in EMS implementation, including:
manufacturers and other organizations considering whether to implement the  Standard; regulatory
agencies; engineering and management consulting firms; law firms; training organizations; banks;
and insurance companies.

The Demonstration Project focused on EMS implementation issues, not on registration. In this
report, "EMS implementation" refers to an organization's effort to develop an EMS based on the
ISO  14001  Standard; the term does not refer to maintaining and improving the system  after it is
implemented.  Participating organizations varied significantly in the extent to which they came
into the  project with  the elements of ISO 14001 already in place.

The organizations, which participated voluntarily, were not required or expected to become
registered to ISO 14001 during or after the project; nor were they required to implement all the
requirements  of the Standard over the course of the project.
Organization of The Report

The Introduction and Project Overview outlines the activities of the project in some detail and
provides an overview of the 18 organizations that participated.  The section on EMS
Implementation Progress provides an analysis of how the project participants as a group made
progress on implementing the ISO 14001 Standard over the course of the project.  The Findings
on Key EMS Implementation Issues discusses several EMS implementation issues, including

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incentives, benefits, and keys to success. It also offers a list of suggested EMS implementation
guidance tools.  A brief Conclusions section discusses major lessons learned from the project and
suggested areas for further inquiry.  The Case Studies, which were written by the participating
organizations and edited by NSF, convey the EMS implementation experiences of the participants
from their own viewpoints (to maintain confidentiality, none of the other sections of the report
refer to specific organizations by name). Appendices A-D are provided to help clarify certain
parts of the project and this report. For those readers who are not familiar with the ISO 14001
Standard, it may be helpful to refer to Appendix C which provides an overview of the elements of
ISO 14001.
Advice to Readers

This report assumes a basic knowledge of ISO 14000 and of the ISO 14001 EMS Standard. A
thorough understanding of environmental management systems is helpful, but not required. For
those who are not very familiar with the language of ISO 14001, it is suggested that the Standard
be referenced regularly while reading the report.
Acknowledgments

NSF International would like to thank the U.S. EPA, Office of Wastewater Management, for
providing the majority of the funding for the EMS Demonstration Project.

NSF also wishes to thank the 18 participating organizations (and the individuals who represented
them in the project) for their invaluable contributions through the case studies, self-assessments,
meeting presentations, and advice to NSF project staff (the organizations are listed in Section III
of the report). NSF would also like to gratefully acknowledge the following individuals who have
given much of their time to the planning and implementation of the EMS Demonstration Project,
and who have contributed to the project's success:

Thomas Ambrose, HS&E Management Advisor
Henry Balikov, TLI Systems
Joe Egan, Tucker Alan, Inc.
Jimmy Margolis, Arthur D. Little, Inc.
Philip Stapleton, Glover-Stapleton Associates, Inc.
Wayne Tusa, Environmental Risk & Loss Control, Inc.
David Van Wie, Robert G. Gerber, Inc.

Finally, the author would like to thank Anita Cooney and Michael Hix of NSF International for
their assistance in the development of this report.

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II. EXECUTIVE SUMMARY
Project Overview

This final report on NSF International's Environmental Management System (EMS)
Demonstration Project summarizes the EMS implementation experiences of 18 organizations of a
variety of types and sizes. The project, which used the ISO 14001 Standard as the model for an
EMS, was funded through a two-year grant from the U.S. Environmental Protection Agency,
Office of Wastewater Management (October 1994 - September 1996). The EPA funded the
project because it recognized that both private organizations and regulatory agencies were in need
of practical information about the process of implementing the ISO 14001 Standard.
Participating organizations included 16 private companies, one government agency, and one
government-owned corporation (the U.S. Postal Service).  The companies ranged from small
manufacturers with fewer than 100 employees to multinational corporations.

The goals of the project were to: (1) document the experiences of a variety of organizations as
they attempted to develop an EMS based on ISO 14001; (2) demonstrate the benefits and
challenges of, and incentives for, EMS implementation; (3) determine what types of tools and
assistance organizations need to be successful  with EMS implementation; and  (4) provide a forum
for  organizations to learn from each others' EMS experiences. Another important objective of
the  project was to identify and assess any differences that might exist between  small and large
organizations in their ability to implement an EMS.

After organizations were recruited for the project, an initial training session was held in March
1995 to familiarize participants with ISO 14000 and EMS. Following the training, participants
conducted self-assessments of their EMS against the requirements in ISO 14001  using a self-
assessment tool developed by NSF International. Three additional meetings were held (in August
and December 1995, and June 1996) during which participants shared lessons  learned from  their
EMS implementation experiences. Final EMS self-assessments were conducted  prior to the last
meeting in June 1996.  In August 1996, participants submitted responses to specific questions  as
well as self-written EMS implementation case studies (the case studies are included in the report).
In October  1996, EMS auditors conducted independent EMS assessments for  four of the
participants to determine if significant differences might exist between the results of the self-
assessments and independent assessments.

To  meet the objectives of the project, NSF collected and analyzed information from four sources:
(1)  results of the initial and final EMS self-assessments, and of the four independent assessments;
(2)  responses to the specific questions about EMS implementation;  (3) the  self-written case
studies; and (4) observations made at the four project meetings.

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Project Findings
EMS Implementation Progress

The results of the EMS self-assessments showed that, overall, participants made notable progress
on implementing the ISO 14001 Standard over the course of the project (the average period of
time between the initial and final self-assessments was approximately 11 months). Whereas the
initial self-assessments showed that the group as a whole had only 22% of the requirements of the
Standard complete, the final self-assessments showed that the group had 50% of the requirements
complete.

       Important Note: For both the initial and final self-assessments, participants evaluated themselves on
       63 requirements which comprise all 17 elements of ISO 14001. Each requirement could be evaluated
       on five different levels: No Action (NA), Initiation (IN), Partial Implementation (PAR), Complete
       Implementation (COM), and Evaluated & Sustained (ES). NA, IN and PAR are considered
       incomplete, while COM and ES are considered complete (in the self-assessment tool, incomplete was
       denoted by "NO," while complete was denoted by "YES").

As a whole, participants also made progress on each of the 17 elements of ISO 14001, although
more progress was made on some elements than on others. The element of ISO 14001 with the
highest level of implementation was Policy, while EMS audit was least implemented (84% of the
requirements  under Policy, and 24% under EMS audit, were evaluated as complete at the
conclusion of the project).

The results of the independent assessments showed that there were significant differences in how
the  organizations and independent auditors evaluated the requirements of ISO 14001.
Approximately 30% of the requirements evaluated in the four organizations were evaluated
differently by the organization and the independent auditor on the YES/NO  response. Twenty-
four percent were rated lower by the independent auditors; i.e., the independent auditor evaluated
these requirements as NO, but the organization evaluated them as YES.  Six percent were rated
higher; i.e., the independent auditor evaluated these requirements as YES, but the organization
evaluated them as NO.

Since 24% of all the requirements were evaluated lower by the independent assessors, and only
6% were evaluated higher, these findings suggest that the %YES of the initial  and final  self-
assessment results would have been lower if all the EMS assessments had been conducted by
independent auditors rather than by the organizations themselves.

The independent auditors made some additional observations during the audits.  Most notably, in
the  three organizations with ISO 9000 systems, the quality management staff was surprisingly
disconnected  from the environmental management staff. It appeared that the organizations were
not taking full advantage of their existing ISO 9000 systems to develop EMS procedures and
documentation.

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Incentives for Implementing an EMS

Participants were asked at the end of the project to list their organizations' incentives for
implementing ISO 14001.  The incentives most commonly cited by participants are listed below.
The number of participants that cited each incentive is provided in parentheses (note: fourteen
participants listed their incentives, and some cited more than one incentive):

       Competitive advantage (7);
•      Improved environmental performance (6);
       Possible ISO 14001 registration (5);
•      Enhanced regulatory compliance (4); and
       Possible regulatory flexibility (3).

Competitive advantage was also mentioned quite frequently at meetings, although participants did
not always  specify whether the advantage would be derived from external recognition (i.e.,
through registration) or from the benefits of improved environmental management.
Benefits of EMS Implementation

Several benefits of implementing an EMS were realized by participants over the course of the
project. In addition, those organizations which had extensive EMSs at the beginning of the
project reported benefits they had realized before becoming involved in the project.  The number
of participants that cited each benefit is provided in parentheses (note: fourteen participants listed
benefits, and some listed more than one). Reported benefits include:

•      Improved cooperation and environmental awareness among employees (5);
       Improved procedures and documentation (5);
•      Enhanced regulatory compliance (3); and
•      Improved environmental performance (5).

Participants had not realized reduced environmental management costs or access to international
markets by the conclusion of the project.  Although these benefits are often mentioned in
conjunction with ISO 14001, it will likely take more time for organizations to realize these
benefits.
Keys to Successful Implementation

The following keys to successful EMS implementation emerged as common themes during the
group meetings and in participants' responses to questions at the conclusion of the project.  These
include:

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       Secure top management commitment early in the process;
       Gain a thorough understanding of the ISO 14001 Standard;
       Perform a thorough self-assessment;
       Involve many functions and staff levels in the planning process;
       Initially, set a small number of achievable environmental objectives; and
       Build on existing business practices.
Links with ISO 9000 and Health & Safety

A majority of project participants have facilities that are either registered to ISO 9000 (ISO 9001
or 9002) or working towards registration (only two organizations reported that they were not
registered or pursuing registration). Most of the organizations with ISO 9000 experience
indicated that they would model several elements of the EMS after their quality system, or that
they would at least partially integrate certain elements of ISO 9000 and ISO 14001.  However,
only a few  participants reported at the end of the project that they intended to fully integrate the
two systems in the near future.  This finding is consistent with observations made during the
independent assessments.

Six participants reported they were intending to integrate ISO 14001 with their health & safety
program.
Comparison ofSMEs and Large Organizations

In the Demonstration Project, small and medium-sized enterprises (SMEs) were defined as having
fewer than 1,000 employees organization-wide. Based on question responses from both SMEs
and large organizations in the project, some differences between the two types of organizations
were observed.

       Incentives.  For certain incentives identified by participants (i.e., competitive advantage,
       regulatory relief) there was not a clear difference between the proportion of SMEs and
       large organizations citing them as incentives.  However, for other incentives there were
       notable differences.  SMEs were more likely than large organizations to identify enhanced
       compliance and improved documentation as motivating factors. Large organizations, on
       the other hand, were more likely to identify improved environmental performance and
       pollution prevention as motivating factors.

       Barriers. SMEs and large organizations cited most EMS implementation barriers (e.g.,
       promoting the EMS concept within the organization, achieving thorough documentation)
       in roughly equal proportions.  However, a much greater proportion of SMEs cited lack of
       time and resources as a barrier.

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Recommended Guidance and Implementation Tools

Based on the experience of the organizations in the project, it became evident that certain types of
guidance are very important for organizations of all types and sizes attempting to implement ISO
14001.  These include:

       Clarification of the intent of ISO 14001;
       A checklist or other tool to conduct an EMS self-assessment;
•      Guidance on how to identify and assess the significance of environmental aspedtHpfuds;
       A step-by-step implementation guide;
•      Examples  of EMS manuals, policies, and procedures; and
       EMS implementation case studies.
Feedback on the ISO 14001 Standard, and Advice to Regulators

Participants reported on their general and specific concerns about the ISO 14001 Standard. In
general, the participants believed that the Standard was a good model for an EMS.  However,
most participants expressed at least one overriding concern about the Standard, and some specific
comments (specific comments are presented in section V of the report).  The greatest overriding
concern was the potential for certain requirements to be variably interpreted by different auditors.
Other commonly reported concerns included confusion over the definition of "environmental
aspects;" an overemphasis on documentation; and confusion about whether written procedures
were necessary for particular requirements.

Participants also offered comments to the regulatory community about how government agencies
should integrate ISO 14001 into their regulatory approaches. Most participants stated that
regulators should offer incentives - primarily "regulatory flexibility" - to companies that
implement an EMS. These proposed incentives included:

•      Reductions in reporting;
       Reductions in site inspections and audits;
•      Reductions in fines;
       Elimination of penalties and NOVs for various environmental compliance issues; and
•      Fast-track permitting.

Many participants expressed a concern about the voluntary disclosure of self-audits (ISO 14001
requires organizations to conduct,  and maintain the records of, EMS audits). Several participants
also commented that a greater level of trust was needed between regulators and the regulated
community.
Conclusions

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Implementing ISO 14001 is Feasible in a Wide Variety of Organizations

The experience of the Demonstration Project suggests that an EMS based on ISO 14001 can be
implemented in a wide variety of organizations, but varying amounts of guidance and assistance
are required for different organizations. The main factors that seem to determine an
organization's ability to implement an EMS are (1) its experience with EMS, ISO 9000, or other
management system concepts; (2) the level of commitment from its top management; and (3) the
resources available to the organization to develop the necessary procedures and documentation.
Since SMEs are more likely to lack adequate resources, they will probably require more guidance
and take longer to complete EMS implementation than large organizations.
EMS Implementation Can Bring Concrete Internal Benefits

Project participants reported many benefits from EMS implementation that were not market or
trade related, including enhanced environmental awareness, improved documentation, and
pollution prevention.  These benefits were realized within the one year time frame of the project,
and before any of the organizations had attained full implementation or registration.
Independent Assessments Can Provide an Important Check on Self-Assessments

The results of the independent EMS assessments suggest that organizations might have the
tendency to evaluate their systems higher than would independent auditors. The results may also
have important implications for the concept of "self-declaration," in which an organization would
declare itself to be in conformance with the ISO 14001 Standard rather than receive an
independent audit from a registrar.

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III. INTRODUCTION AND PROJECT OVERVIEW
In October 1994, the U.S. EPA, Office of Wastewater Management, awarded funding to NSF
International to manage the EMS Demonstration Project. EPA awarded the grant because it
recognized that both private organizations and regulatory agencies needed practical information
about the EMS implementation process in organizations of various types and sizes. NSF was
selected to manage the project because it had developed an interim EMS standard (NSF 110) very
similar to ISO 14001, and because NSF was an active participant in the ISO 14000 development
process.

The goals of the project were to: (1) document the experiences of a variety of organizations as
they attempted to develop an EMS based on ISO 14001; (2) demonstrate the benefits and
challenges of, and the incentives for, EMS implementation;  (3) determine what types of tools and
assistance organizations need to be successful with EMS implementation; and (4) provide a forum
for organizations to learn from each others'  EMS experiences. An important objective of the
project was to identify and assess any differences that might exist between small and large
organizations in their ability to implement an EMS (for the remainder of this report, smaller
organizations will be referred to as small and medium-sized enterprises, or SMEs). In part, this
objective was intended to address concerns which arose during the Standard development process
regarding the applicability of ISO 14001 to  SMEs.

The intent of the project was to examine the process of implementing an EMS based on ISO
14001. It was not within the scope of the project to measure or assess the effects of EMS
implementation on environmental compliance or other aspects of environmental performance.  It
was also not required or expected that participating organizations would become registered to
ISO 14001 during or after the project. It is important to note that this report attempts to focus on
the experience of implementing an ISO 14001 EMS, as opposed to the benefits of already having
one in place.  However, those participants which came into the project with most ISO  14001
elements in place reported on the experience of having  an established EMS as well as on the
experience of implementing certain requirements. Nevertheless, most of the feedback received
from the participants addressed their experiences with the process of implementing the EMS.
Project Summary

Project participants were recruited in late 1994 and early 1995.  A project announcement and
interest form were sent to approximately 1,000 organizations. A few organizations were also
recruited individually.  A maximum of 20 organizations were sought, and 18 were recruited (there
was no competitive selection process; i.e., all 18 organizations that expressed interest were
selected for the project). There was no fee charged for participation.

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The project consisted of two major activities: (1) EMS self-assessment and implementation; and
(2) group training and discussion.  Each participant performed an initial assessment of its EMS in
the spring of 1995 using NSF's EMS Self-Assessment Tool. The participants used the results of
their initial assessments to develop EMS implementation action plans.  Based on their action
plans, participants implemented the ISO 14001 Standard at their own pace. Each participant
conducted a second self-assessment in the spring of 1996 to determine progress made over the
course of the project. Following the final self-assessments, four participants received independent
EMS assessments conducted by EMS auditors. The results of these assessments were compared
to the final EMS self-assessments  for the four participants. The purpose of the independent
assessments was to determine if organizations might evaluate their own systems differently than
independent auditors would.

In addition to self-assessment and  implementation, the organizations convened in four meetings at
NSF to receive training on EMS implementation and to discuss practical implementation
strategies. Based on feedback received  from participants, these meetings were a very constructive
way to exchange ideas about EMS concepts.

At the conclusion of the project, participants submitted responses to a series of questions
regarding their EMS implementation experiences; these responses are summarized in Section V,
Findings on  Key EMS Implementation Issues (the questions are listed in Appendix B).
Participants  also prepared self-written case studies which are included in Section VII. (Note:  14
of the 18 organizations submitted question responses regarding their EMS implementation
experiences; 17 submitted case studies).

Figure I provides an overview of the project.
                                            10

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                                           Figure 1
                                  EMS Demonstration Project
                                     Activities at a Glance
 1st Meeting

EMS Training
  Initial Self-
 Assessments
   & Begin
Implementation
 March 1995
April -July 1995
2nd Meeting

 Discussion
and Training
August 1995
Continued
Implementation

>„
*
3rd Meeting
Discussion
and Training
>>,

   August -
December 1995
December 1995
         Continued
       Implementation
              Final Self-
            Assessments
      December 1995
        March 1996
             March - May
                1996
              Final Meeting

                Discussion
                    Independent
                       EMS
                   Assessments
                June 1996
                   October 1996
                                               11

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Project Activities in Detail
EMS Self-Assessments and Implementation

Each participant performed two EMS self-assessments, one in the spring of 1995 (following the
first meeting) and one in the spring of 1996 (before the last meeting).

The results of the self-assessments were aggregated and summarized to serve two purposes: (1)
to provide an internal benchmark for the group; and (2) to measure group progress over the
period of the project.

Self-assessments were conducted internally by the organizations (some had consultants assist with
the self-assessment, others did not) using NSF's EMS Self-Assessment Tool. The tool was
developed prior to the first meeting under the direction of an ad hoc advisory group. The group
was comprised of environmental management consultants, in addition to environmental managers
from some of the companies recruited to the project. The tool contains a checklist that allows the
user to assess how the organization's EMS compares to the requirements in ISO 14001.  The self-
assessment results and a brief description of the EMS Self-Assessment Tool are provided in
Section IV.

Following the initial self-assessments in the spring of 1995, each participant identified those EMS
elements it wanted to develop (please refer to Section IV for an explanation of the self-assessment
process). While some of the organizations already had several elements of ISO 14001 already in
place, others needed to make more substantial changes to their existing environmental
management practices to develop an ISO 14001 EMS.  As mentioned previously, participants
were not required to implement any particular requirements of the Standard in any specific time
frame. Rather, they were asked to make the best effort possible, based on their own priorities,
over the course of the project.
Group Training and Discussion

Group meetings were held at NSF International in March, August and December of 1995, and in
June of 1996.  The purpose of these meetings was to provide EMS training and to create a forum
in which participants could learn from each other. Each organization was represented at the
meetings by one to three individuals. The attendees served a variety of roles in their organizations
including company presidents, environmental managers, and quality managers.  The first three
meetings were two-day sessions, while the last meeting was a one-day session.

The first meeting provided training on the requirements of ISO 14001 and included an overview
of basic EMS concepts.  NSF's EMS Self-Assessment Tool was provided to each participant at
                                           12

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the meeting so that each organization could conduct a self-assessment of its EMS before the
second meeting. At the conclusion of the first meeting, participants were asked to make their best
effort to implement the requirements of ISO 14001 over the course of the project, and were
encouraged to do so at a pace appropriate to their individual situations.

The second meeting provided further training on specific topics related to EMS implementation,
including: identifying environmental aspects and impacts; setting environmental objectives and
targets; promoting the EMS concept within an organization; and integrating ISO 14001 with ISO
9000. In addition, each participant reported back to the group on its experience with the EMS
self-assessment and on progress it had made in implementing the requirements in the Standard.
Individual progress reports (each about 10-15 minutes) were followed by questions from the
group and discussion.  For both the training and report-back sessions, participants were broken
into smaller groups to  facilitate discussion.

The third meeting was similar to the second, but more time was devoted to feedback and
discussion than to training. Each participant presented its progress on EMS implementation, and
discussed keys and barriers to success. Following the progress reports, plenary workshops were
held on estimating the costs and benefits of EMS implementation, and on evaluating
environmental performance.  In addition, guest speakers updated the group on developments in
EMS registration and accreditation.  In the fourth meeting, the majority of the agenda was
devoted to  sharing keys and barriers to EMS implementation, and lessons learned over the course
of the project.
Profile of Participating Organizations

Ten of the 18 participating organizations are large, and eight are SMEs (for the purpose of
categorization, large organizations were defined as having over 1,000 employees organization-
wide, while SMEs were defined as having fewer than 1,000 employees organization-wide).  The
organizations provide a variety of products and services, and range from Fortune 100
corporations to small manufacturers.  At the outset of the project, the organizations also varied
significantly in their approach to environmental management.  In particular, they varied in the
extent to which procedures were formalized and documented, and in the extent to which activities
that go beyond regulations had been integrated into their existing environmental management
practices.

A majority of the participants are either registered to ISO 9000 or working towards registration.
Approximately one-half operate facilities overseas. Table I lists the 18 organizations that
participated in the project. They consist of 16 private companies, 1 government agency, and one
government-owned corporation (the U.S. Postal Service). It is important to note that the
organizations in the project, because they participated voluntarily, were likely inclined to make
more progress on EMS implementation than would an average cross section of companies in the
U.S.; most of the participants had already decided to pursue EMS implementation before
                                            13

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becoming involved in the project.

As of December 1996, two organizations (both companies) in the project had facilities that were
registered to ISO 14001  or other EMS standards. Many others are planning to become ISO
14001 registered within the next few years.  Others may not be specifically planning for
registration, but are committed to developing an EMS based on the requirements of ISO 14001.
                                           14

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Table I: Brief Profiles of Participating Organizations
Organization
3M Corporation
Allergan, Inc.
Commodore Applied
Technologies
Fluke Corporation
Globe Metallurgical
Hach Company
K.J. Quinn & Co.
Lockheed Martin
Federal Systems
Madison Gas & Electric
Company
Milan Screw Products
NEO Industries Ltd.
NIBCO Inc.
Pacific Gas & Electric
Pitney Bowes Inc.
Prime Tanning Co.
TRINOVA Corporation
U.S. Postal Service
Washtenaw County
Government
Headquarters
St. Paul, MN
Irvine, CA
Columbus, OH
Everett, WA
Selma, AL
Ames, IA
Seabrook, NH
Manassas, VA
Madison, WI
Milan, MI
Portage, IN
Elkhart, IN
San Francisco, CA
Stamford, CT
Berwick, ME
Maumee, OH
Washington, DC
Ann Arbor, MI
Products/Services *
Produces multiple products for the
industrial, commercial, consumer, and
health care markets
Produces pharmaceuticals
Performs remediation technology
R&D
Produces electronic test and
measurement instruments
Produces silicon metal and ferroalloys
Produces instruments for water
analysis
Produces coatings and adhesives
Produces semiconductors and
computer systems
Provides electricity and natural gas
Produces screw machine products
Performs metal finishing
Produces fluid handling products
Provides electricity and natural gas
Produces mailing systems and other
office machines
Produces finished leather
Produces engineered components and
systems for industry
Provides mail delivery services
Provides a variety of municipal
services
Size"
Large
Large
Small
Large
Med
Med
Small
Large
Med
Small
Small
Large
Large
Large
Med
Large
Large
Large
       Note: Please refer to the Case Studies for a more detailed description of products/services.
       Note: Small denotes fewer than 250 employees; Med denotes 250-1000 employees; Large denotes over  100
                                                                                             0
                                                                                             emp
                                                                                             loye
                                               15

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                                                                                    es
                                                                                    (app
                                                                                    lies
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                                                                                    entir
                                                                                    e
                                                                                    orga
                                                                                    niza
                                                                                    tion
IV. EMS IMPLEMENTATION PROGRESS


Background on EMS Assessments and Data Analysis

Self-Assessments

Progress on EMS implementation over the course of the project was measured by comparing the
results of the initial and final self-assessments conducted using NSF's EMS Self-Assessment Tool.
The initial self-assessments were conducted between April and July 1995, while the final self-
assessments were conducted between March and May 1996 (thus, the average time between self-
assessments was approximately 1 1 months). The analysis provided in this section reflects results
for the entire group of organizations, not for individual participants.  Of the 18 organizations in
the project, 15  submitted data on both their 1995 and 1996 self-assessments; therefore, 3 of the
18 organizations are not included in the aggregate data analysis.

The EMS  Self-Assessment Tool contains a checklist which breaks the 17 elements of ISO 14001
Standard down into 63 separate requirements. The checklist does not interpret the Standard,
rather each requirement is taken verbatim from ISO 14001.  The user evaluates each requirement
on five possible "implementation levels": No Action (NA), Initiation (IN), Partial Implementation
(PAR), Complete Implementation (COM), and Evaluated & Sustained (ES). If the requirement is
evaluated as COM or ES, it is considered to be satisfied, or complete ("YES"); if the requirement
is evaluated as NA, IN, or PAR, it is considered to be not satisfied, or not complete ("NO").  The
reader should refer to Appendix D which provides  a sample page of the assessment tool and
detailed descriptions of each implementation level.

Because the final ISO 14001 Standard was published only recently (September 1996), the Self-
Assessment Tool was based on the Draft International Standard (DIS). This does not affect the
results of the project because there are no substantive differences  between the DIS and the final
version  of the Standard.

A note regarding the initial self-assessments. The initial self-assessments were conducted using an
assessment tool which contained the requirements  of both the ISO 14001 draft and another EMS
standard (NSF  110), while the final self-assessments used a revised self-assessment tool which

                                           16

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contained only the requirements of the ISO 14001 draft.  Participants were given the option to
complete the initial assessment using NSF 110, ISO 14001, or both. Three participants did not
complete the 14001 assessment; those organizations were asked to retroactively evaluate
themselves on how their EMS would have compared to ISO 14001 in the spring of 1995. (Note:
NSF 110 was developed by NSF International as an interim EMS standard in the U.S.  The NSF
standard was used in the initial phases of the project because, at the time, NSF 110 was a
completed standard and ISO 14001 was in an earlier draft stage; as the project progressed and
interest in ISO  14001 increased, a decision was made to use ISO 14001 in the project rather than
NSF 110).

Independent Assessments

In October 1996, four project participants received EMS assessments conducted by independent
EMS auditors.  The assessments were conducted by experienced environmental auditors utilizing
the same assessment tool used in the self-assessments.  Each assessment took two days and was
conducted by two auditors. Three of the assessments were conducted for single facilities, and one
was conducted for an entire organization. As discussed below, there were significant differences
between the results of the self-assessments and independent assessments for the four
organizations in which independent assessments were conducted.
Self-Assessment Results

The initial and final self-assessment results were aggregated and analyzed to evaluate (1) overall
implementation progress on the Standard as whole; and (2) implementation progress on each of
the 17 elements of ISO 14001.  As presented and discussed below, progress was made on the
Standard as a whole and on all of the 17 elements.
Overall Progress on ISO 14001

A total of 945 self-assessment responses were analyzed (15 organizations x 63 requirements in
assessment tool = 945 total responses).  In the initial self-assessment, 22% of responses were
"YES" (i.e., COM or ES) and 78% were "NO" (i.e., NA, IN, or PAR).  However, in the final
self-assessment, 50% of responses were "YES" and 50% were "NO." In Table II, these results
are further broken down into the five implementation levels.
Table II: Overall Progress on ISO 14001 Implementation
                                           17

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Implementation
Level
No Action (NA)
Initiation (IN)
Partial Implementation (PAR)
Complete Implementation (COM)
Evaluated & Sustained (ES)
Initial
Results
25%
23%
30%
18%
4%
Final
Results
8%
15%
27%
37%
13%
Table II also shows that participants, as a group, did not begin ISO 14001 implementation "from
scratch," since only 25% of the requirements were evaluated as No Action initially.

There was a large variation amongst project participants both on EMS implementation progress
and on the %YES of requirements for the initial and final self-assessments.  Some participants
evaluated well under 50% of their requirements as YES, while others evaluated well over 50% of
their requirements as YES.

Table III shows the %YES of individual participants for both the initial and final self-assessments.
Each column represents a participant (there are only 15 columns because 15 of the 18 project
participants submitted both their initial and final self-assessments).  The columns are ordered,
from left to right, by the %YES in the initial  self-assessments. These data illustrate the extent to
which project participants varied in their levels of EMS implementation at both the beginning and
end of the project. Note that only three of 15 showed no progress over the course of the project.
The two negative results are likely due to the final self-assessments being more rigorous than the
initial self-assessments in those two organizations.
Table III
EMS Implementation Progress of Individual Participants
Initial
%YES
Final
%YES
Final -
Initial
75

100

25

54

100

46

41

84

43

38

37

-1

33

33

0

27

18

-9

21

51

30

21

41

20

16

81

65

6

41

35

0

62

62

0

52

52

0

27

27

0

11

11

0

5

5

Progress on the Individual Elements of ISO 14001
                                           18

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Table IV shows how the elements ranked for both the initial and final self-assessments in terms of
the % of responses evaluated as "YES" within each element. The %YES was calculated by
dividing the total number of responses in an element into the number of responses evaluated as
"YES." For example, there are six requirements in the Self-Assessment Tool under Policy. Since
15 participants responded, there was a total of 90 responses for Policy. Seventy-six of the 90
responses (84.4%) were evaluated as "YES."

Table V shows the same information as Table IV, but in a different format.  The 17 elements of
ISO 14001 are ranked by the extent to which project participants made implementation progress
on them over the course of the project. The difference between the initial and final self-
assessment for each element is provided in the third column.  For example, although 6.7% of
responses for Records were evaluated as "YES" (COM or ES) in the initial assessments, 48.3%
or responses were evaluated as "YES" in the final assessments.
                                          19

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Table IV
Ranking of ISO 14001 Elements — Initial and Final Self-Assessments
ISO 14001 Elements - Initial Rank
4.3.2 Legal and other requirements
4.2 Environmental policy
4.4.7 Emergency prep/resp
4.4. 1 Structure and responsibility
4.5. 1 Monitoring and measurement
4.3.3 Objectives and targets
4.4.3 Communication
4.4.6 Operational control
4.6 Management review
4.4.5 Document control
4.4.2 Training/awareness/competence
4.3.4 Environmental mgmt. program
4.3.1 Environmental aspects
4.5.2 Nonconf/corr&prev action
4.5.4 EMS audit
4.4.4 EMS documentation
4.5.3 Records
%YES
Initial
53.3
44.4
35.6
28.3
24.4
22.2
22.6
20.0
20.0
19.0
18.9
17.8
15.6
13.3
13.3
10.0
6.7
ISO 14001 Elements - Final Rank
4.2 Environmental policy
4.3.2 Legal and other requirements
4.4. 1 Structure and responsibility
4.3.3 Objectives and targets
4.3.4 Environmental mgmt. program
4.4.7 Emergency prep/resp
4.4.2 Training/awareness/competence
4.3.1 Environmental aspects
4.4.6 Operational control
4.5.3 Records
4.4.5 Document control
4.5. 1 Monitoring and measurement
4.6 Management review
4.4.4 EMS documentation
4.4.3 Communication
4.5.2 Nonconf/corr&prev action
4.5.4 EMS audit
%YES
Final
84.4
66.7
61.7
57.8
57.8
57.8
56.7
48.9
48.3
48.3
43.8
40.0
37.8
36.7
35.6
31.1
24.0
                                     20

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Table V
Implementation Progress on Individual ISO 14001 Elements
ISO 14001 Element
4.5.3 Records
4.2 Policy
4.3.4 Environmental mgmt program
4.4.2 Training/awareness/competence
4.3.3 Objectives and targets
4.4. 1 Structure and responsibility
4.3.1 Environmental aspects
4.4.6 Operational control
4.4.4 EMS documentation
4.4.5 Document control
4.4.7 Emergency preparedness/resp
4.5.2 Nonconformance/corr&prev action
4.6 Management review
4.5. 1 Monitoring and measurement
4.3.2 Legal and other requirements
4.4.3 Communication
4.5.4 EMS audit
Initial
%YES
6.7
44.4
17.8
18.9
22.2
28.3
15.6
20.0
10.0
19.0
35.6
13.3
20.0
24.4
53.3
22.2
13.3
Final
%YES
48.3
84.4
57.8
56.7
57.8
61.7
48.9
48.3
36.7
43.8
57.8
31.1
37.8
40.0
66.7
35.6
24.0
Final minus
initial
41.6
40
40
37.8
35.6
33.4
33.3
28.3
26.7
24.8
22.2
17.8
17.8
15.6
13.4
13.4
10.7
It is difficult to draw hard conclusions from Tables IV and V because many factors may
contribute to why certain ISO 14001 elements were more developed than others at the beginning
of the project, or why organizations addressed certain elements of the Standard before others.
However, a few observations from Tables IV and V are provided below.

Policy was evaluated the highest in implementation in the final assessment (84.4%) and the
second highest in the initial assessment (44.4%). Moreover, Policy was ranked 2nd in progress.
EMS audit, on the other hand, was evaluated quite low in both the initial assessments (13.3%)
and final assessments  (24.0%). It is perhaps not surprising that Policy was ranked high.
However, it is unclear why EMS audit was ranked so low.  One possible reason is that
                                          21

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organizations may choose to wait until most other EMS elements are in place before developing
an EMS audit program. Another possible reason is that organizations may tend to rate
themselves down on this element because they have not yet performed an audit, even if they have
the procedures in place.

Although Records was evaluated the lowest in the initial assessments (6.7%), the greatest
progress was made on that element (up to 48.3%).  On the other hand, Legal and other
requirements., which received the highest evaluation initially (53.3%), made relatively little
progress over the course of the project (up to 66.7%).  It is not clear what factors may have
contributed to these results.

Environmental aspects was ranked quite low in the initial assessment (15.6%), but significant
progress was made over the course of the project (up to 48.9%).  The low initial evaluation for
this element likely reflects that most organizations have not yet attempted to conduct a formal
assessment of their environmental aspects and impacts because doing so is  not required under
traditional command and control. The significant progress made over the course of the project is
probably due to the fact that many participants recognized the importance of identifying
environmental aspects and impacts early on in the EMS implementation process.
Findings from Independent Assessments

This section discusses the results of the four independent EMS assessments performed in October
1996. First, the aggregate findings are analyzed.  Then, several examples are given of specific
requirements where there were differences between the self-assessments and independent
assessments. Finally, some additional observations from the independent assessments are
discussed.
Aggregate Results

For the four organizations receiving independent assessments, a total of 252 requirements were
evaluated (4 x 63 requirements in assessment tool = 252).  The evaluations were analyzed by
identifying all those requirements for which there were differences on the YES/NO response
between the self-assessment and independent assessment.  The analysis showed that
approximately 76 of the 252 requirements, or 30%, were evaluated differently on the YES/NO
response.  Twenty-four percent (61 out of 252) were rated lower by the independent auditors;
i.e., the independent auditor evaluated these requirements  as NO, but the organization evaluated
them as YES. Six percent (15 out of 252) were rated higher; i.e., the independent auditor
evaluated these requirements as YES, but the organization evaluated them as NO.  Notably, 13 of
the 15 requirements evaluated higher were in one organization.

These differences were distributed throughout the Standard.  All of the 17 elements of ISO 14001
                                           22

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showed at least one of the four organizations with a difference on the YES/NO response.
Moreover, 51 of the 63 requirements showed at least one organization with a difference on the
YES/NO response; however, for only three of the 63 requirements did three or more of the four
organizations have differences on the YES/NO response.

The most notable differences in the Standard between the self-assessments and independent
assessments were found in the sections on Objectives and targets and Environmental
management program.  In Objectives and tar gets, five out of the 12 responses were evaluated
lower, while two were evaluated higher. The most significant differences were found in the
language requiring organizations to consider their significant environmental aspects and the views
of interested parties when setting environmental objectives. In Environmental management
program., seven out of 12 responses were evaluated down, while none were evaluated up.  The
most significant differences in this section were found in the language requiring organizations to
include the means and time-frame by which objectives and targets will be achieved.

Since 24% of all the requirements were evaluated lower, and only 6% were evaluated higher,
these findings suggest that the %YES  of the initial and final self-assessment results would have
been lower if all the EMS assessments had been conducted by independent auditors rather than by
the organizations themselves.  And because seven out of 12 responses in the Environmental
management program section of the Standard were evaluated lower, this section in particular may
have been evaluated too high in the self-assessments.  These findings do not imply, however, that
less overall progress was made over the course of the project, since any "self-assessment bias"
would have  been a factor in both the initial and final self-assessments.  In fact, there was likely
more bias in the initial self-assessments because the organizations' understanding of the Standard
was probably not as thorough.  This suggests that the overall progress may have actually been
greater than  the observed difference, even though the initial and final %YES may have been lower
than reported in the self-assessments.
Specific Examples from the Standard

Two types of differences were observed between the self-assessments and independent
assessments:

•      differences in how the organization and the auditors interpreted the intent of ISO 14001
       requirements; and

       differences in opinion on what environmental management practices satisfied particular
       ISO 14001 requirements. (Note: this could be the case even if there is agreement between
       the organization and the auditors on the intent of the Standard).
A small number of differences found between the self-assessments and independent assessments
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were due to auditor oversights.

Most of the differences appeared to fall under the second type — differences in opinion — but in
many cases it was difficult to differentiate between interpretation and opinion since the two are so
closely linked. However, in some cases the differences could be explained fairly clearly by one
type or the other.  A few examples of each case are provided below.
       Differences in Interpretation. One organization's Environmental policy did not have the
       terms "prevention of pollution" or "pollution prevention;" rather, it had the terms "waste
       management" and "waste minimization." While the independent auditors felt that the
       word "prevention" was required, the organization believed that "minimization" was
       sufficient. Therefore, the organization evaluated itself as COM on this requirement, while
       the auditors evaluated it as PAR on the requirement.

       Another organization was evaluated higher on several requirements due to a different
       interpretation of the Standard. The reason for the auditors evaluating these requirements
       higher than the organization did was the same in each case.  The organization believed that
       several requirements could not be complete (i.e., COM or ES) because they had not
       implemented every element of the ISO  14001 Standard. For example, in Structure and
       responsibility, the organization evaluated itself as PAR on the requirement that
       management provide "essential resources;" it did so because it did not have a specific
       budget item for an ISO 14001 EMS. The auditors, however, evaluated this requirement
       as COM because they had observed that the existing EMS was being adequately
       resourced.

       Also in Structure and responsibility, the organization evaluated itself as NA (No Action)
       on the requirement that the management representative report EMS performance to top
       management. It reasoned that it could not report on the EMS because it did not yet have
       an ISO 14001 EMS. Again the auditors evaluated this requirement as COM because the
       management representative was in fact reporting regularly to top management on the
       performance of the existing EMS.  The same type of situation occurred in the sections on
       Training, awareness and competence and Management review in which the organization
       evaluated itself as NO on certain requirements, while the auditors evaluated the
       organization as YES on those requirements.
       Differences in Opinion. Under Objectives and targets, one organization was evaluated
       lower on the requirement that significant environmental aspects be considered in
       establishing and reviewing objectives and targets.  In the judgement of the auditors, the
       objectives and targets did not adequately address the organization's significant
       environmental aspects.  Unlike with the above examples, this YES/NO difference was not
       caused by differing interpretations of the  Standard; both the organization and the auditor
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       agreed that significant aspects were considered, but the auditors felt that aspects had not
       been considered adequately.  In the same organization under Document control., the
       auditors evaluated lower the requirement that "documentation shall be legible, dated, and
       readily identifiable..." because the organization had not placed footers on each page of
       controlled documents to prevent copying pages out of context.  This reflects a difference
       in judgement about what constitutes an effective document control  system, rather than a
       difference in interpretation of the requirement.

       In another organization, under  Training, awareness and competence, the auditors
       evaluated lower the requirement that "training needs be identified" because the
       organization had not indicated who would be responsible for identifying those needs.
       Again, this difference is more a matter of judgement or opinion than interpretation, since it
       does not state in the Standard that the  organization must specify the individual who is
       responsible for identifying training needs.
Additional Observations

Following the independent assessments, the audit teams were asked to report any additional
observations regarding the four organizations' EMS implementation processes. They observed
two areas with which the organizations appeared to be most challenged: (1) EMS planning; and
(2) taking advantage of the existing ISO 9000 system to help develop EMS procedures and
documentation.

The auditors found that, as a whole, the four organizations were having more difficulty with EMS
planning (with the exception of Legal and other requirements) than with the other parts of the
Standard. Although all the organizations had at least some of the planning requirements in place,
each organization needed to make improvements in several areas. For example, one organization
had not considered all of its activities, products or services in identifying its environmental
aspects.  Another organization had set objectives and targets, but had not communicated them to
upper management. A third organization had identified significant environmental aspects and set
objectives and targets, but had not adequately identified the means and time-frame for achieving
the objectives and targets.

The auditors also found that those organizations with ISO 9000 systems  (three of the four
organizations were registered  to ISO 9000) were not taking full advantage of their internal
expertise in management systems to prepare procedures and documentation for the EMS. In all
three cases, the environmental manager responsible for the EMS was surprisingly disconnected
from the activities of the ISO  9000 staff.  For example, in one organization the environmental
manager was not aware  that certain environmental procedures had already been incorporated into
the ISO 9000 system.
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V. FINDINGS ON KEY EMS IMPLEMENTATION ISSUES
The primary source of information for this section is the set of question responses submitted by 14
participants at the conclusion of the project.  The questions (which are listed in Appendix B) were
open-ended; i.e., information was not collected through a formal survey that provided response
choices. This section also draws, to a limited extent, on information presented in the self-written
case studies and on observations made by project staff during the four meetings held atNSF
International.
Incentives for Implementing an EMS

There are many reasons why project participants decided to develop an EMS based on ISO
14001. The major incentives cited by participants are discussed below (note that incentives
should be differentiated from benefits, which is discussed later in this section).
Competitive Advantage

Most participants believed that implementing an EMS will be important in maintaining or gaining
competitive advantage (seven of the organizations reported that competitive advantage was an
incentive for implementing an EMS, and competitive advantage was discussed frequently at the
meetings).  However, participants did not always specify whether the advantage would be derived
from external recognition (i.e., registration) or from the benefits of improved environmental
management. For some participants, the anticipated competitive advantage may have been
different among departments in the organization.  For example, two participants reported that the
environmental management department believed that competitive advantage would be derived
from improved environmental management, while upper management believed that competitive
advantage would derive from external recognition.

Although competitive advantage can be viewed as an obvious incentive (i.e.,  an organization
would not implement an EMS if it believed that doing so would not in some way lead to
competitive advantage), it is discussed here because it was mentioned quite frequently throughout
the project.
Improved Environmental Performance

Six of the participants cited improved environmental performance as a reason for implementing
the ISO 14001 Standard. These organizations view the EMS as a good way to identify pollution
prevention opportunities and encourage continual improvement of environmental performance.
As discussed below under Benefits and Costs, several participants did realize improvements in
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environmental performance as a result of implementing an EMS.
Possible ISO 14001 Registration

Preparing for possible ISO 14001 registration was cited by five of the project participants as an
incentive for implementing an EMS. Anticipating the need for ISO 14001 registration is
important for companies that sell products internationally or operate facilities overseas. It is
believed by many that ISO 14001 registration could become a de facto requirement in
international markets and in the U.S. marketplace as well. Registration is also seen by some
companies as a potential way to demonstrate environmental performance to customers and other
stakeholders including regulators, insurance companies, and community groups.

Two participants stated that implementing ISO 14001 would be an effective way to demonstrate
good environmental practices  externally, even though they did not tie that potential benefit
directly to registration.
Enhanced Regulatory Compliance

Four participants cited enhanced regulatory compliance as an important reason they were
implementing an EMS. Some participants viewed an EMS as a mechanism for cost-effectively
maintaining compliance.  Twice as many participants (eight) reported at the end of the project that
they believed implementing an EMS would in fact improve their compliance management. It
should be noted that the participants generally had very good systems to manage compliance
before the project began.
Possible Regulatory Flexibility

The term "regulatory flexibility" is used to describe regulatory changes such as fewer inspections,
reduced fines, and expedited permitting.  Many organizations are hoping that having both a solid
compliance record and a proactive EMS will result in regulators focusing efforts on organizations
with significant compliance problems.  Currently, regulatory flexibility appears to be a fairly weak
incentive (although three project participants did cite it as an incentive) because regulatory
agencies have not yet determined how to integrate ISO 14001 into their regulatory programs. If
regulators determine that regulatory flexibility can be effectively linked to ISO 14001, and if
agencies begin to make significant changes, then regulatory flexibility may become a much
stronger incentive than it is now.
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Benefits and Costs of Implementation

Every organization faced with the decision of whether or not to implement ISO 14001 must
estimate the potential benefits and costs.  However, accurately predicting the actual benefits and
costs can be quite difficult.  An organization may rely on its previous experience with ISO 9000
or other management systems to estimate EMS benefits and costs, or it may look at the
experiences of other organizations.

A common question asked about ISO 14001 is, "What are the benefits and costs of implementing
the Standard?"  This question is difficult to answer in general terms, because each organization
will realize different benefits and costs based on a variety of factors. These factors include the
size of an organization, and the environmental impacts of its activities, products, and services. An
equally important factor is the extent to which an organization already has the elements of ISO
14001 in place. It is likely that an organization with the majority of ISO 14001  elements already
in place before starting implementation will realize fewer benefits and incur fewer costs than a
similar organization which had significantly fewer elements already in place. An organization's
accounting methods can also affect the manner in which benefits and costs of EMS
implementation are calculated.
Benefits of Implementation

Measuring the benefits of EMS implementation can be challenging. Even for those benefits that
are seemingly measurable (e.g., environmental management cost-savings), it can be difficult for an
organization to conclude that the EMS alone is responsible for a given outcome given all the
other changes occurring in the organization. For example, one organization in the project said
that it had identified some specific environmental management cost-savings while implementing
the EMS, but the organization could not pinpoint to what extent EMS implementation was
responsible for the improvement.

At the conclusion of the project, organizations began to realize some benefits of their efforts.
Most of these benefits were recognized between the third and fourth meetings (i.e., between
December 1995 and June 1996), about one year after the beginning of the project. A few
participants realized some benefits that they had not anticipated at the beginning of the process.

Below is a discussion of the types of benefits participants reported they had realized (or not
realized) at the conclusion of the project. It is important to keep in mind that although most of
these benefits were realized over the course of the project during the ISO 14001 implementation
process, a few participants which already had well developed EMSs reported benefits they had
realized before they became involved in the project. It appears likely that many of the
organizations will realize further benefits over future business cycles.
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Improved Cooperation and Environmental Awareness Among Employees

Five participants reported that the EMS had enhanced awareness of environmental issues among
its employees. Enhanced awareness had resulted in improved employee morale, in addition to
improved operations.  One organization said, "people want to do the right thing in the correct
manner but need to be made aware of the opportunities and methods available."  The
organization noted that the EMS had provided employees with the "opportunities and methods"
to do the right thing.  Another organization reported "an enhanced spirit of cooperation at the
facility" which was attributable to the EMS. This organization commented that "perceptions that
the work force doesn't care about management, or management doesn't care about the work
force, or that corporate is out of touch and offers no practical help are torn down" when
employees at all levels are given enhanced roles in environmental management.  A third
organization reported that heightened responsibility  at the facility level made the facility less
dependent on the corporate environmental office.
Improved Procedures and Documentation

Five participants reported that the EMS had led to improved procedures and documentation. This
reported benefit is interesting in light of the fact that it is common for organizations considering
EMS to complain about the level of documentation that is required in ISO 14001. One
explanation for this seeming discrepancy is that organizations see a value in documentation and
written procedures, but they do not want a standard to require what should or should not be
documented.
Enhanced Regulatory Compliance

Several organizations reported that they had not yet been able to determine if EMS
implementation had actually improved their compliance management; however, most believed that
having an established EMS would do so in the future. Those organizations which began the
project with well-developed systems (primarily the larger organizations) reported that their EMS
had undoubtedly enhanced their ability to maintain regulatory compliance (three organizations
reported this).  As one large organization  summarized: "Our EMS provides the process whereby
environmental laws and regulations are analyzed, guidance is provided, practices are implemented,
and performance is audited.  The reports from the audit feed our continuous improvement cycle."
The three organizations which reported these benefits had realized many of them before
participating in the project; thus, the benefits may be more likely a result of having an EMS in
place than a result of implementing one.
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Improved Environmental Performance

The ISO 14001 Standard defines environmental performance  as "measurable results of the
environmental management system, related to an organization's control of its environmental
aspects, based on its environmental policy, objectives and targets."  Although this definition was
developed through a broad consensus process, there is still no universally shared definition of
environmental performance.   However, it is probable that most people generally view
environmental performance in terms of an organization's ability to maintain compliance and/or
reduce emissions, effluents, and other causes of detrimental environmental impact. It should be
noted that project participants were not asked to consider any particular definition of
environmental performance in reporting how their EMS influenced environmental performance.

Five organizations reported that they had realized improved environmental performance due, at
least in part, to implementing their EMS or having one already established (several others,
particularly those in the earlier stages of implementation, believed that an EMS would lead to
improved performance in the future).  Examples from different organizations are provided below.

       Fifty percent reduction in the quantity of hazardous waste generated over a five year
       period (this benefit was realized before the demonstration project).

•      Improved emergency preparedness and response procedures (this occurred during the
       project).

       Identification and implementation of two specific pollution prevention projects involving
       materials substitution (this occurred during the project).
Reduced Environmental Management Costs

Most organizations reported that it was very difficult to determine if the EMS was responsible for
a net reduction in overall environmental management costs (it is likely that an organization's EMS
would need to be in place for a significant amount of time before the organization could measure
costs-savings). However, a few participants did cite specific cost reductions in a particular area
due to EMS activities.  For example, one organization reported a 74% reduction in hazardous
waste disposal costs over the period of the project.
Access to International Markets

At the end of the Demonstration Project, participants reported that the EMS had not yet opened
or maintained an opportunity in international markets. This finding is consistent with the fact that
market forces for international EMS registration have not yet developed.  One organization said
that it was actually skeptical of the trade benefits of ISO 14001. This organization had originally
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implemented ISO 9000 primarily for trade reasons, but ISO 9000 registration had not resulted in
the competitive advantage that the organization originally anticipated.
Costs of Implementation

The major cost of implementing an EMS is staff time.  If an organization chooses to have an
outside consultant perform a large portion of the work, consulting fees might also be significant.
Other costs might include travel (if, for example, corporate staff are actively involved with an off-
site facility that is developing an EMS), EMS auditor training, and computer software. Additional
costs might be incurred if an organization decides to pursue EMS registration or have a baseline
assessment conducted.

Fewer than half of the participants specifically tracked the costs of EMS implementation, and only
two (both large companies) actually reported estimated costs.  Several organizations noted that
they did not track the costs of EMS implementation because it was not established as a cost
center — it was simply considered a part of doing business. Those that did track costs included
different items in their cost calculations.  For example,  some organizations only tracked consulting
fees and training, while others only tracked staff time.

One participant reported estimated EMS implementation costs in some detail.  Costs were
estimated for 12 facilities from the beginning of implementation (spring 1995) through  initial
registration (around the spring of 1997). Since the estimate only pertains to EMS
implementation, it does not include the future costs of EMS maintenance or registration
surveillance audits.  Table VI below shows categories used by this organization in estimating
costs. It is important to note this is only one example from the 18 organizations participating in
the project, and should not be interpreted as a "typical" case.
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Table VI
One Company's Estimation of EMS Implementation Costs



Corporate
Costs
Costs per
Facility
Total Costs:
Corporate +
12 facilities
Personnel
Costs
Individual
managers
$95,000
includes salary
and overhead
$17,000
includes salary
and overhead
$299,000

Personnel
Costs
Cross Functional
Mgmt. Team
NA
$25,000
includes salary
and overhead
$300,000

Travel


$75,000
5 annual site
visits per
facility, one
person for 2-3
days
$5,000
includes
seminars and
auditor training
$135,000

Materials


$5,000
includes
handbooks,
training,
supplies, etc.
$2,500
includes
handbooks,
training
supplies, etc.
$35,000

Registration


NA
$25,000
based on costs
of ISO 9002
registration
$300,000

                          Total: $1,069,000 corporate-wide, or $89,000 average per facility
Barriers and Keys to Successful Implementation

Even with the commitment of upper management, implementing an EMS can be a challenging
effort, particularly for organizations that have few ISO 14001 elements in place or are unfamiliar
with management system concepts.

Project participants cited several barriers to implementation. By far the most commonly cited
barrier was lack of time due to competing priorities (nine organizations reported this); as will be
discussed later, lack of time tends to be a greater concern for SMEs. Other barriers cited include:

       insufficient support or lack of understanding from top management;
•      insufficient resources;
       uncertainty about the intent of ISO 14001; and
•      an aversion to added documentation and paperwork (a few organizations reported that it
       was difficult to convince the organization to add procedures and documentation to a
       system already perceived as quite successful in maintaining compliance).
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A few central themes on keys to overcoming implementation barriers emerged during the group
meetings and in participants' responses at the conclusion of the project.  They are discussed
below.
Secure Top Management Commitment Early in the Process

Without top management commitment, the resources and support necessary for EMS
implementation is much more difficult to obtain. Although some participants had obtained a
strong commitment from upper management before participating in the project, others struggled
to obtain the necessary support throughout the project.
Gain a Thorough Understanding of ISO 14001

Several participants reported that they came to truly understand the intent of ISO 14001 only
after several months of study, discussions with co-workers and colleagues, and attempts to
implement some of its requirements. One participant reported that it was more stringent on its
final self-assessment than on its initial self-assessment because it had developed a better
understanding of the Standard over the course of the project. Based on the self-assessment
results of the individual organizations (three showed no progress, or negative progress, over the
course of the project), it is likely that other participants had similar experiences.
Perform a Thorough Self-Assessment

A thorough self-assessment of the existing EMS is necessary to provide direction for
implementation. Many participants found it helpful to use a consultant or other external
assistance in performing the assessment, or in reviewing the protocol and results of the
assessment.  As evidenced by the results of the independent assessments, this external objective
review can be important to obtain a more neutral view of the organization's existing EMS and to
provide an additional interpretation of the EMS standard.
Involve Many Functions and Staff Levels in the Planning Process

Several participants reported that one of the keys to successful EMS implementation was
involving representatives from different parts of the organization. This cross-functional
involvement not only brought different expertise together, it also facilitated consensus and
acceptance from the organization as a whole.  Many participants (both small and large) formed
teams  that included employees from manufacturing, marketing, the ISO 9000 program, and other
functions.  Several participants found it very helpful to include employees from the shop floor
because of their intimate knowledge of processes and environmental aspects.  Most teams in
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organizations with multiple facilities were comprised of both facility and corporate employees.
Initially, Set a Small Number of Achievable Environmental Objectives

Some participants reported that setting a limited number of objectives initially helped them
overcome considerable resistance to EMS implementation. One organization, for example,
decided to set and achieve a few simple but meaningful pollution prevention objectives before
developing most of its EMS documentation.  This approach was intended to avert the possibility
of employees being discouraged by the need to write numerous procedures (it was also intended
to convince management that providing resources for the development of procedures was
worthwhile).  The organization reported that setting and accomplishing the pollution prevention
objectives brought a great deal of satisfaction to the employees involved.
Build on Existing Business Practices

One approach to overcoming resistance to change is building on successful ways of doing
business. For example, one participant noted that although there was fairly limited environmental
awareness in the organization, there was widespread understanding and acceptance of basic TQM
principles.  After failing at first to promote the EMS concept in its entirety, the organization chose
to introduce a few environmental objectives - "disguised" as quality objectives - through the
TQM system.  Once these objectives were accepted in the organization, it became easier to  ask
employees to write plans and procedures to address them.
Links with ISO 9000 and Health & Safety

As previously mentioned, most project participants have facilities that are either registered to ISO
9000 (ISO 9001 or 9002) or working towards registration. Only two participants reported that
they were neither registered nor pursuing ISO 9000 registration.  Generally, those organizations
which came into the project with ISO 9000 experience had an easier time convincing others
internally of the value of an EMS.  Having the ISO 9000 system established or under development
meant that the organization was familiar with the concept and benefits of management systems.

Some participants cited specific ISO 14001 elements that had been (or would be) modeled after
analogous elements in the ISO 9000 system.  They anticipated that modeling certain ISO 14001
elements after existing ISO 9000 elements would produce significant cost-savings for EMS
implementation. A collective list of those ISO 14001 elements is  provided below:

• Training, awareness and competence
• EMS documentation
• Document control
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• Operational control
• Monitoring and measurement
• Nonconformance and corrective and preventive action
• Records
• EMS audit
• Management Review

Seven participants reported that they would integrate at least some elements of ISO 9000 and ISO
14001; however, at the end of the project only a few reported that they intended to create one
fully integrated quality and environmental management system in the near future.  One barrier to
integrating the systems is that the individuals responsible for ISO 9000 within many organizations
are often not knowledgeable of environmental management, and in turn,  environmental managers
often lack an understanding of quality management. Because of this, several organizations
reported that it took considerable time to establish links between the environmental and quality
programs.

There can be other constraints to system integration as well. For example, one organization, after
carefully exploring its options about ISO 9000/14001  integration, decided not to combine the two
systems because of a concern that (1) integrating incomplete EMS requirements into the ISO
9000 system could jeopardize their ISO 9000 registration; and  (2) many procedures under the
existing 9000 system were not appropriate for environmental issues. The observation made
during the independent assessments regarding the separation of the environmental management
staff from the ISO 9000 staff confirms that significant barriers  exist to  integrating the two
systems.

Regarding health & safety, six participants reported that they intended to integrate ISO 14001
with their health & safety program.  This is a logical step for those participants that came into the
project with their environmental, health and safety programs already integrated. One organization
plans to fully integrate its ISO 9000, ISO 14001, and health &  safety systems in the long term.
Comparison of SMEs and Large Organizations

As Table I depicts, the 18 organizations that participated in the EMS Demonstration Project were
categorized as small, medium, or large entities. The participating organizations include four
small, four medium-sized, and ten large organizations.  Categorization was based solely on the
number of individuals employed by the organizations. An organization with fewer than 250
employees was categorized as "small"; an organization employing between 250 and 1000
individuals was categorized as "medium-sized"; and an organization with more than 1000
employees was categorized as "large". The number of individuals employed by the organization
as a whole was considered (not just the number of employees in a particular facility). No attempt
was made to consider Standard Industrial Classification (SIC Code) or revenue in categorizing
project participants.
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Some of the differences between Small and Medium-Sized Enterprises (SMEs) and large
organizations are analyzed below. Differences discussed included: motivation to implement an
EMS, barriers, and potential SME advantages. Information from eight SMEs and eight large
organizations was considered. (Note: this section on SMEs draws on a slightly different data set
than other parts of Section V.  It includes information from two additional organizations that were
not included in the analysis done for the other sections).
Incentives for Implementing an EMS

SMEs and large organizations cited certain incentives in fairly equal proportions.  For example,
four large organizations and four SMEs stated that a desire to gain a competitive advantage was
an incentive for implementing an EMS.  Likewise, a desire to achieve EMS registration and gain
regulatory flexibility were cited as incentives by equal numbers of SMEs and large organizations.
Other incentives, however, were not cited by SMEs and large organizations in equal proportions.
Of the eight SMEs, four reported a desire to achieve more cost-effective or enhanced compliance
as an incentive for implementing an EMS, and three SMEs stated that a need for better
documentation and procedures was an incentive. None of the large  organizations stated that
"enhanced compliance" or a "need for better documentation" were incentives.  In addition, four
large organizations - but only one SME — reported that improved environmental performance or
the desire to benefit from pollution prevention opportunities were incentives. These findings
suggest that SMEs may be more motivated to implement an EMS because they want to enhance
their compliance management and improve their documentation, while larger organizations may
be more satisfied with their compliance efforts and documentation and are ready to focus on
pollution prevention.
Barriers

Ten participants reported that a lack of time (due to workload and production priorities) was one
of the greatest barriers to implementing an EMS; seven of the eight SMEs reported this, while
only three of the eight large organizations did.  Moreover, four organizations (all SMEs) found
that a lack of resources, including funding, was a significant barrier, and two SMEs reported that
the  allocation of human resources was a significant challenge. In addition to the time and
resource barriers, the SMEs reported several of the challenges that were also mentioned by the
large organizations (e.g.  interpreting the ISO 14001 Standard; achieving detailed documentation;
promoting EMS concepts to management and employees; and training employees).  This suggests
that SMEs and large organizations share many of the same challenges in implementing an EMS,
but that SMEs are more challenged by a lack of time and resources.

One large organization in the project found that it took the organization a great deal of time to
understand the Standard before it was willing to invest time in EMS implementation. This
participant stated, "Our organization dealt with this barrier in a manner which, unfortunately,
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smaller organizations cannot do without hiring outside consultants."  In this case, the corporate
staff invested time in understanding the Standard, and then disseminated guidance tools and
information to personnel at the facility.
Potential SME Advantages

Some project participants also found that an SME can have certain advantages over a large
organization in implementing an EMS. For example,  an SME may be able to develop an EMS
that is less complex than one that might be appropriate for a large organization.  In addition,
employees in SMEs often "wear many hats;" i.e., they have multiple functional responsibilities. In
an SME with ISO 9000 experience, for example, the individual responsible for the quality system
may also be responsible for implementing ISO 14001. In a large organization, however, the
employees responsible for the quality system are more likely to be separate from the
environmental staff.

Certain requirements in ISO 14001 might be easier to implement in an SME than in a large
organization. For example, two SMEs noted that the Structure and responsibility requirements in
ISO  14001  are simpler to achieve in an SMEs than in a large organization, since  an SME typically
has a less complex hierarchy. Other parts of an EMS  that may be simpler for an  SME include
training and internal communication.
Recommended Guidance and Implementation Tools

Based on the experience of the Demonstration Project, it has become evident that certain types of
guidance are very important for organizations of all types and sizes attempting to implement ISO
14001. These include:

• clarification of the intent of the ISO 14001 Standard;
• a checklist or other tool to conduct an EMS self-assessment;
• guidance on how to identify and assess the significance of environmental aspects and impacts;  •
a step-by-step implementation guide;
• examples of EMS manuals, policies, and procedures; and
• EMS implementation case studies.

These are each discussed below.
Clarification of the intent of ISO 14001

The most commonly asked questions from project participants revolved around the intent of the


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ISO 14001 Standard. They want to know what the authors intended in the language of the
Standard, and how registrars will interpret it.  Although interpretation of the Standard is
necessary for organizations to move forward with implementation (and particularly registration),
creating a single authoritative interpretation of the Standard may be problematic. SubTAG 1 of
the U.S. Technical Advisory Group has established a formal process to respond to questions
submitted by interested parties about the interpretation of the ISO 14001 Standard.  SubTAG 1
intends to issue answers to questions based  on the SubTAG's consensus interpretation of the
Standard.  A list of interpretation concerns submitted by project participants is provided in the
next section of the report.

A good way to understand the intent of ISO 14001 is to read EMS implementation guidance
documents, such as ISO 14004 ("Environmental management systems - General guidelines on
principles, systems and supporting techniques").  Another useful document is the guidance for
small and medium-sized organizations developed by NSF International, which is discussed below.
A Checklist or Other Tool to Conduct an EMS Self-Assessment

One of the first steps for an organization considering implementation of ISO 14001 is to conduct
an initial assessment of its current environmental management practices.  Prior to the EMS
Demonstration Project, NSF International developed a user-friendly checklist to help
organizations compare their existing environmental management practices to the requirements of
ISO 14001.  Participants used the checklist in the Demonstration Project, and NSF received
positive feedback on its use.  Other organizations, including the Global Environmental
Management Initiative, have  also developed ISO 14001 assessment tools.
Guidance on How to Identify and Assess the Significance of Environmental Aspects and Impacts

ISO 14001 encourages organizations to move "beyond compliance" through continual
improvement and pollution prevention by identifying environmental impacts and setting objectives
to address them.  In the past, many organizations conducted environmental planning solely in
response to regulatory requirements, or addressed environmental problems on an "ad hoc" basis.
Thus, systematic identification and prioritization of environmental aspects (and resulting impacts),
including those not regulated, is a new process for many organizations. NSF's implementation
guide provides broad guidance on environmental aspects and impacts, but more detailed guidance
for organizations appears to be needed.
A Step-by-Step Implementation Guide

Many organizations, particularly those that do not have much experience with EMS, need to seek
outside expertise to help with the planning process and implementation. However, for smaller
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organizations, which may not have a corporate environmental staff, this assistance is often
unavailable internally and too expensive to secure from a consultant. Through an EPA grant,
NSF has developed "Environmental Management Systems: An Implementation Guide for Small
and Medium-Sized Organizations" that provides step-by-step implementation assistance and
sample worksheets and procedures (although the Guide is directed toward SMEs, it is just as
useful for larger organizations). The NSF document, along with other implementation guides that
are either available now or will be soon, will hopefully help to satisfy the need for cost-effective
step-by-step implementation guidance.
Examples of EMS Manuals, Policies, and Procedures

Most project participants requested examples of EMS manuals, policies, and procedures.
Commonly requested items included: environmental policies, procedures for identifying aspects
and impacts, monitoring and measurement procedures, auditing procedures, etc.  An EMS
manual, although not explicitly required by ISO 14001, can be a useful tool because it provides a
concise overview of the system.
EMS Implementation Case Studies

Organizations considering the implementation of ISO 14001 can benefit from learning why other
organizations implemented an EMS, as well as their experiences with implementation. As more
organizations implement and become registered to ISO 14001, many case studies should become
available.  However, at present relatively few organizations have attempted to implement ISO
14001, and thus the experiences of these few organizations are particularly valuable.  This report
contains self-written case studies from 17 of the 18 organizations that participated in the
Demonstration Project. CEEM, Inc. has also published a collection of EMS case studies.
Participant Feedback on ISO 14001

According to ISO rules, each ISO standard must be updated every five years. Over the next few
years ISO 14001 is likely to be read or implemented by thousands of organizations who will be
able to offer feedback on the  Standard.  Since the EMS Demonstration Project presents an early
opportunity for this process, each participant was asked to provide feedback on ISO 14001.

Project participants generally found ISO 14001 to be a sound model for environmental
management. However, most participants expressed at least some overriding concerns about the
Standard as a whole and/or concerns about specific requirements. The most commonly cited
concern was the potential for  auditors to interpret the Standard differently (note: this may be
viewed as a registration concern rather than a concern about the Standard). Other commonly
reported concerns included confusion over the definition of "environmental aspects;" an
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overemphasis on documentation; and confusion about whether written procedures are necessary
for particular requirements. Additional comments that were submitted regarding specific
requirements are shown in Table VII.
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Table VII
Specific Comments on the ISO 14001 Standard
Section
4.2 Environmental policy
4.2
4.3.1 Environmental aspects
4.3.2 Legal and other
requirements
4.3.3 Objectives and targets
4.3.4 Environmental
management program
4.3.4
4.4.1 Structure and
responsibility
Language
"appropriate to the nature, scale, and environmental
impacts"
"provides the framework for setting and reviewing
environmental objectives and targets"
"identify the environmental aspects of its activities,
products or services... in order to determine... significant
impacts on the environment"
"establish and maintain a procedure to identify and have
access to legal and other requirements..."
"consider... the views of interested parties"
"designation of responsibility for achieving objectives
and targets at each relevant function and level of the
organization"
"programme(s) shall be amended where relevant"
"Roles, responsibility and authorities shall be defined,
documented and communicated"
Comments
A few participants said this requirement is too subjective, and it
is not auditable.
A few participants said the meaning of this requirement is not
clear.
Several participants expressed concerns about the definition of
"aspects" and about how to determine "significance." The
question was raised why the term "aspects" was needed in
addition to "impacts".
One organization felt this was a difficult requirement to interpret.
One participant said this requirement is too subjective, and it is
not auditable.
Two organizations said that they wanted further guidance in the
Standard on how deep into the organization this should go.
One participant felt that more detail is needed to explain under
what circumstances changes should be made.
Two organizations said they wanted further guidance in the
Standard on how many and what type of employees should be
covered by this requirement.
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Section
4.4.2 Training, awareness and
competence
4.4.2
4.4.3 Communication
4.4.3
4.4.4 EMS documentation
4.4.5 Document control
4.4.6 Operational control
4.5.1 Monitoring and
measurement
4.5.2 Nonconformance and
corrective and preventive action
Language
"The organization... shall require that all personnel
whose work may create a significant impact on the
environment, have received appropriate training"
"Personnel... shall be competent"
"the organization shall establish and maintain
procedures for internal communication"
"The organization shall consider processes for external
communication.. .and record its decision"
"The organization shall... describe the core elements of
the management system... [and] provide direction to
related documentation"
"obsolete documents are promptly removed from all
points of issue and points of use" and "any obsolete
documents retained for legal and/or knowledge.. .are
suitably identified"
Entire element
"The organization shall... periodically [evaluate]
compliance with relevant environmental legislation and
regulations"
"action taken to eliminate the causes
of..nonconformance shall be appropriate to the
magnitude of problems and commensurate with the
environmental impact encountered"
Comments
One organization said that it is very difficult to directly tie
environmental impacts to specific employees.
One organization said this requirement was too subjective.
One organization said that more guidance was needed in the
Standard on the meaning of "internal communication."
One organization said that there was no value added for the
organization to record its decision.
Two organizations commented that this requirement was mostly
useful for an auditor.
One organization said that the requirement that documents be
removed from "all" points of issue and use was too stringent; the
organization also felt that the requirement that obsolete
documents be "suitably identified" was not enforceable.
One organization commented that operational control in ISO
14001 is much less specific than it is in ISO 9000, and thus could
potentially be a difficult requirement to implement.
One organization expressed the concern that this requirement
could potentially cause legal difficulties if EMS auditors were to
identify non-compliance with regulations.
The same organization as above commented that this requirement
is unnecessary because few organizations would take action that
was either inappropriate to the magnitude of problems or not
commensurate with the environmental impact encountered.
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Participant Advice to Regulators

Thirteen of the participating organizations provided advice for regulators seeking to use the EMS
approach in their interactions with the regulated community.  The most common advice was that
regulators should offer incentives — primarily regulatory flexibility — to companies that implement
an EMS. These proposed incentives include:

• reductions in reporting;
• reductions in site inspections and audits;
• reductions in fines;
• elimination of penalties and NOVs for various environmental compliance issues; and
• fast-track permitting.

One project participant offered the following advice:  "...(W)e genuinely believe that EMS
implementation will improve our environmental performance. In fact, we have seen indications
already that is exactly what is happening. We would invite regulators to confirm that this is so,
and then, if satisfied, provide significant regulatory relief to companies with effective
environmental management systems."

Two participants expressed concern about the ability  of smaller organizations to afford ISO
14001 registration, and suggested that incentives such as those outlined above be made available
to organizations which have a fully functional EMS but may not be registered to the Standard.

Many participants expressed concern about the voluntary disclosure of self-audits, and expressed
a desire for a greater level of trust between themselves and regulators regarding this issue.
Several participants indicated that there is a fear of being punished for "doing the right thing" in
self-reporting of violations and nonconformances.

One participant noted the similarities between ISO 14001 and the "Due Diligence" criteria
contained in EPA's final policy on auditing and self-policing  — Incentives for Self-Policing:
Discovery, Disclosure, Correction and Prevention of Violations, Jan. 22, 1996 — and expressed
concern about the possibility of this policy becoming a  regulation. The participant noted that
there are benefits resulting from reliable guidance for civil penalty mitigation, but there is a
concern that EMS elements, even if not in a specific EMS standard, will become regulation.

Three participants suggested that regulators provide expertise and assistance to organizations
seeking to implement an EMS. It was suggested that regulators should place more stress on the
value of  an EMS to recipients of NOVs and penalties.
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VI. CONCLUSIONS
Major Lessons Learned
Implementing ISO 14001 is Feasible in a Wide Variety of Organizations

The experience of the Demonstration Project suggests that an EMS based on ISO 14001 can be
implemented in a wide variety of organizations, but varying amounts of guidance and assistance
are required for different organizations. The main factors that seem to determine an
organization's ability to implement an EMS are (1) its experience with EMS, ISO 9000, or other
management system concepts; (2) the level of commitment from its top management; and (3) the
resources available to the organization to develop the necessary procedures and documentation.

Whereas some organizations might be able to implement most ISO 14001  elements in a short
time-frame (e.g., one year) with limited outside guidance, others might require much more time
and a substantial level of guidance. SMEs, in particular, will likely require more guidance and
take longer to complete EMS implementation than large organizations. All project participants
found that a significant level of effort was required, regardless of how fast implementation
occurred or how much outside guidance was used.

Although notable progress on EMS implementation was made over the course of the
Demonstration Project, it is not clear how many participants will  eventually become registered to
ISO 14001 or attempt to implement further elements of the Standard following the project.  Since
it will likely take some participants two or more years to implement ISO 14001, follow-up on
these organizations would be needed to determine the time and effort that  was ultimately
required.

Since the organizations in the project participated voluntarily, they might be inclined to be more
successful with EMS implementation than an average sample of U.S. organizations. However,
the wide variety of organizations in the project, and the significant differences among them in their
abilities to make progress on EMS implementation, provide confidence that the findings from the
project reflect what would be the experience of a large cross-section of U.S. organizations that
might attempt to implement ISO 14001.
EMS Implementation Can Bring Concrete Internal Benefits

Project participants reported many benefits from EMS implementation that were not market- or
trade-related, including enhanced environmental awareness, improved documentation, and
pollution prevention.  These benefits were realized within the one year time-frame of the project,
and before any of the organizations had attained registration or complete implementation. This
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suggests that there are many reasons other than the market and trade benefits of registration to
implement the ISO 14001 Standard.
Independent Assessments Can Provide an Important Check on Self-Assessments

The results of the independent EMS assessments suggest that organizations might have the
tendency to evaluate their systems higher than would independent auditors.  This may be
particularly true for Objectives and targets and the Environmental management program.

The findings from the independent assessments may also have important implications for the
concept of "self-declaration," in which an organization would declare itself to be in conformance
with the ISO 14001 Standard rather than receive an independent audit from a registrar.  The
distinction between self-declaration and registration does becomes  smaller if the self-declaration is
based on an objective audit from a consultant; however, consultants are not required by
accreditation bodies to maintain objectivity in audits or to have specified qualifications for
conducting EMS audits.
Remaining Questions and Areas for Future Study
What are the Long Term Benefits and Costs of an ISO 14001 EMS?

The Demonstration Project focused primarily on the process of developing an EMS, not on the
benefits and costs of maintaining one. In the future, studies could be conducted which attempt to
measure and quantify the benefits  and costs of maintaining an EMS over time in a variety of
organizations.
Will Implementing ISO 14001 Improve Environmental Performance?

A question frequently asked is whether implementing and maintaining an ISO 14001 EMS will
improve an organization's overall compliance and environmental performance. The answer to this
question may become increasingly important if regulators seek to use ISO 14001 as a tool to
complement regulatory programs.  Although it was not within the scope of this project to measure
environmental performance, the project provided an opportunity to make several observations
about the relationship between environmental performance and organizations' motivations for
implementing ISO 14001.  The brief discussion below is intended to raise questions about this
relationship that might be addressed through future studies.

The extent to which an ISO 14001 EMS will improve an organization's environmental
performance may  depend primarily on upper management's commitment to improving compliance
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and performance.  It is difficult to argue that a fully implemented EMS will not improve the
performance of an organization struggling to maintain compliance.  However, if the organization
lacks upper management commitment to improve, it is unlikely to develop an EMS in the first
place unless it is mandated to do so through contract or market requirements. Similarly, if the
upper management of an organization having a solid compliance record is not interested in going
beyond compliance, it is unlikely that the organization will implement ISO 14001 solely because it
wants to motivate itself to move in that direction; in this case, the organization would be more
likely to implement the Standard in order to position itself strongly in the marketplace.

Even if an organization's motivation for implementing and maintaining an EMS is market-driven
and not performance-driven, it's certainly possible that the EMS, once in place, could lead an
organization to recognize the environmental and economic benefits of pollution prevention and
other proactive activities. If this were to occur, the organization might begin to set and meet
environmental objectives and targets that go beyond compliance. Thus, an organization might not
be initially motivated to implement ISO 14001 because of a desire to improve performance, but
the EMS could lead to improved performance once established in the organization.

The nature of the relationship between EMS implementation and environmental performance
cannot be known until a substantial number of organizations of different types and sizes
implement the ISO 14001 Standard. In the future, studies could be performed examining the
relationship between management systems, management attitudes, and particular performance
parameters.
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VII. CASE STUDIES
Participants in the EMS Demonstration Project were asked to write case studies of their own
experiences with the project and EMS implementation.  The case studies are important because
they convey how the individual organizations view EMS and ISO 14000; they also constitute the
only part of the report in which information associated with specific companies is presented. All
participants submitted case studies for inclusion in this report, with the exception of Prime
Tanning Company.

All but two of the case studies were written by the organizations and edited by NSF International
(the case studies for Hach Company and Milan Screw Products, which were adapted from NSF's
EMS implementation guide for small and medium-sized organizations, were written by NSF). The
primary purpose of the editing process was to create a uniform format for the case studies.
Although the case study formats are not identical, most contain the following sections:
Background, Drivers for Implementing an EMS, Self-Assessment, Implementation, Benefits,
Challenges, and Final Thoughts.
Notes on the Case Studies

       Several case studies refer to NSF 110, an interim EMS standard developed by NSF
       International prior to the development of ISO 14001.  As discussed in Section IV, both
       NSF 110 and the ISO 14001 draft were used in the initial self-assessments.

       The terms "registration" and "certification" are used interchangeably in the case studies.
       Essentially, the terms have the same meaning. The difference is that in the U.S., the term
       registration pertains to management systems (i.e., ISO 9000, QS 9000, and ISO 14001),
       while certification pertains to products.  In other countries, certification pertains to both
       management systems and products.

       Some of the case studies refer to "percent of EMS requirements in place," or "percent of
       EMS requirements complete." Please refer to Section IV for an explanation of how this
       type of information was generated through the self-assessments.
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                                 3M Corporation

Background

3M, based in St. Paul, Minnesota, is a $14 billion, multinational firm with over 50,000 products.
These products are manufactured by over 40 business units operating in more than 300 locations.
Globally, 3M has 69,000 employees and operations in more than 60 countries.

3M has long been recognized as an environmental leader that manufactures innovative, high
quality products.  Approximately 200 of 3M's facilities worldwide have been registered (or are in
the process of being registered) to the ISO 9001 or ISO 9002 Standards.


Drivers for Implementing an EMS

More than 30 years ago, the need to address potential environmental issues at the corporate level
was recognized within 3M.  The company's commitment to the environment was formalized when
the 3M Board of Directors adopted the Corporate Environmental Policy in February 1975. This
policy, which remains unchanged today, was crafted long before most companies had developed
such policies.

A highly successful waste minimization program known as Pollution Prevention Pays (3P) was
launched in 1975. Today, the 3P program continues to encourage employees to find innovative
ways to minimize wastes and reduce costs. The 3P program has prevented 1.4 billion pounds of
pollutants from entering our environment while saving the company 750 million dollars that would
otherwise have been spent on pollution control and wasted resources. 3P continues to be an
internationally acclaimed model waste minimization program. The corporate environmental
organization (Environmental Technologies and Services (ET&S)) has initiated numerous
additional environmental programs for managing other  specific environmental aspects (e.g.,
underground tanks, asbestos, air emissions, etc.) on a global basis.  These efforts have
substantially reduced wastes and emissions and move 3M towards sustainable development. 3M's
corporate ET&S staff viewed the EMS Demonstration  Project as an opportunity to gain
experience in formalizing an environmental management system (EMS) at a 3M facility and to
increase 3M's institutional knowledge of EMS reviews.

The 3M Dental Products facility in Irvine, California volunteered to be the pilot site for the EMS
Demonstration Project.  The Irvine site's interest in pursuing ISO 14001 is a natural  outcome of
their business and environmental culture. Irvine has the strong management support essential for
an EMS to be successful.  The site, which employs 240 people, manufactures and markets over
700 products used in dental offices and orthodontic laboratories worldwide.  The Irvine facility
was the first 3M facility to obtain ISO 9001 registration. The site also has been working through
the Malcolm Baldridge Award process at the state and national levels. Due to the nature of its
products, the 3M Dental Division also has significant involvement with the US Food and Drug
Administration.

The Irvine operation's primary customers are dentists.  The division has significant export markets

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beyond North America (including the European Union, Pacific Rim, South America, and Africa).
Products manufactured include dental restoratives (such as aesthetic filling materials for teeth),
dental adhesives, caps, and impressioning materials used in making bridges and crowns.
Self-Assessment

The initial EMS review was conducted in May 1995.  The NSF self-assessment tool was used to
conduct an evaluation of the site's existing EMS versus the requirements of ISO 14001. Potential
ISO 14001 linkages with existing ISO 9000 requirements were identified, and the development of
an implementation guide for use by other 3M locations was initiated.

The review team consisted of three 3M ET&S staff members (the Quality Manager, Auditing
Supervisor, and a Senior Environmental Auditor), a 3M Corporate ISO 9000 Quality Manager,
and an independent environmental consultant familiar with the NSF and ISO environmental
management standards. Three preliminary site contacts (the Environmental Engineer, Safety,
Health and Environmental Manager, and ISO 9000 Quality Manager) were heavily  involved in the
initial assessment.
Implementation

Independent of the development of ISO 14001 and the EMS Demonstration Project, 3M had been
moving towards more formal documentation of its EMS. In 1994, a formal EMS was initiated for
3M's international locations and discussions were initiated for implementing this process on a
global basis. The 3M vision and mission statement are as follows:


Vision: "3M practices sustainable development by  continuously improving the
environmental performance of our products and processes."

Mission: "The EMS will ensure compliance to global regulations and 3M policies and will
facilitate continuous improvement of environmental performance."
Once the initial self-assessment was completed (including a written report assessing observed
gaps), internal division resources were used to review the identified gaps, define an
implementation plan, and close each gap. A Gant chart was used to ensure that the
implementation plan described a logical sequence of events (for example, you cannot conduct an
EMS audit until you have identified and defined all of the EMS elements and have trained
auditors).

Although follow-up efforts were primarily the responsibility of the Irvine site, the facility also
utilized division-level resources. For example, a division representative trained in ISO 9000
auditing had significant involvement in the development of the EMS documents. A team
consisting of two site employees and one division employee spent six and one-half months

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preparing EMS documentation.  Since there are major similarities between ISO 9000 and ISO
14001, eight of the 22 documented EMS procedures came directly from Irvine's ISO 9001
Quality Manual.  These procedures were in the areas of:
       training, awareness, and competence

       management system documentation

•       document control

       monitoring and measurement (calibration of equipment for both process and test)

       nonconformance (corrective and preventive action/root cause analysis and closure)

       records (identification and retention)

       management system auditing (internal and external)

•       management review
In addition to writing a site-specific Environmental Management Systems Policy Manual, a total
of 22 Standard Operating Procedures (SOPs) were written to address all areas of ISO 14001.

The ISO 14001  certification audit occurred in June 1996, and the facility received its certification
to the ISO 14001 DIS in July 1996.  The registrar used for the ISO 14001 audit was also used by
the Irvine site for its ISO 9001 registration.
Challenges

The biggest obstacle encountered was in interpreting the ISO 14001 Standard.  While the
Standard describes what should be included in an EMS, it leaves the level of detail and level of
documentation open to interpretation. Through substantial literature review and numerous
discussions with peers, consultants and potential registrars (as well as internal discussions), an
agreement was reached on 3M interpretations that define our "Practice in Place" for each element
of the ISO 14001  Standard.

Although the site has not seen a reduction in overall environmental costs as a result of the EMS,
neither has it seen an increase in environmental costs.  Current estimates are that development and
implementation of the EMS for the Irvine site required approximately 1,200 person-hours,
covering both facility and division personnel. Much of the effort was spent in interpreting and
understanding the Standard and designing the Environmental Policy Manual. This estimate
includes the time required for SOP documentation and additional EMS training for facility
personnel. Overall costs to develop an EMS implementation strategy and corporate guidance
have not been defined.
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Benefits

Implementing this EMS model brings a more systematic approach to managing overall
environmental compliance. The EMS also leads to more direct ownership of environmental
compliance issues by facility operations and potentially reduces reliance on corporate staff.
Through the process of continuous improvement, more focused resource utilization, and issues
management concepts (which are inherent in the ISO 14001 process), further environmental
improvements will occur.  Ultimately, this process is a necessary element of 3M's sustainable
development efforts to develop products that meet customer needs and respect the ability of
future generations to meet their own needs.
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                                   Allergan, Inc.

Background

Allergan, Inc. is a pharmaceutical manufacturer of eye care and skin care products. The
company's headquarters is located in Irvine, California and maintains operations worldwide.  The
Allergan facility in Waco, Texas was selected to participate in the EMS Demonstration Project.


Drivers for Implementing an EMS

Allergan is pursuing the development of a formal EMS and independent certification under
various worldwide standards for a variety of reasons.  These are listed below.

       A formal EMS will help the company to ensure regulatory compliance.
•      A high environmental standard is already in place at Allergan.
       Allergan's competitors are preparing to implement EMS standards and intend to become
       certified to them.
•      Development of a formal EMS might be required by certain governmental bodies if
       voluntary EMS efforts by industry are  not effective.
       Obtaining permits and approvals from  regulatory agencies and communities might be
       streamlined if a facility has ISO 14001 or Eco-Management and Audit Scheme (EMAS)
       certification.
•      Regulatory audits and inspections might be reduced if a formal EMS exists.
•      New drug  approvals (by the US Food and Drug Administration or Ministries of Health in
       other countries) and other required approvals might be streamlined.
       EH&S operations at the facility level should improve over time where a formal plan and
       actions are in place for attaining and maintaining certification.
       Adoption of a formal EMS might provide marketing opportunities (by easing the entrance
       into new markets).


Self-Assessment

At the outset of the project, the Waco facility already had a well-developed and formal
environmental program in place.  Allergan wanted to test this program against the requirements of
NSF 110 and to determine where improvements could be made.  The facility had also attained
ISO 9002 certification and thus had a formal quality process in operation.

NSF supplied an EMS self-assessment tool along with training and guidance on how to conduct
the self-assessment and interpret its  results.  The site's Facility Management Team and the
Corporate EH&S  Team both supported the pilot assessment. Based on this assessment, some
minor deficiencies in the EMS were discovered and corrective actions were subsequently
implemented.
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Since the Waco facility is routinely inspected by FDA and other regulatory agencies, the site was
ready to be evaluated by an external third-party EMS assessor. Allergan contracted with an
assessor to conduct a one-day independent assessment of the Waco facility's EMS.  This follow-
up assessment was conducted three months after the initial (internal) self-assessment.  The
independent assessor reviewed the facility's environmental manual, which covered the nine major
topics in NSF  110.
Implementation

Allergan has found that one of the key challenges in implementing a formal EMS is the need to
clearly demonstrate the system's positive benefits. The ability to demonstrate cost savings from
pollution prevention/waste minimization activities helped to improve the credibility of Allergan's
environmental program.  In addition, putting environmental performance criteria into all job
descriptions, performance reviews, and specific management objectives helped to maintain focus
on the environmental area and supported our efforts to integrate environmental management with
other business requirements.

During the course of our implementation process, we also found that learning to "speak the
language" of other business functions (such as Marketing, Sales, R & D, and Production) was
critical to obtaining and maintaining the support of key business managers.
Benefits

By providing a structured methodology for evaluating EH&S effects, policies, business and legal
requirements, stakeholder interests, and objectives and targets at the facility level, the
demonstration project proved to be very beneficial.  Allergan also benefited from the development
of written EMS implementation action plans.

The EMS has also helped to ensure regulatory compliance by providing a methodology for
managing compliance requirements and correcting deficiencies.  While the company already had a
compliance process in place, the EMS made this process more formal by tying accountability and
performance to individual employees.  In addition, education and awareness related to the EMS
have improved considerably as a result of the project.

Finally, the EMS process facilitated the institution of a formal product design process that
incorporated life-cycle concepts.
Challenges

Allergan has identified several issues which might affect EMS implementation and certification.
Two of these are discussed below.
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       It is not clear whether an EMS certification for a facility that is part of a larger
       organization must "stand alone" on all EMS elements or whether some elements can be
       addressed by a corporate function or another facility within the organization. One
       example at Allergan would be product design. Allergan's Waco facility is a manufacturing
       site and has very little control over product design, including product packaging.  It may
       take several years of research and development on a product before the manufacturing
       facility is made aware that a new product will be manufactured at that site. If certain
       activities or functions are outside the control of a facility seeking registration, how will a
       registrar determine if EMS elements related to those activities or functions have been
       adequately addressed?

       The threshold criteria for certification are not clear at this time. Could a facility achieve
       certification if all  elements of the EMS  standard have not been fully addressed? Guidance
       is needed to allow companies to make internal judgments as to whether or not a facility is
       ready for certification.
Final Thoughts

In retrospect, a one-day review of the EMS by an outside assessor was not adequate to cover all
EMS elements and to show evidence of achievement.  Two days should be adequate for this
purpose. In addition, it would be preferable to have two assessors evaluate a facility's EMS,
thereby ensuring a more objective review of the system and allowing for "reality checks" between
the assessors.

As of December 1996, Allergan had received EMS registration at its facility in Westport, Ireland
(the facility was registered to ISO 14001 and IS 310 (the Irish national EMS standard)).  Allergan
had also received a recommendation for registration to ISO 14001 at its Waco, Texas facility.
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                     Commodore Applied Technologies

Background

Commodore Applied Technologies, Inc. is a small publicly-owned company specializing in the
discovery and development of new technologies for the remediation of hazardous materials.
Although small in size (currently the company employs 25 staff members), Commodore can list
among its achievements the only operating permit for a non-thermal PCB destruction process
granted by the US Environmental Protection Agency. In addition, Commodore's Agent 313™
technology for environmental restoration and remediation was selected by the US Department of
Commerce as one often innovative technologies for the Rapid Commercialization Initiative
Program.


Drivers for Implementing an EMS

There are two primary motivations for Commodore to implement an EMS — regulatory
compliance and an anticipated competitive business advantage. Commodore is required under the
terms of its EPA permits to have an EMS. The company believes that an EMS designed to
conform with ISO 14001 would satisfy those permit requirements in a manner that also addresses
the company's other business needs. Commodore further envisions that an EMS will help the
company become more effective at compliance, and expects that companies certified to ISO
14001 will be looked upon favorably by both regulators and customers. Because Commodore is
an environmental business, it was desirable to lead by example in the area of EMS development.


Implementation

Small businesses face many challenges when trying to comply with state and federal regulations
and when competing with larger, more established businesses. We believed that implementation
of ISO 14001, while providing the benefits noted above, would be a considerable challenge for
our company.

Initially, our worst fears were realized.  Limited staff and other resources made it difficult to
compose and review the new policies and procedures required to satisfy the ISO 14001 Standard.
Those same organizational limitations left us with a system that was often no more than one layer
deep. Also, due to the size of the organization, the employees implementing the procedures were
also responsible for management review.  Additionally, urgent business needs frequently delayed
work on EMS documentation.  It began to appear that a task of this magnitude might be beyond
the capabilities of a small business such as ours.  While the company continued to have a strong
commitment to an EMS and to the creation all of the procedures and programs necessary to
effectively operate an environmental business, the problem was in backing up that commitment
with action.

Surprisingly, Commodore found that the ISO 14001 Standard actually was the solution to our
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EMS development challenge — that is, by using the ISO 14001 framework as a template for the
EMS, we found that some of the system design work had already been done for us.

As a small business without a formal management system, it was found that Commodore actually
might have several advantages over a large business with an established EMS, such as:

•  building policies and procedures was simplified in a small organization;
   an EMS culture could be built from the beginning (rather than adding EMS onto an existing
   management system); and,
•  policies and procedures could be written to follow the ISO 14001 format the first time, rather
   than rewritten at a later date.

In other words, it was not necessary to change a culture at Commodore, rather, we had to create
one.  Furthermore, since Commodore has an operational commitment to both ISO 14001 and ISO
9000,  it was possible to build all  of the system documentation to follow ISO format and ideals.

Using the concepts in ISO 14001, Commodore began to write its environmental policy and
procedures. Since the environmental policy and all of the EMS procedures were new,
Commodore was able to base everything on the requirements of the ISO Standard. By creating
policies, procedures and other EMS documents "from scratch," it is expected that
nonconformities related to the system's documentation and its contents can be avoided.
Final Thoughts

Commodore gained a lot of knowledge and experience from the EMS Demonstration Project.
The opportunity to benchmark with other companies and to share solutions for overcoming
common challenges has been a great advantage in the EMS planning stages.

As with anything new, there are questions that remain unanswered. The most significant relates to
the value of ISO 14000 certification.  No one can say for certain what the value of certification
will be.  It is hoped that certification will cause regulators to look favorably upon companies
during inspections or incidents. It is also hoped that certification will prove advantageous in the
marketplace. But no one really knows. Nonetheless, Commodore believes that the value is in the
doing, and that having an EMS is the right thing to do.
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                                Fluke Corporation

Background

Fluke Corporation is a global manufacturer of electronic test and measurement instruments,
including multimeters, oscilloscopes and other devices. With annual sales exceeding $400 million,
Fluke sells its products in over 80 countries. The distribution of sales is 40% in the U.S., 40% in
Europe, and 20% elsewhere, including Asia. Fluke's worldwide headquarters is in Everett,
Washington, and the European headquarters is in Eindhoven, The Netherlands. Fluke product
development divisions and manufacturing facilities are in Everett, Washington, and Almelo, The
Netherlands.

Fluke is a vertically integrated company, which means that it manufactures many of its own
instrument components, including printed circuit boards, semiconductors and other
microelectronic components, and plastic parts. These processes are the source of large quantities
of hazardous wastes, wastewater (which must be treated prior to discharge), and air emissions
which must be controlled.
Drivers for Implementing an EMS

Fluke has been in the process of implementing an EMS since about 1988. The implementation
began with an expansion of the environmental program to include activities which go "beyond
compliance." These activities include pollution prevention, and integration of environmental
responsibilities into overall business practices. Integration has been achieved by a decentralized
corporate environmental staff. At the same time, environmental issues began to become
recognized as "quality" issues, resulting in integration of the quality and environmental programs.
This realignment has resulted in significant cost savings through more efficient use of materials,
waste minimization, and other activities which directly impact profitability.

With almost two-thirds of its business outside the U.S., Fluke is very aware of the impact of
international standards and directives on its processes, products, and sales. Fluke was the first
company based in Washington  State to achieve ISO 9001 certification, in 1993. As a result of
this awareness of the international marketplace, Fluke has been gradually developing an EMS
which will conform to international standards: first the British Standard BS 7750; and now ISO
14001. The primary driver for implementation of an EMS is the market itself, both in terms of
product end-user (customer) expectations, and potential trade barriers.
Self-Assessment

An initial self-assessment was conducted in June 1995. This assessment indicated that Fluke's
EMS conformed to approximately 55% of the draft ISO 14001 Standard. The major areas that
were not in conformance with the Standard were EMS documentation, formal objective setting,
and self-auditing.

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Implementation

A long history of progressive environmental management at Fluke, which continues to reap
bottom line benefits, indicates that the existing EMS is highly effective.

In early 1996, Fluke management made a deliberate decision to delay the full implementation of
ISO 14001, and third-party certification, indefinitely. This decision was based on the fact that
there is no clear indication that customers or others in the marketplace are requiring certification.
Fluke is currently monitoring customer expectations and international trends in anticipation that
changing trends could lead to a decision to certify to the ISO 14001 Standard.

However, Fluke's environmental strategy includes efforts to prevent or overcome environmental
barriers to international trade.  This strategy is resulting in continuing efforts to achieve
conformity to ISO 14001. The ISO 14001 manual is in draft form. All documentation for
environmental operations, hazardous waste and wastewater treatment system documents, and
training records, are included in the ISO 9001 program.  In addition, linkages between ISO 14001
and existing ISO 9001 documentation are being identified. Fluke's two internal ISO 9001
auditors have attended a one-day ISO 14001 training session, and the current plan is to merge the
ISO 9001 and  14001 programs as much as possible.  If and when the decision is made to pursue
ISO 14001 certification, the auditors will receive training in EMS auditing.

Other educational activities are also ongoing, such as participation in local area ISO 14001 work
groups, and subscription to various information sources.  In addition, Fluke is actively involved in
a local EMS leadership project, in which representatives  from business, environmental agencies,
and public interest groups are looking into the potential benefits of ISO 14001 as  an alternative to
traditional "command and control" systems. Finally, Fluke has obtained a proposal for
registration services, and five year maintenance of registration.  These costs are included in the
EMS budget for the next two years, in anticipation of the need to become registered on relatively
short notice.

In October 1996, Fluke conducted a third-party baseline audit of its EMS against the ISO 14001
Standard.  This audit, which involved extensive documentation inspection and personnel
interviews, provided further clarification of documentation and other requirements which must be
addressed in order to demonstrate compliance with ISO  14001.

Fluke's expectation is that certification will become  a business necessity in the relatively  near
future. Based  on emerging trends, it is expected that both the U.S. and Netherlands
manufacturing operations will probably receive third-party certification to ISO 14001 by the end
of 1998.

Challenges

Fluke's ISO 9001 registration experience indicated that the company had "over-documented" its
quality management system in anticipation of what was expected by ISO 9001 auditors.  Since the
original ISO 9001 certification in 1993, Fluke has been systematically simplifying its quality
program documentation, while maintaining conformity with the Standard. In order to preclude
such "over documentation" for ISO 14001, Fluke will conduct a comprehensive third-party pre-

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registration audit prior to actual application for registration.

Another challenge is to take full advantage of existing ISO 9001 processes.  Since there appears
to be a considerable overlap between ISO 9001 and ISO 14001, Fluke sees a definite advantage in
combining these programs, including the internal audits. This will be a major new activity for the
ISO 9001 auditors, who will need considerable EMS training.
Benefits

Even without the benefit of a formally documented program, Fluke has continued to set goals and
make progress on various pollution prevention and resource conservation projects.  These
successes have been possible because Fluke has integrated its environmental policy into the
corporate culture and into many of its basic business practices, and because the link between
environmental issues and quality is well established.  The benefits of sound environmental
management are recognized and supported by top management. In addition to management
support, employee team contributions are recognized through quality program rewards and other
recognition programs.

Environmental managers at Fluke also recognize that having an ISO 14001 EMS can potentially
cut costs, reduce wastes, and involve employees in every aspect of environmental management.
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                            Globe Metallurgical Inc.

Background

Globe Metallurgical Inc. (Globe) is a privately-owned producer of silicon metal and specialty
ferrosilicon products. Globe's products are produced in ten submerged arc furnaces at four
manufacturing facilities (located in Beverly, Ohio; Selma, Alabama; Springfield, Oregon, and
Niagara Falls, New York). Globe is the oldest ferroalloy company in the United States and the
largest US producer of silicon metal and specialty ferroalloys. Silicon metal is marketed to the
primary aluminum industry and the chemical industry, and the specially ferroalloys are used in the
foundry industry. Globe has been recognized by its customers as a quality leader, winning the
first "Malcolm Baldridge Quality Award" for small business in 1988, the "Shigeo Shingo Prize for
Manufacturing Excellence" in 1989, General Motor's "Targets for Excellence" award, and Ford's
"Total Quality Excellence" award.


Drivers for Implementing an EMS

Globe decided to participate in the EMS Demonstration Project after receiving a survey from a
key customer requesting information on our environmental management program.  This same
customer also requested that Globe participate in its 1995 Supply Chain Environmental Forum.
Globe also has a customer that has included environmental commitment in its current Supplier
Excellence Agreement.  In addition, Globe sells about 25%  of its specialty ferroalloys overseas
and, as is the case with  ISO 9000, there are indications that ISO 14001 registration could become
a prerequisite for doing business overseas (especially in Europe). Globe believed that the EMS
Demonstration Project would help the company establish an EMS that satisfies its own
requirement for  continuous improvement and will meet any future requirements of its customers
or regulatory agencies.

An  important consideration in Globe's decision to develop an EMS is the growth of the company,
coupled with the increasingly complex environmental regulations faced in four different states.
Without a well-designed EMS, Globe felt that a high probability existed that there would be an
inadvertent regulatory violation or failure to meet some other obligation established by law.


Self-Assessment

At the beginning of the  EMS Demonstration Project, Globe did not have a comprehensive EMS in
place. The company's primary focus was on ensuring compliance with environmental regulations
at the federal, state and  local levels.  Its EMS consisted of an environmental policy and various
programs established at each of the manufacturing plants. That is, each of the four plants had
implemented its own  environmental policies and procedures based on state and local regulatory
requirements, rather than on any specific corporate directives.

The first self-assessment (performed by site and corporate environmental managers) was based on
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the environmental policies and procedures in place at the four plants.  This self-assessment was
designed to:

•  identify what was currently in place at each site; and

   assess what might be transferable from one location to the others.

The scope of the assessment included examination of records, interviews with individuals at each
plant, and a comparison of the resulting data against the requirements of NSF 110. The
assessment indicated that the company had partially implemented some of the elements of NSF
110, but that very few elements had been implemented completely.

The second self-assessment (performed approximately one year later) was conducted by the
individuals responsible for day-to-day environmental duties at each of the four plants with the
assistance of Globe's environmental consultant.  The second self-assessment was based on the
ISO 14001  Standard, rather than NSF 110.  The basis for scoring in the second self-assessment
was as follows:

•      If all four plants had completed an element, that element was scored as complete for the
       corporation.

       If only some of the plants had successfully completed a requirement, it was scored as
       partially complete for the corporation.

The results of the second self-assessment showed that none of the ISO 14001 elements were
considered successfully implemented, because not all of the sub-elements were rated as "evaluated
and sustained". At the time of this writing (October 1996), we believe that the company is
nearing completion on certain ISO 14001 elements, but the process is so dynamic that it is often
difficult to declare that something is really completed.
Implementation

To continue to make progress, Globe is embarking on a four-year program to develop an EMS
that will be fully integrated with its existing quality and safely management system.  New
procedures and programs will be developed to fully implement Globe's environmental policy by
consulting with individuals on the shop floor who actually perform the work. The integrated
system will reflect all of the elements of ISO 14001 in case the need for registration develops;
however, Globe has no plans to seek ISO 14001 registration at the present time. It is believed
that lessons learned during the ISO 9002 certification process will facilitate the establishment of
an effective EMS. Some of the key lessons are that employee training and clear internal
communications are critical elements in the development of a successful system. Globe
anticipates that its greatest effort and actual expense will be in the area of personnel training.

All of Globe's plants have received ISO 9002 certification. Where appropriate, the ISO 14001
requirements will be incorporated into the existing management system documentation.  Some

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elements (such as training, documentation and management review)  present obvious
opportunities for ISO 9002/14001 integration. Quality, environmental, and safety issues will
continue to be integrated into work instructions and training so that employees will not need to
learn and maintain multiple sets of procedures.  It is also possible that Globe may combine its
environmental audits with quality and safety audits.

Quality, safety, and environment issues have been and will continue to be discussed at Globe's
monthly Quality, Efficiency and Cost (QEC) committee meetings.  The QEC committee is
composed of managers from all four plants and from corporate headquarters.  These meetings
provide a venue for discussing issues and events,  as well as for developing strategies and plans.
Challenges

For Globe, the greatest challenge in the development and implementation of an EMS has been the
competition for resources and the "human engineering" that must be done to create a sense of
environmental concern within an organization dedicated to production and quality at the lowest
possible cost to its customers. Glove believes that the integration of management systems (as
discussed above) will help to create and sustain a culture in which environmental management is
an integral part of the job.
Benefits

Once the EMS is in place and effectively implemented, Globe should be able to demonstrate
continuous improvement in the environmental area. As with its quality management system, the
company expects some economic benefits as well. For example, its is expected that continuous
environmental improvement will reduce air emissions. The 1990 Amendments to the Clean Air
Act require monitoring of emission limits and payment of fees based on tons of pollutants emitted.
By reducing  air emissions, the company should save money by reducing waste generation and by
limiting air pollution fees.

In addition, with the interest shown in environmental matters by some of its customers, Globe's
expects that a comprehensive EMS could be a valuable business tool, particularly by retaining
customers and market share.
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                                  Hach Company
Background
The Hach Company (Hach) is an international manufacturer and distributor of instruments and
reagents for colorimetric testing, with annual sales of over $100 million. Hach manufactures
spectrophotometers, colorimeters, turbidimeters, and portable testing equipment for the water and
wastewater markets. The company manufactures instruments at its headquarters in Loveland,
Colorado, and has a chemical manufacturing and distribution plant in Ames, Iowa. Hach is
registered to ISO 9001 and is a member of the Chemical Manufacturers Association's (CMA)
Responsible Care® program.
Drivers for Implementing an EMS

Through the demonstration project, Hach decided to pilot EMS implementation at its Ames
facility.  The Ames facility has approximately 300 employees and faces environmental
management challenges due to its many chemical production processes. The Ames facility is the
only Hach facility that is currently participating in CMA's Responsible Care® program. Hach
decided to implement an EMS at its Ames facility for several reasons.  The company felt that a
sound EMS would: 1) provide assurance to the officers, board of directors, and company
stockholders that the company will continue to meet regulatory compliance requirements and is
prepared to handle other environmental issues; 2) provide a framework to maintain support and
resources from senior management to meet environmental objectives and targets; 3) help create
market opportunities for the organization; 4) be a mechanism to gauge environmental
performance; and 5) help the company to identify its responsibilities beyond compliance in order
to meet the needs of stockholders, employees, neighbors,  customers, vendors, and suppliers.
Hach also believes that the EMS provides a mechanism to keep its staff lean and responsive to
the constantly changing needs of the organization.
Self-Assessment

In order to examine the Ames facility's environmental strengths and weaknesses, the facility's
Quality Director performed an initial self-assessment of the EMS. The Quality Director reviewed
the NSF 110 EMS Standard and interviewed the Environmental Safety and Health (ESH) staff at
length. The Quality Director determined that the facility's EMS conformed with approximately
30% of the requirements of NSF 110, which was consistent with the expectations of the ESH
staff at that early stage of EMS implementation.  The assessment process provided the ESH staff
with a benchmark from which they could measure progress as they continued to improve the
facility's EMS.

After the initial self-assessment performed by the Quality Director, the ESH staff performed an
informal interim audit. The Quality Director then performed a second formal audit of the EMS
(using ISO 14001) after one year of implementation. The ESH staff was pleased with the audit
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process because the quality management system (QMS) staff had extensive experience in auditing
management systems.  The Quality Department acted as an independent party and performed a
very thorough audit. The Quality Department has stressed that the ESH staff must document
how they do things.  There were times when an EMS element was in place but needed to be
documented.
Implementation

Hach Company had previously developed an environmental policy, but developed additional
policies to fulfill CMA's Responsible Care® program and the policy requirements of ISO 14001.
Hach Company has issued its Corporate Environmental and Safety Policies to address continuous
improvement, periodic assessments, product stewardship, regulatory compliance, operations,
facilities, and employee health and safety. In addition, the President of Hach Company has issued
The President's Commitment, which expresses top management's commitment to environmental
stewardship and the safety of employees and customers.

In order to determine the Ames facility's environmental aspects, the ESH Department reviewed
the table of contents of its new ESH manual. The table of contents helped them to develop an
informal environmental effects register and a safety register.  The group then evaluated how
environmental regulations affect the company by examining federal requirements (e.g., Clean
Water Act, Safe Drinking Water Act, Clean Air Act, etc.), as well as state and local
environmental regulations. The ESH Department then explored the facility's environmental
aspects and resulting impacts which are beyond those addressed by environmental regulations. A
three- to four-page document was developed that focuses primarily on the facility's operations
and processes and puts less emphasis on aspects such as energy use.

Development of the environmental effects register facilitated the setting of objectives and targets.
While the EMS is still in development, the objectives are focused on maintaining compliance and
tackling issues that had been previously unresolved. One particularly important environmental
issue for the company is determining the impact of its chemical products on international
customers, since 35% of the company's products are sold internationally. These product-related
impacts will be given more consideration when setting objectives and targets in the future.

The ESH staff maintains access to copies of federal and state regulations, manuals, journals, on-
line resources, and software packages that help them to keep abreast of all pertinent
environmental regulations and statutory requirements.  While the company has always been very
good at maintaining regulatory compliance, the new EMS procedures for legal and other
requirements have helped to make compliance activities more focused and efficient  Procedures
designed to ensure compliance have been properly documented and will protect the company in
the event of employee turnover. The ESH staff at the Ames facility is developing extensive
written procedures to address compliance activities that are sometimes above and beyond those
required by ISO 14001.

Hach believes that the structure and responsibility requirements of an EMS are simpler to achieve
in a medium-sized organization than in a large one. The staff at the Ames facility has been given

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the autonomy to implement an EMS without extensive corporate supervision.  This has simplified
the process because the lines of communication are shorter and the EMS can be focused on the
operations of a single facility.

The Ames facility has an excellent training program due in part to the commitment of resources in
this area. The facility has a full-time ESH training coordinator. Implementing the EMS has
supported the facility's ESH training efforts by helping to define training objectives.  The ESH
staff is also developing procedures for all ESH training. The documented procedures will
describe the goals and objectives of training and establish curricula for applicable programs.

Internal communication has improved due to EMS implementation. The ESH staff is working
with members of the  site's operations, design, and purchasing  departments to set reasonable
environmental objectives and targets that complement other business goals.  Environmental issues
are becoming an integral part of the business.

While the ESH  staff started to develop an ESH manual in September 1995, the Ames facility is
still in the process of completing its EMS documentation. The ESH manual is somewhat unique
in that it must be able to accommodate the extreme diversity of the site's operations — for
example, the manual  must address over 6,500 chemicals used or produced at the facility.

The site's ESH  staff includes two college students that are working at the facility to develop some
of the documentation (such as EMS procedures) required for a successful EMS.  The students
have been very  helpful — they ask a lot of questions and can explain the procedures clearly and
without jargon.  The site has also has run some mock-drills or table-top exercises to assess the
effectiveness of its procedures.

Because Hach is registered to ISO 9001, the ESH staff has learned valuable lessons from the
QMS staff, including lessons about document control practices. As the ESH staff began
implementing the EMS, they discovered that the site was not as good at controlling environmental
documents  as they had believed. A sound document control system is crucial to a successful
EMS — without it, sooner or later someone will be working from an old version of a procedure.
The document control system is managed electronically by a senior ESH staff member.

As mentioned previously, the ESH staff at the Ames facility is  developing extensive written
procedures to address compliance activities, including those that pertain to monitoring and
measurement. These procedures will be included in the ESH manual.  The ESH staff has built
upon the facility's QMS corrective and preventive action procedures to facilitate development and
implementation of the EMS.

The management review element of the ISO 14001 Standard has not been implemented at the
Ames facility.  The facility does not intend to fulfill the requirements of the management review
element unless the site decides to pursue EMS registration. Hach does not believe that the
management review process adds value to the EMS unless registration is being sought. Hach
believes that all other elements of an EMS can be implemented without management review.

As discussed earlier, the initial self-assessment showed that the Ames facility's EMS conformed to

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approximately 30% of the NSF 110 EMS Standard. After six months of dedicated
implementation efforts, the site had successfully implemented approximately 58% of the Standard,
and after one year of implementation it has successfully implemented approximately 71% of the
Standard.  During this time, the ESH staffs primary goal was to continue to ensure regulatory
compliance. EMS implementation efforts were carried out whenever time permitted.
Challenges

One of the challenges that the ESH staff at the Ames facility experienced during EMS
implementation was driving the EMS down through the organization and up through
management. The ESH function is often viewed as a separate entity in many organizations and
not as an integral part of the business.  This perception was initially a barrier to EMS
implementatioa ESH is now viewed as a more integral part of operations.

Costs associated with EMS implementation can be difficult to quantify. To date, the most
significant costs have been related to personnel expenditures and office supplies.  The ESH staff
at the Ames facility has estimated that if the facility had to start from scratch, EMS
implementation over a two-year period would cost approximately $20,000 - $30,000 per year.
Hach estimates that a company must be willing to commit at least one person-year to
implementation of an EMS, but this will vary from company to company.  Some of the costs of
implementation can be hidden but must be accounted for — for example, the Ames facility spent
approximately $5,000 on supplies and printing costs for EMS implementation. Initially the costs
of EMS implementation may outweigh the benefits, but in the long run, an EMS can help prevent
an environmental problem and strengthen an organization's commitment to be a good corporate
citizen.

Currently, there are no plans to integrate the ISO 14001-based EMS and the ISO 9001 QMS at
the Ames facility.  The QMS staff has suggested that operating parallel systems is the best
approach for both ESH and Quality at this time.  The QMS was adapted from existing procedures
and possibly could be more efficient in some areas, while the EMS developers had the opportunity
to "start from scratch" and develop processes and procedures that may be more effective and
appropriate for ESH issues.  In addition, the QMS staff are hesitant about fully integrating an
"immature" EMS into the QMS as  this might jeopardize the company's ISO 9001 registration.  In
the event that Hach chooses to pursue EMS registration, the issue of system integration will be
revisited, because integration could result in synergy and cost-savings for both Quality and ESH.
Benefits

Hach believes that there are numerous potential benefits associated with implementation of an
EMS (e.g., assurances to stakeholders, a framework to maintain support and resources from
senior management, market opportunities, a mechanism to gauge environmental performance and
to identify responsibilities beyond compliance). During the EMS implementation process, the
Ames facility began to observe improvements in its environmental performance. For example,
waste disposal costs have dropped 70% in one year. The EMS was a contributing factor to the

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cost reduction along with the company's quality focus and continuous improvement efforts.

Since the EMS has not been completely implemented and the system is relatively new, the benefits
have been hard to quantify.  But the company believes that the benefits are there.  The EMS
development process helped to spearhead a major renovation program within the facility for safety
and environmental improvements.  Employees have started to ask questions and are following
procedures carefully. In addition, the ESH Department is gaining respect from other business
units. The ESH staff will maintain a focus on compliance and is working closely with plant
managers to minimize the impact of compliance requirements on production. However, the ESH
staff is now in the position to discuss why the company should go beyond compliance and what
the business reasons would be for doing so.
Final Thoughts

Hach has not determined if it will pursue EMS registration. The company will "wait and see" if
market forces (particularly demands from international customers) and potential regulatory
incentives provide sufficient benefits to offset the costs of registration. The company may not
implement the remaining 20 - 25% of the ISO 14001 requirements unless the company decides to
pursue EMS registration.  In the event that the company decides to pursue registration, it will be
relatively easy to put the remaining elements in place given sufficient notice, time and planning.

While questions remain about the value of EMS registration, Hach has come to some conclusions
about EMS implementation at its Ames facility.  Initially there were concerns about how the EMS
would fit with the company's culture, but Hach believes that the EMS has helped to bring about a
positive culture  change. The EMS approach is consistent with the company's audit policies and
procedures, because it fosters a systematic approach that lends itself to periodic evaluation.  In
addition, the process of evaluating the strengths and weaknesses of the facility's EMS has
identified opportunities for improvement.  Hach believes that it has benefited from assessing and
improving the EMS at its Ames facility.
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                                 K.J. Quinn & Co.

Background

K. J. Quinn & Co. (Quinn) is a privately owned specialty chemical company involved in the
research, development, and manufacture of high performance liquid resins, coatings and adhesives
worldwide. Quinn is comprised of three divisions: the Coatings and Adhesives (C&A) Division,
which manufactures solvent-based, water-based and 100% solid urethane products; the
QureTech® Division, which manufactures UV and E-beam curable products; and the Shoe Finish
Division, which manufactures shoe-related products.

Quinn is working on ISO 9001 certification for both its C&A and QureTech® Divisions and plans
to obtain certification in late 1996.  These two divisions are located in one facility and will be
certified together.  During the ISO 9001 certification process, the managers involved with quality,
safety, and environmental issues became aware of the developing ISO 14001 EMS Standard and
began investigating whether Quinn should also pursue EMS certification.


Drivers for Implementing an EMS

As a chemical manufacturer and formulator, Quinn has significant environmental obligations.
These include the need to comply with an ever expanding set of regulations; the need to develop
more environmentally-friendly products; and increasing demands from customers for assistance in
complying with their environmental, health and safety requirements.  Quinn concluded that
implementation of an EMS would improve and properly focus the company's efforts to meet its
environmental obligations. As with other businesses today, Quinn operates with a lean workforce
in all areas (including its environmental and safety department) and strives to be more efficient
with the limited resources currently available. The company views the establishment of an EMS
as a process that forces it to better organize its priorities and projects, to identify problems and
potential exposures, and to respond in a proactive manner. It goes without saying that preventing
an incident is much more efficient than simply responding to one.

It was concluded that Quinn would eventually require ISO 14001 certification in order to
compete internationally, just as companies now need ISO 9000 certification to compete in certain
markets. However, as Quinn was experiencing greater commercial pressures to obtain ISO 9001
certification, the company opted to develop and certify its quality management system first.  It
was determined that by implementing the EMS after ISO 9001 certification has been obtained,
Quinn could take advantage of lessons learned from the ISO 9001 experience.  For example, the
employees would be knowledgeable about management system concepts and certification
processes.
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Self-Assessment

Quinn became involved in the EMS Demonstration Project to learn more about the EMS
implementation process and to facilitate the establishment of an EMS for the QureTech® and
C&A Divisions.  As a first step, Quinn performed a self-assessment of its current environmental
and safety programs.  The company decided to incorporate safety into Quinn's EMS because of
the close relationship and numerous overlaps between safety and environmental concerns in the
specialty chemicals industry.  The Director of Safety and Environmental Affairs conducted the
preliminary self-assessment using the tool developed by NSF. The company's officers then
reviewed and commented on the results of the self-assessment.  The process was not as time-
consuming as anticipated — approximately 20 to 25 hours were needed to perform a
comprehensive review.

The assessment showed that Quinn should concentrate its efforts toward (1) developing more
formal environmental and safety policies and procedures and (2) improving communications on
environmental issues with its neighbors, customers, and other stakeholders. Efforts to obtain ISO
9001 certification were reflected positively in the EMS self-assessment, especially in the areas of
work policies and procedures, documentation, document control,  and training. In addition,
compliance with the OSHA Process Safety Management (PSM) regulation reflected positively in
our processes for evaluation of problems and management of change.  It was determined that
many procedures that were originally developed for compliance with the PSM standard could be
extended to cover environmental actions not currently addressed by these PSM procedures.
Implementation

With the self-assessment completed, the next obvious step was to implement the changes needed
to bring the program into line with the requirements of ISO 14001. Although formal EMS
implementation has been delayed until after ISO 9001 certification has been obtained, Quinn
continues to develop elements of its EMS on a case-by-case basis as opportunities arise. For
example, as procedures or practices are developed to meet ISO 9001 or various regulatory
requirements, Quinn considers how these procedures or practices might be modified to help us
meet ISO 14001 requirements at the same time.

The biggest hurdle in the implementation process continues to be devoting the time and resources
necessary to develop the missing components of the system, to improve upon the existing
components, and to maintain the system once it is in place. With the employees working at a
significant pace, this can be a challenging situation, especially in the final push toward ISO 9001
certification.
Final Thoughts

Quinn believes that there are some issues that need to be addressed with regard to ISO 14001
implementation.  In particular, there is the issue of registrar access to compliance audit reports

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and the potential impacts of this access on a company's ability to maintain these reports as
privileged documents. Since conformance with the ISO 14001 Standard would require companies
to periodically evaluate their compliance with applicable environmental laws and regulations,
many companies may be concerned about potential loss of audit privilege as a result of ISO 14001
registration.

Implementation and maintenance of the EMS will be a challenging task, but a necessary one
which should be very rewarding both in cost-savings as well as in protection of the employees and
the environment.
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                      Lockheed Martin Federal Systems
Background

The Lockheed Martin Federal Systems site in Manassas, Virginia has as its mission software
development, hardware integration, and special purpose semiconductor device manufacturing.
The customer base of the site includes the US Department of Defense, other federal agencies (to
include space applications), commercial companies, and foreign governments.

The Manassas site has a strong history of compliance in all environmental media. The compliance
posture has continued through two previous owners (IBM and Loral Corporation) and continues
with Lockheed Martin.
Drivers for Implementing an EMS

The site's compliance record reflects a culture of compliance among site personnel; it is this
culture, combined with the interest in continued success in its markets, that generated interest in
exploring ISO 14001. Similar foreign interest in ISO standards was the driver for the site to
pursue and obtain ISO 9001 certification in 1995.

The site plans to continue its market exploration outside the US. To be successful, this effort will
almost certainly require ISO 9001 and ultimately ISO 14001 certification. The site plans to seek
ISO 14001 certification as soon as feasible, especially because the ISO 14001 Standard was
officially published in September 1996.
Self-Assessment

To help plan for ISO 14001 certification, we compared the Standard's requirements against the
EMS that was already in place at the site.  We performed an analysis to identify the gaps between
what we had in place and what we needed to meet ISO 14001 requirements.  In general, we found
most of the elements were in place, although some enhancements were needed. Certain elements
of ISO 14001 were essentially complete, such as document control and records procedures.
These were the result of the site's effort in ISO 9001.  In fact, the close relationship between ISO
9001 and ISO 14001 became  evident during the gap analysis. The cost of obtaining ISO 14001
certification is expected to be  significantly below that of ISO 9001 because:

       existing environmental programs are strong; and

       many overlaps between ISO 9001  and ISO 14001 were identified (particularly in the area
       of documentation).
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Implementation

To satisfy the requirements of ISO 14001, the site environmental program needed to be enhanced
in several areas. Primarily, we needed to formalize a policy statement and document our goals
and objectives. In addition, the site needed to implement a formal environmental assessment
program and strengthen its existing audit program. As part of this effort, we have strengthened
our existing compliance audit program and developed an EMS audit program. The latter is
focused more on our posture relative to ISO 14001. Although the two programs have a different
focus, we feel both are important aspects of the site environmental program.  A schedule of
implementation activities is shown below.
Activity
Develop / enhance audit checklists
In-house auditor training for select site personnel
Develop environmental assessment process
Integrate ISO 14001 elements into ISO 9001 program
Formalize environmental policy statement
Formalize environmental objectives and targets
Third-party walk through
External auditor training for two members of the
environmental staff
Conduct EMS audits
Update management review
Third-party initial assessment
Third-party final assessment
Completion Date
August 1996
April 1996
May 1996
May 1996
September 1996
September 1996
September 1996
October 1996
November 1996
December 1996
December 1996
April 1997
Status
Complete
Complete
Complete
Complete
Complete
Complete
Complete
Complete
Ongoing
Planned
Planned
Planned
The Manassas site has chosen its current ISO 9000 registrar to conduct the ISO 14001
registration audit.
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Challenges

Perhaps the biggest challenge of the ISO 14001 implementation process was the need to develop
a business case to justify the required EMS improvements. Making this business case can be
particularly challenging at a site which has historically had a strong environmental program.  In
order to sell the need for change, we:

• worked with the site Total Quality Management group and ISO auditors to explore common
  system features (and possible benefits to the site of integrating these systems); and

• raised the awareness of site management regarding the potential benefits (both environmental
  and economic) of ISO 14001 certification.
Final Thoughts

We believe that ISO 14001 offers both an environmental and business opportunity for Lockheed
Martin Federal Systems at Manassas.  Through the efforts to formalize and enhance the existing
environmental program, we believe the company will experience greater efficiencies resulting
from:

•      proper and current procedures;
       adequate and accurate data collection and calibration systems;
•      well-defined processes to ensure compliance with new regulatory requirements;  and
       sufficient documentation to allow more efficient coverage when the primary staff person is
       not available.

In addition, we believe that ISO 14001 offers a vehicle for approaching regulators to  request a
reduction in the frequency of on-site audits and reviews.  We also believe organizations should
look carefully at combining their ISO 9001 and ISO 14001 efforts into a single cohesive program
to provide a transparent single program to the site.  This feature will also aid in the acceptance of
the total effort by site management.
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                     Madison Gas and Electric Company

Background

Madison Gas and Electric Company (MGE), founded in 1896, is a public utility located in
Madison, Wisconsin.  MGE generates, transmits and distributes electricity to 120,000 customers
in a 250 square mile area in Dane County, Wisconsin.  MGE also transports and distributes
natural gas to 103,000 customers throughout a 1,325 square mile area in seven counties.

In addition, MGE subsidiaries market non-regulated natural gas and other fuels to large
commercial and industrial customers and governmental institutions nationally.


Drivers for Implementing an EMS

Over the past 30 years, the utility industry has encountered many environmental issues and has
been heavily regulated. MGE initially adopted an EMS to ensure compliance with environmental
regulations.  Over time, the EMS has expanded to address new regulatory requirements, concern
of future environmental liability, cost management, competition, audit results, and new corporate
policies, goals and objectives.

MGE's key motivations for implementing an EMS based on ISO 14001 are ensuring regulatory
compliance, improving the company's competitive advantage, and continually improving
environmental performance over time.  MGE decided to participate in the EMS Demonstration
Project because it provided opportunities for:

       benchmarking its  EMS with those of other project participants; and
•      learning from the  EMS implementation successes and problems of other participants.


Self -Assessment

As a first step, MGE hired an environmental consulting firm to conduct an independent
assessment of its existing EMS.  The results of the independent assessment  were reviewed by
company management and compared with earlier informal self-assessments. The independent
assessment showed that MGE was strong in the areas of environmental policy, management
support, provision of resources,  among other areas. Some of the elements requiring improvement
included environmental aspects  identification, EMS documentation,  and document control.

MGE found the self-assessment process to be worthwhile.  We learned that much of our
environmental program paralleled the ISO 14001 Standard very well; however,  certain areas of
our program lacked the depth and detail required by ISO 14001.
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Implementation

Based on its self-assessment, MGE decided to incorporate the elements of the ISO 14001
Standard into its existing EMS.  This decision was based on a goal of full integration of
environmental concerns into the daily operations of the company. The company's Management
Environmental Task Force (MET) and Green Team Leaders (GTLs) were assigned the job of
integrating the elements of ISO  14001  into MGE's environmental program.

The MET, which is comprised of senior managers, establishes environmental policies, performs
strategic planning, and provides resources to the GTLs.  The GTLs are the implementing arm of
the MET and represent the company's operating and service departments, including union
representation.

The GTLs decided to focus first on two elements of ISO 14001: environmental aspects (Section
4.3.1 of the Standard), and monitoring and measurement (Section 4.5.1).  Working on the
environmental aspects element allowed us to review our operation again and to confirm and/or
modify the basis for our existing environmental program (i.e., the issues or aspects that the
program was designed to address).   Working on the monitoring and measurement element
provided a mechanism for communicating environmental performance to MGE departments and
management. We expect to complete work on these two elements by the end of 1996. Work on
the remaining ISO 14001 elements (as identified through the self-assessment) is scheduled for
completion by the end of 1997.

MGE has decided not to seek registration to the ISO 14001 Standard at this time. We believe
that registration would have limited value because the company does not currently participate in
the international marketplace. The effort, cost, and time required to develop and maintain the
written documentation required by ISO 14001 would not be offset by the benefits of registration.
However, as more companies become registered, the registration process should improve and
additional registration benefits should be identified. If ISO 14001 does become a standard for
doing business in the future, MGE will be well-positioned for registration.

Perhaps the greatest difficulty we faced in implementing ISO  14001 was in defining significant
environmental aspects. This element raises a number of critical issues such as determining which
stakeholder concerns are significant, how "significance" should be measured, how a company
ensures that all significant aspects have been identified, and how the process for identifying
significant aspects should be sustained over time.
Benefits

The EMS process resulted in better environmental awareness, which in turn improved the
communication between the company's operating departments and the Environmental Affairs
staff.  This has led to a proactive approach to environmental problem-solving whereby MGE can
anticipate problems and develop cost-effective and efficient programs to address them. Improved
awareness also resulted in the implementation of pollution prevention programs.
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Final Thoughts

Environmental management has become an integral part of doing business today. The ISO 14001
Standard provides an additional tool for managing a company's environmental concerns in a cost-
effective and efficient manner. A strong EMS can bring competitive advantage by:

       reducing costs through pollution prevention and waste minimization programs;
•      ensuring sustained environmental compliance;
       reducing future environmental liabilities;
•      reducing insurance costs; and
       addressing the needs of customers, shareholders, the community, and regulatory agencies.

In the future, the ISO 14001 Standard may also lead to regulatory incentives, such as fast-track
permits, reduced inspections and fines, and the potential for further partnering of business,
stakeholders, and government in eliminating and controlling environmental impacts.
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                              Milan Screw Products
Background
Milan Screw Products is a small (32 employee) manufacturing firm located in southeastern
Michigan. The company manufactures precision fittings for the fluid power, automotive, and
refrigeration industries,  and is registered to ISO 9002. There are approximately 1,500 companies
in the United States in the screw-machine products industry. Most of these companies are family-
owned and family-managed, and typically have approximately 50 employees.
Drivers for Implementing an EMS

There are generally few hazardous materials used in the screw-machine industry, but there are
environmental issues associated with the containment of coolants and cutting oils, the need to find
substitutes for chlorinated solvents, and the disposal of waste oils. The most persistent
environmental challenge is the containment of cutting oil within production machines. Many
screw-machine shops have production equipment that was manufactured in the 1950s, which may
have leaky gearbox covers and inadequate oil splash guards.  Failure to adequately contain cutting
oils also creates cleaning and disposal  issues, such as stained carpets, solid wastes (saturated oil
absorbents swept from the shop floor), and liquid wastes (solvents and soaps used in parts or
equipment cleaning). The cutting oils  also can have health and safety implications.

While it may be simple in the industry to accept the oily film that can coat everything from the
light fixtures to the floors as a "fact of life," Milan Screw Products decided to improve the
management of its environmental issues. Top management recognized that a clear environmental
policy, objectives and targets, written procedures, training, and corrective action (elements similar
to its quality management system (QMS)), would help the company to proactively manage its
environmental practices.

Implementation of an EMS was motivated by the company's desire to improve its environmental
performance.  While progress had been made in the past, the organization was lacking a structure
for its environmental management program and had no means to measure progress.  In light of the
company's QMS experience, the EMS approach appeared to be  the best way to achieve its goals.
Self-Assessment

In March 1995, Milan Screw Products joined the EMS Demonstration Project. One of the first
steps in the project was to conduct a self-assessment. Milan Screw Products used NSF's self-
assessment tool, which enables an organization to determine how its EMS measures up against
ISO 14001. The company's score was very low because it did not have a formal EMS in place.
However, the low score did not discourage Milan Screw Products; instead, the company set a
goal to fully implement an EMS by June 1996.
Implementation
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One of the first steps in implementing the EMS was the establishment of a cross-functional
environmental task group (ETG), which consists of five representatives from production, support,
and management.  The ETG is responsible for assuring continued regulatory compliance
(including the submission of all permit applications and reports to federal, state, and county
environmental agencies) and improving the company's environmental performance. Milan Screw
Products found that participation of shop-floor employees is essential to the successful
implementation of its EMS because participation encourages employee ownership of the process.
Participation in the ETG has heightened environmental awareness among its members and
enhanced their understanding of the company's environmental responsibilities.  In addition,
environmental compliance activities are now being managed effectively by the ETG and require
limited top management oversight.

In order to determine the company's environmental aspects, ETG members first used
brainstorming techniques. They listed all of the company's inputs (e.g., energy, water), outputs
(e.g., oil mist, noise), and conversions (e.g., steel bars to chips, cutting oils to mist). The ETG
also examined the company's purchases, processes, and waste streams.  Stakeholders were
identified, and some stakeholders were interviewed so that the company could gain a better
understanding of their environmental concerns. These stakeholder concerns were added to the list
of environmental aspects. Once the environmental aspects were identified, the ETG then rated
the probability of an environmental impact occurring and the severity of the impact if it were to
occur.  The environmental aspects and impacts were then grouped into general categories, such as
oil-related problems.

Based on the assessment of environmental aspects, it became clear that the company's primary
environmental objective should be oil recovery. During the same time period, Milan Screw
Products had been contemplating the need for a new manufacturing facility.  The identification of
the company's environmental aspects and impacts provided additional impetus for the
development of a new facility. The identified environmental aspects and impacts and other
elements of the company's EMS have played a significant role in determining how the new facility
will be designed and built.  The company will continue to perform oil recovery practices at the
existing shop (in accordance with its environmental objective), but will not set numerical targets
until the new facility has been completed.

Milan Screw Products has found that the structure  and responsibility requirements of ISO 14001
are easier to manage in a small company. Milan Screw Products has formed six teams for quality
and productivity purposes.  These teams have been given decision-making authority and have
been effective contributors to the overall management of the shop. Over time, the teams also will
support the company's environmental management efforts.  The ETG will continue to spearhead
the EMS program since the company owner,  plant manager, quality manager, safety manager,
plant supervisor/environmental coordinator, and a representative from production staff are
actively involved.  The key to success in a small company appears to be the team approach, since
small businesses seldom have the luxury of dedicating a person to manage environmental affairs
on a full-time basis. The team approach also has fostered effective internal communications.
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Finding the time to train employees can be a challenging aspect of running a small business.  To
meet this challenge, Milan Screw Products conducts training sessions one half hour before or after
the employees' normal shift. The company also has been quite successful at holding "brown bag"
sessions, where employees bring their lunches, participate in a training presentation, and remain
"on-the-clock" for the lunch/training period.  The company also has videotaped training sessions
to facilitate the training of new hires.  The ETG has supported the training effort by gathering and
compiling training materials.

Milan Screw Products has gone beyond the requirements of ISO 14001 by soliciting the views of
external interested parties.  The company has found that an effective external communication
program builds trust.  The company has been straightforward with the community about potential
oil problems and the community has been very supportive of the company's environmental efforts
and its plans for the new facility. In addition, communicating about environmental management
issues with its customers has enhanced their appreciation of Milan Screw Products as an
environmentally responsible company and a leader in the industry.

Since Milan Screw Products has a ISO 9002-registered QMS, the company has a sound document
control process in place.  The QMS document control procedures will be adapted where
applicable, and the corrective and preventive action procedures will be used in the EMS. The
company intends to utilize some of the lessons it has learned through its QMS about data
collection and monitoring and measurement and apply these lessons to the EMS.

Milan Screw Products has gained experience in management system auditing through
implementation of its QMS. Top management has performed QMS audits with the help of an
auditor training guide prepared by a QMS consultant. The company has conducted in-house
auditor training with the help of the guide and has used the auditor training guide (where
applicable) in conducting  its EMS audits. Milan Screw Products plans to continue to integrate its
ISO 9002 QMS with its ISO 14001 EMS, including development of a single manual that will
incorporate both quality and environmental management system elements.
Challenges

To date, the biggest challenge that Milan Screw Products has encountered has been allocating the
human resources to the EMS project in the face of high production demands.  The company has
also had to overcome some old practices by explaining to employees the rationale behind the
changes and the company's desire to successfully implement an EMS.

While Milan Screw Products has not completely implemented its EMS, it has made significant
progress over the last eighteen months. Groundbreaking for the new facility (in June 1996) has
caused the company to shift some of its priorities to support the new construction.  The company
hopes to fully implement its EMS by April 1997.
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Benefits

Milan Screw Products believes that there are numerous potential benefits associated with an
effective EMS.  An EMS can improve employee retention, new hire selection, and working
conditions, as well as the perceptions of its suppliers, lenders, customers, neighbors, and
regulators.  The EMS also can ease management concerns that an environmental problem could
arise from simple ignorance or lack of training.

It may be difficult to perform a cost/benefit analysis of EMS implementation because some of the
potential benefits are intangible and cannot be assigned a monetary value. It also is impossible to
tally citations that are not written, fines that are not levied, and lawsuits that are not filed.

Milan Screw Products' proactive environmental program has improved its stature and fostered
better communication with regulatory agencies. The company will also benefit from being one of
the first in its industry to successfully implement an EMS — this may promote the perception
among customers that the company is more innovative, more responsible, and perhaps more
desirable than their competitors. The company has found that although many of the benefits of an
EMS cannot be anticipated beforehand, they will be discovered as pleasant surprises after
implementation.
Final Thoughts

Milan Screw Products has not determined if the company will pursue EMS registration — that
decision will depend on factors such as costs and customer demand. The company intends to fully
implement its EMS and then evaluate the need for registration next year. Obtaining EMS
registration would be a source of pride and it might improve customer perception of the company,
but the company has not determined whether the costs associated with registration can be
justified.

Top management believes that organizations that choose to implement an EMS should not get
discouraged if EMS implementation efforts need to be set aside occasionally. You can start, stop,
and resume your efforts as needed — your aspects won't change unless you change your
processes or products — and any progress that you have made will still be there.

Milan Screw Products encourages other small companies to implement an EMS. An EMS can
help a small or medium-sized organization to prevent environmental problems from occurring
(rather than mitigating their resulting impacts), which may keep a small company in business.  An
EMS  enables an organization to look at its business from another perspective. Many
organizations have considered quality, safely, and other functions as integral parts of their
business, and they should look at environmental management in the same light. Looking at all of
the critical business functions together provides great opportunities for improving the
organization as  a whole.
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                               NEO Industries Ltd.
Background
NEO Industries (NEO) is an international service company specializing in the industrial hard
chrome plating of steel and aluminum mill work rolls. The company, which is headquartered in
Portage, Indiana, consists of small service facilities in North America and Europe that are
strategically located in close proximity to these mills. NEO's core business is the application of a
thin layer of hard chrome to the rollers in the mills.  This chrome layer increases resistance to
wear and improves the quality of the rollers' surface characteristics.
Drivers for Implementing an EMS

NEO's business dictates the need for an EMS.  Due to the nature of the processes and materials
employed, NEO has been proactive in the environmental design and operation of its facilities. An
environmental consulting company supported NEO in planning future environmental initiatives by
performing environmental audits of all of the company's facilities.

NEO decided to participate in the EMS Demonstration Project based on a number of
environmental concerns, including: (1) air emissions; (2) handling, disposal and proper
containment of hazardous wastes; (3) employee health and safety; and (4) compliance with local
and federal regulations. NEO also believes that implementation of an effective EMS will promote
market leadership, enhance stakeholder confidence, and help to ensure the public that the
company is effectively managing its environmental obligations.
Self-Assessment

NEO initially selected its Portage, Indiana facility as the pilot location for developing and
implementing an EMS.  An EMS self-assessment was conducted at the Portage facility using the
NSF self-assessment tool.  Considerable effort was made to ensure that the internal assessors
presented a candid picture of the status of the EMS.

The self-assessment confirmed that NEO had sound environmental practices, the most modern,
efficient equipment available, and excellent environmental design and facility construction.
However, the self-assessment also showed that formal programs and documentation to manage
environmental issues were lacking.  The company was proactive in the areas that it knew about,
but did not have formal procedures and training to ensure that the environmental implications of
new issues or conditions were  adequately identified and addressed in all cases.
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Implementation

As the project moved forward, NEO realized that the plan to implement an EMS at one pilot site
and then roll the EMS out to other facilities was unrealistic. Given the size of the company, it
was not feasible to dedicate the skilled resources necessary to adequately implement an EMS one
site at a time. As a result, NEO shifted away from tackling the EMS as a pilot project at one
plant to organizing a team to pursue EMS for all plants simultaneously. In this manner, NEO
could use skills throughout the organization to support development of the EMS.

During the course of the project, NEO wrote an environmental policy based on NSF 110 and ISO
14001.  The NEO policy includes commitments to the principles of compliance,  prevention,
communication and continuous improvement. The management team also chose to incorporate
health and safety management into the policy.  The NEO Health, Safety and Environmental Policy
has been fully implemented at all of its facilities in North America.

Over time, it became evident that establishing and maintaining a formal EMS would be a greater
challenge than NEO had originally envisioned. NEO held several discussions (both internally and
as part of the EMS Demonstration Project) about the benefits of initiating an EMS once an ISO
9002 project was completed.  This approach has the advantage that the systematic documentation
and procedures needed for an EMS are similar to those needed for the ISO 9002 quality system.

Although NEO has an excellent reputation for quality and service, it was just embarking on
certification to ISO 9002.  NEO shifted its priority and immediately focused on certification to
ISO 9002. Then NEO utilized this methodology to establish and document an effective EMS.  It
feels that experiencing the rigors of ISO 9002 certification will facilitate the development and
implementation of an EMS.  The two systems will follow a consistent format, and much of the
required training will be used to satisfy both standards.

Through the EMS Demonstration Project, NEO recognized some of the difficulties in developing
an EMS. Without the advantage of an existing ISO 9000 system, it lacked some of the
procedures, documentation and know-how that is advantageous in developing an EMS. At the
same time, compliance with new air quality  standards and NEO's ongoing need  to upgrade certain
processes diverted resources away from EMS development. NEO did not progress as far as
hoped due to the numerous demands of running a business. Hence, NEO can claim only partial
EMS implementation at the close of the project.
Benefits

NEO has already experienced some of the benefits of EMS implementation and expects to see
other benefits as system development moves forward.  First, EMS development has heightened
employee awareness of environmental issues. NEO is more focused on areas that can impact the
environment and has taken steps to eliminate certain processes that must be controlled due to
their environmental impacts. EMS development has also helped NEO to utilize its resources
(both in-house and outside) more effectively.

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NEO anticipates that implementing an EMS will result in more effective approaches for managing
compliance, especially through documentation of existing and new procedures and processes.
Environmental training will also be formalized and tracked.

Other anticipated benefits include improved employees' attitudes, better financing capability, and
maintained stakeholder confidence.  NEO believes that continued attention to environmental
matters has helped (and will continue to help) to retain long-term customers.
Final Thoughts

The EMS Demonstration Project was an excellent opportunity to learn about the emerging ISO
14001 Standard. The blend of large and small companies, represented by individuals from both
environmental and operational areas, provided participants with broad exposure to the challenges
in implementing an EMS.  The environmental consultants who volunteered to participate in the
project were extremely helpful to all participants. The cooperative approach of the EPA and local
officials bolstered the development of the project.

Participation in the EMS Demonstration Project has been of great value to the NEO organization.
The company is more focused on environmental management due to the support of NSF
International, the EPA and the input of other participating companies and sponsors. It has helped
NEO  to establish priorities and set a goal for implementing an effective EMS in 1997.
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                              NIBCO Incorporated

Background

NIBCO Incorporated (NIBCO) is a worldwide manufacturer of fluid handling (plumbing)
products for the residential, commercial and industrial markets.  Founded in 1904, NIBCO is a
family-owned Fortune 1000 and Forbes 500 company.  NIBCO has a total of 13 manufacturing
facilities, 11 of which are ISO 9002 certified.  NIBCO employs approximately 3,200 associates
worldwide. NIBCO is committed to continued excellence, leadership, and stewardship in
protecting the environment and conserving natural resources. Environmental protection,
including compliance with applicable laws and regulations, is a primary management responsibility
and the responsibility of every NIBCO associate.


Drivers for Implementing an EMS

In light of constantly and rapidly changing public expectations, community concerns, customer
expectations, and federal, state and local legislative and regulatory activities, successful companies
can no longer merely respond to these changes — they must proactively identify and manage their
environmental obligations.  NIBCO realized that it had to learn how to anticipate these changing
expectations and adopt new ways of providing for continuous improvement in its efforts to
manage environmental compliance and environmental performance. The company views an EMS
as a perfect tool for presenting and supporting its environmental philosophy. The fundamental
driving force behind developing and implementing an EMS at NIBCO was the desire and need to
formally define and put in place the structure, practices, procedures, processes, and resources
necessary to ensure regulatory compliance and continuous improvement in environmental
performance.


Implementation

NIBCO's EMS is focused around two distinct yet intimately connected concepts: Total Quality
Environmental Management and Waste Minimization and Pollution Prevention (WM/PP). In
designing our EMS, the key objective was to expand upon the concepts, tools, and experiences of
our ISO 9002 Quality Management System (QMS), and to apply them to environmental
management, including environmental compliance. This approach  allowed NIBCO to integrate the
control, monitoring,  and other management aspects of the QMS with the cost savings and other
benefits of WM/PP.  Having a certified ISO 9002 QMS was an advantage — our associates
understood what EMS development would mean in terms of resources and time.

The process of developing an EMS involved an  in-depth evaluation of the existing ISO 9002
QMS and developing national and international  EMS standards (e.g., ISO 14001, NSF 110,
BS7750, and CSA Z750), as well as a review of the company's environmental policy and
environmental objectives. This evaluation resulted in the development of a NIBCO environmental
management standard that meets the requirements of ISO 14001 and fulfills NIBCO's
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environmental policy. This internal standard describes the minimum requirements for the
development and implementation of a formalized, systematic environmental management program
at each manufacturing facility.

The development, implementation, and auditing of the program is directed and supported
internally by the corporate environmental department. The brunt of the work, however, is
accomplished at the facility level by cross-functional environmental management teams. These
teams generally include the plant manager, the plant environmental professional, the plant quality
manager, and representatives from other business functions within the facility, such as production,
accounting, maintenance, and safety. The application of TQM concepts, combined with the use of
internal standards and the involvement of cross-functional teams, has been the catalyst for
NIBCO's success in its attempts to manage environmental activities.
Benefits

Because the company-wide Environmental Management Program emphasizes cross-functional
team building and the importance of problem solving, NIBCO has begun to realize some of the
benefits of an EMS. The most significant benefits have been: improvements in communication;
the increase in environmental awareness throughout the company; the level of employee
involvement and interest in environmental management efforts at the manufacturing facilities; the
realization of environmental responsibility and accountability; and some operational cost savings
resulting from initial WM/PP projects.  Other perceived benefits include: reduced environmental
risk and liability; positioning for marketplace advantage; improved compliance posture and
relations with regulators; the ability to benchmark and measure progress using consistent
methodologies; and strategic environmental planning and budgeting.
Challenges

The process of developing and implementing an EMS has not been without its challenges. Initial
barriers that had to be overcome in order to sell the concept of an EMS to senior management
and the manufacturing facilities included:

•      the fear of increased liability as a result of auditing;
       the cost of technology required to meet NIBCO's policy and objectives; and
•      the fear of compromising production.

We communicated to senior management that an effective EMS would help the company to
reduce liabilities and environmental risks, as well as help to achieve other business goals. To
increase ownership throughout the organization, NIBCO educated the workforce about the real
and potential impacts on the environment due to their everyday jobs.

NIBCO found that many sections of ISO 14001 were subject to interpretation, but that no single
element was too onerous to implement.  The Operational Control section was perhaps the most
challenging, but NIBCO believes that there is sufficient flexibility built into ISO 14001 for

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companies to tailor their operational control needs based on their actual or potential
environmental impacts.

The EMS implementation process has presented some significant challenges. Some of the
challenges that NIBCO has faced include: limited time and resources at the site level; obtaining
meaningful  cross-functional involvement; dwindling inertia; lack of data required to support
continual improvement; development of performance measurements (how and at what cost); lack
of definition of best management practices; and the degree to which the EMS and ISO 9002 QMS
can and should be integrated.  We had to dispel the notion that "environment is not my job" and
demonstrate that managing our environmental aspects effectively would actually help us to meet
other business goals, such as reduction in downtime.
Final Thoughts

Despite the drawbacks and hurdles of implementing an EMS, the system has provided NIBCO
with:

•      a mechanism to control and manage operational and waste management activities;
       an effective strategy for monitoring and measuring our compliance status and promoting
       continuous improvement in environmental performance; and,
•      a link between environmental management and the ISO 9000 QMS (as well as other
       business management initiatives).

In addition, by increasing the focus on documentation and document control, the EMS provides a
tool to demonstrate to regulatory agencies what the company is doing to ensure  compliance.

Combining the concepts of ISO 14001 and ISO 9000 has allowed NIBCO to move toward the
development of a single cohesive integrated management system designed to apply to all areas of
the business, and has given NIBCO another tool for meeting and/or exceeding our customers'
expectations.
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                      Pacific Gas and Electric Company

Background

Pacific Gas and Electric Company (PG&E) is a public utility supplying electric and natural gas
service throughout most of northern and central California. Our service territory covers 70,000
square miles with a population of about 13 million. In 1995, PG&E's utility assets were
approximately $26.9 billion and operating revenues were $9.6 billion. PG&E has about 22,000
employees and operates more than 1,500 facilities subject to environmental regulations.

PG&E's electricity production comes primarily from  seven natural gas-fueled power plants, two
nuclear units, 70 hydroelectric powerhouses, and a geothermal energy complex. PG&E also
purchases power from a wide array of resources, including hydroelectric, wind, solar, biomass,
and cogeneration.  In 1995, its natural gas supply came primarily from Canada (64%) and the
southwestern US (28%), with the remainder from California fields.


Drivers for Implementing an EMS

For many years, PG&E has had an EMS which is now in a fairly mature state.  Our participation
in the EMS Demonstration Project was driven primarily by a desire to benchmark our existing
EMS against the developing ISO 14001 Standard and against the systems employed by other
participants in the  project. Our goal was to use the EMS Demonstration Project to identify areas
for potential EMS  improvements.  PG&E's participation had the additional benefit of providing a
realistic assessment of what would be required to achieve ISO 14001 certification, should a
business need for certification develop.  While PG&E does not market its products or services in
international markets, many of our customers do.  Thus, ISO  14001 certification may provide a
competitive advantage in a California energy market that is rapidly approaching deregulation.


Self-Assessment

The electric and natural gas services we provide to our customers cannot be associated with
specific production facilities.  Even the routes of transmission can vary,  as loads within our
distribution system change. We determined, therefore, that our self-assessment should cover the
EMS for the entire company and include all aspects of production and distribution. The self-
assessment was conducted by senior managers in the  environmental and law departments.
Because many of the ISO 14001 requirements were already covered by  the existing EMS, the
principal focus of the self-assessment was on the effectiveness of EMS implementation
throughout the company.
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Implementation

Based on the self-assessment results, we created a prioritized action plan for desired EMS
improvements.  In developing the action plan, we recognized that some EMS improvements
would have existing environmental or business justifications, while others would not proceed
without a business decision to seek ISO 14001 certification.

PG&E has always enjoyed strong senior management support for its EMS, particularly as it
facilitates cost-effective compliance with environmental laws. Over the years, PG&E has
undertaken extensive education efforts with its employees to underscore the need for continual
improvement in environmental practices.  This education effort helped to dispel the perception
that, since some past practices were adequate in protecting the environment, there was no reason
to change  or improve these practices.
Challenges

We foresee two major challenges to achieving ISO 14001 certification. The first is that the
Standard's strong emphasis on documentation runs counter to an ingrained corporate bias to
minimize paperwork.  Given that current environmental regulations already mandate extensive
recordkeeping requirements, establishing new voluntary documentation requirements may be a
hard sell, particularly if existing practices have functioned adequately to protect the environment.
As regulatory agencies themselves are moving to reduce mandatory paperwork, why levy new
documentation and recordkeeping requirements through a voluntary EMS standard?

The second challenge will be common to most utilities. Under ISO 9000, certification has
pertained primarily to individual production facilities, not entire companies. Because we cannot
tell a customer the exact source of the electrons or gas molecules we provide, certification of
individual facilities to ISO 14001  is meaningless. However, if we must certify all (or even most)
of our 1,500 facilities, the costs and administrative burden of certification would be unacceptable.
PG&E will work with the appropriate accreditation organizations in an attempt to find an
acceptable certification process for the utility industry.
Benefits

Our EMS has helped the company to ensure compliance and to reduce costs.  Our audit function
feeds the continuous improvement cycle. We have seen cost reductions as a result of reduced
hazardous waste generation, improved management of hazardous waste recycling and disposal,
and rapid deployment of new, cost-effective compliance approaches. In addition, the EMS has
helped PG&E to reduce environmental impacts in other areas (including reductions in impacts on
fish and wildlife and reductions in air pollution).
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Final Thoughts

PG&E believes that its participation in the EMS Demonstration Project supported our corporate
policy to continuously improve our EMS.  Our participation also helped to position us for
eventual ISO 14001 certification, if such certification is deemed a valid business need.
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                                Pitney Bowes Inc.

Background

Pitney Bowes is a leading provider of mailing, messaging and document handling products and
services with 30,000 employees in over 100 countries around the world. Pitney Bowes has two
primary manufacturing facilities, one located in Stamford, Connecticut and the other in Harlow,
United Kingdom. The company's core business consists of mailing products and systems,
complemented by the additional product lines of facsimile systems, copier systems, financial
services and management services. Pitney Bowes Inc., headquartered in Stamford, Connecticut,
registered annual revenues in 1995 of over $3.5 billion, an increase of 9% over the previous year.


Drivers for Implementing an EMS

The impetus to implement an EMS and to attain certification to ISO 14001 originated in the
company's Corporate Safety and Environmental Affairs Department. EMS implementation was
viewed as a means to improve upon and integrate existing environmental programs. Certification
to ISO 14001 was viewed as a means of attaining competitive advantage and ensuring long-term
security in the marketplace. EMS implementation also provides a vehicle to demonstrate the
company's environmental commitment to customers, investors and other stakeholders.

The Harlow, UK manufacturing site was chosen to be the subject of the EMS Demonstration
Project. The Harlow site is a medium- to large-sized manufacturing plant with approximately 900
employees.   The site manufactures products for sale worldwide, but primarily in Europe and the
Far East. Primary manufacturing processes include metal finishing, machining, plastic injection
molding, product assembly, and product refurbishment. The site has a history of management
system implementation, having attained certification to both BS 5750 and ISO 9002 several years
earlier.  In fact, this pre-existing ISO culture was one reason that the site was chosen for the pilot.
Furthermore, predictions have been made (based on the company's ISO 9000 experience) that any
marketplace effects of ISO 14001 would likely be felt first in Europe.


Self-Assessment

The first step in the EMS implementation process was to perform a self-assessment using the NSF
self-assessment tool.  The assessment was performed at the Harlow site by a group of middle
managers. After each manager completed the self-assessment checklist individually, all of their
responses were pooled and the response most frequently cited was chosen. The results of this
self-assessment indicated that the site was at the beginning stages for most of the elements of ISO
14001 — most of the elements were rated as either "no action taken" or "action initiated." The
self-assessment team did not rate the site as  "complete" or "evaluated and sustained" for any of
the elements of ISO 14001. This self-assessment provided a good  starting point from which the
Harlow site could plan its implementation activities. It also required all of the managers involved
in the self-assessment process to think about how each element of ISO  14001 related to their
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organization.
Implementation

In April 1996, after five months of implementation activity, the self-assessment process was
repeated. This time the results showed encouraging progress. Several ISO 14001 elements had by
now earned a "complete" ranking, although none had yet become "evaluated and sustained."
When the second self-assessment was conducted, only one element remained in the "no action"
category. Clearly, the site had made significant progress toward full EMS implementation in only
a few months.

At the time of this writing (August 1996), the Harlow site is preparing for the ISO 14001
registrar's pre-assessment visit, scheduled for September.  Most elements of the Standard have
been fully implemented.  The site has  developed a detailed register of its environmental aspects, a
register of applicable laws and regulations, and an EMS Manual consisting of several procedures,
including those for EMS auditing, management review and emergency response.  A team of
individuals on-site has been trained to perform internal audits and the first of these audits has been
scheduled. A process for ranking the significance of each environmental aspect has been
established and applied.  In addition, environmental objectives and targets have been set, based on
the outcome of the process for ranking significance aspects and on the company's environmental
policy. Elements of the ISO 14001 Standard which remain to be fully  implemented include
employee awareness training and external communication plans.

When the pilot was initiated, Pitney Bowes decided to keep the ISO 14001 initiative separate
from the site's existing ISO 9000 system. Since that time, however, some small-scale integration
of these systems has occurred.  The EMS Manual is formatted in the same manner as the ISO
9000 manual, allowing for easier integration in the future should the company choose to do so.  In
addition, approximately one-half of the individuals trained to perform internal EMS audits are also
responsible for internal ISO 9000 audits.
Challenges

Challenges to implementation have been surprisingly limited. Senior management has been very
supportive of the pilot project and has allocated sufficient resources to ensure its success.  Despite
some issues with individual staffing constraints, most members of the EMS team at the site have
been productive contributors.

In retrospect, the biggest challenge to implementation has been interpretation of the Standard
itself. In particular the most difficult section of the Standard to interpret was section 4.3.1
("Environmental aspects").  The choice of wording and lack of practical guidance made this
section difficult both to understand and to apply. In fact, a large portion of the person-hours
consumed to date on the project have been focused in this area. Even though the register of
environmental aspects has been completed for the Harlow site, modifications to this register
continue to be made on a regular basis.

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Final Thoughts

Participation in the EMS Demonstration Project has been a rewarding experience for Pitney
Bowes. The project provided a much needed structure for implementation activities. In less than
one year from its EMS kick-off meeting, the Harlow site is ready for a certification assessment.
We believe that having a structured, certified EMS in place will improve our environmental
performance and add real value to the business.
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                             TRINOVA Corporation

Background

TRINOVA Corporation, headquartered in Maumee, Ohio, is a worldwide industrial manufacturer
and distributor of engineered components and systems. TRINOVA's companies, Aeroquip and
Vickers, operate approximately 75 facilities in 18 countries.  The pilot facility chosen for the EMS
Demonstration Project has an excellent environmental compliance record, is ISO 9001 certified,
employs 125 people, and manufactures hydraulic fittings for the aerospace industry.


Drivers for Implementing an EMS

TRINOVA did not join the EMS Demonstration Project based on any internal driver to
implement ISO 14001.  Rather, the possibility that this voluntary Standard might become a de
facto requirement of doing business internationally created a need to learn as much as possible
about ISO 14001, so that an implementation strategy could  be developed.  In short, our
motivation to learn about the ISO 14001 Standard and be prepared with an implementation
strategy was business driven.


Self-Assessment

An assessment of the site's environmental management practices against the requirements of ISO
14001 was conducted by the pilot facility's environmental manager and an engineer from
corporate headquarters who had recently performed a comprehensive compliance review at the
facility.  These two individuals then discussed and resolved any differences in their findings and
jointly produced a draft assessment report.  The draft report was critiqued by an independent
EMS consultant before being finalized and submitted for the EMS Demonstration Project. This
outside critique ensured that the assessment provided an accurate basis upon which to move
forward.  The critique also improved our understanding of the ISO 14001 Standard at an early
stage of the project.


Implementation

Although a basic action plan was formulated to address gaps in environmental management
practices (as identified in the self-assessment), there was uncertainty as to how to reach full EMS
implementation.  Because of the sheer number of detailed requirements in ISO 14001, the task of
fully implementing its requirements seemed daunting.  One doesn't simply pick up and read ISO
14001 and then immediately begin to implement it.  A great deal of time was required to review
the Standard and attend Demonstration Project meetings to build understanding and confidence
before resources were invested in EMS implementation.

Implementation progress was limited at first because our approach was to focus on the 17
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elements of the ISO 14001 Standard one at a time rather than on the Standard as a whole. We
believed that "environmental aspects" was an element that needed to be expertly fashioned and
installed before moving on to "legal and other requirements," which also needed to be expertly
fashioned and installed before moving on to "objectives and targets," and so on.  A key to
improving our implementation progress was the realization that systems in place for compliance
with US environmental regulations would fulfill most ISO 14001 requirements (as noted by an
EMS Demonstration Project guest speaker who was one of the leaders of the US Technical
Advisory Group).

Based on this understanding, we began to incorporate elements of our pilot facility's existing
compliance program and procedures into the framework established for implementing ISO 14001.
The initial EMS thus developed, though unrefined, can be improved over time, consistent with the
need to demonstrate continual improvement in environmental performance. Using this approach,
we have made much better progress toward complete implementation of ISO 14001  at the pilot
facility.  As a company that lacked a mature EMS at the outset of the EMS Demonstration
Project, TRINOVA is hardly in a position to offer advice to others on deeper understanding of the
fine points of ISO 14001; however, we would recommend this approach to other companies that
experience difficulty in initially implementing their EMS.

A key element of our strategy during the Demonstration Project was to promptly form an
interdisciplinary team to identify environmental aspects, establish one or two targets related to
these aspects, and then carry out a program to achieve these targets. It was felt that some early,
tangible results would allow EMS development to be viewed as a dynamic and practical process,
rather than a paperwork / procedures exercise. The team  felt strongly that demonstrating early
results would enhance the EMS Demonstration Project's  acceptance and momentum at the
facility.

This strategy proved to be effective. People get excited when they have a feeling of
accomplishment in lessening the environmental impact of their jobs on the community in which
they live. Due largely to this approach in the earlier stages of the project, development of various
written procedures required by ISO 14001 (the more tedious part of implementation) has
proceeded in earnest and a positive attitude has been maintained.

One of the key challenges in implementing ISO 14001 is the  Standard's great emphasis on written
procedures. More detailed documentation requires greater maintenance. While it is clear that any
system must be documented to be worthwhile, it does not follow that the greater the level of
documentation, the greater the value that will be added.
Benefits

The "ISO 14001 team" was comprised of the pilot facility manager, the environmental manager,
key workers from various areas within the facility, and a corporate representative. The team
found that people on the manufacturing floor who actually work with processes which impact the
environment have a very thorough knowledge of those processes, while environmental managers
at the facility and corporate level had the most thorough knowledge of existing and emerging

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regulations.  It was demonstrated during the project that the EMS can bring these people closer
together. As employees' roles become better defined, and as information flow between
employees improves, they become better informed and proceed to more effectively fulfill their
roles in managing environmental activities.  A broad-based, improved understanding of
operations, coupled with the systematic approach described by ISO 14001, supports
environmental improvements.

In addition, based on the systematic approach and the use of interdisciplinary teams, the pollution
prevention projects which were identified and implemented at the pilot facility, have reduced the
site's direct costs. Other pollution prevention projects should help the site to avoid certain costs
in the future.
Final Thoughts

Our experience with the EMS Demonstration Project has shown that a systematic approach to
environmental management makes sense; however, we are somewhat skeptical at this time about
the potential benefits of ISO 14000 registration due to our experience with ISO 9000. ISO 9000
registration at the pilot facility has not resulted in the domestic or international trade opportunities
predicted in the earlier days of that Standard.  Little value has been added to offset the costs of
maintaining ISO 9000 registration. Based on this experience with ISO 9000, our current
environmental strategy calls for implementing a systematic approach to environmental
management, but not for seeking ISO 14001 registration unless a business advantage can be
demonstrated.

The EMS produced and the experience gained as a result of the EMS Demonstration Project will
serve as guides for TRINOVA's business units in which ISO 14001 registration is deemed to be a
prudent business decision.
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                          United States Postal Service
Background
The United States Postal Service (USPS) is a government-owned corporation whose mission is to
provide prompt, reliable, and efficient mail service to all communities in the United States.  With
over 720,000 employees working at more than 40,000 post office facilities nationwide, the USPS
is second only to the Department of Defense in terms of the size and reach of its operations and
activities.  The USPS is organized into 10 area offices, which are further subdivided into 85
districts.

Although one might not immediately associate the USPS with potentially significant
environmental impacts, a number of environmental issues relate directly to the USPS's core
business processes. These environmental issues derive from, among other things:

•      the 205,000 vehicles the USPS operates and maintains;
       the chemicals it uses to maintain automation and mechanization;
•      the solid wastes it generates; and,
       the content of the products it sells.  (For example, in manufacturing and  selling postage
       stamps, the USPS is the largest single consumer of adhesives in the United States.)
Drivers for Implementing an EMS

During the two years immediately preceding the EMS Demonstration Project, the USPS
undertook an intensive effort to improve the management and performance of its environmental
program.  This effort included the development and issuance of a comprehensive environmental
policy statement; conduct of a thorough environmental effects (impacts) analysis of major
operations and activities; subsequent development of environmental strategies, development of
objectives and targets;  and preparation of over 100 tactical action plans designed to implement the
strategy.  Senior managers from the 10 area offices and major divisions within the Headquarters
actively participated in this effort. The principal focus of this effort was to:

•      ensure compliance with  environmental laws;
       integrate environmental  considerations into business planning;
•      promote individual responsibility for environmental protection and enhancement;
•      work more closely with customers to address their concerns;
•      track progress in meeting environmental goals and objectives; and
       set environmental standards for suppliers.

While this undertaking was and continues to be immensely successful, senior management
recognized that a key element was still missing — the basic framework for a comprehensive EMS.
While not necessarily intending to pursue formal ISO 14001 registration, the USPS felt that the
requirements set forth in the ISO 14001 Standard described activities that any environmentally
responsible organization should be doing as part of its routine business practice.  From that
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perspective, the USPS was eager to see just how well its program "measured up," while at the
same time identifying areas where more emphasis was needed.

Recognizing that there was a great deal to learn about what an EMS is and what is required to
successfully develop and implement one, the USPS decided that active participation in the EMS
Demonstration Project would provide valuable insight and practical experience. Accordingly, the
USPS decided to participate in the project with the assistance of a private, non-profit third-party
organization (the Logistics Management Institute (LMI)), a federally-funded research and
development center located in McLean, Virginia.
Self-Assessment

LMI staff members (who were relative newcomers to the EMS concept) underwent NSF
International's extensive EMS training program and conducted assessments at representative
USPS facilities. Facilities selected for assessment were the USPS Headquarters located in
Washington, DC, and the Southwest Area (SWA) Office, located in Dallas, Texas.  Initial
assessments were completed in April and May 1995, with follow-up assessments conducted in the
spring of 1996.

The assessments, which were conducted by LMI staff using the NSF self-assessment tool,
included face-to-face interviews as well as extensive documentation reviews.  Selected field
facilities (such as the Dallas Bulk Mail Center) were also visited so that assessors could determine
the degree to which policies and procedures were actually being implemented. At the USPS
Headquarters, interviews were conducted with key members of the Environmental Management
Policy Office, while at the SWA Office, the area environmental compliance coordinator was the
principal contact. The results of the initial self-assessment showed that the SWA Office was
roughly at a 25% implementation level.  The Headquarters Office was found to be at 49%
implementation level because the extensive strategic planning initiative and other actions were
already underway at that location.
Implementation

Based on the self-assessment results, the USPS was particularly encouraged to note that many of
the requirements of ISO 14001 were already being addressed to some degree. (In fact, almost any
organization with a formal environmental program already has many elements of an EMS in
place.) The principal reason for the disparity in EMS implementation between the two pilot
locations of USPS organization was the fact that seven key district environmental coordinator
positions in the SWA were unfilled, and the single area coordinator was totally engulfed in
managing day-to-day operations.  This left little time for the SWA organization to focus on EMS
implementation activities.  Nevertheless,  significant improvements were noted at both levels
during the reassessment one year later. The Headquarters Office improved to 87%
implementation, while the SWA Office achieved 51% implementation — almost a 100%
improvement at both organizational levels.
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EMS areas where the USPS was found to have particular strength (or to have made the most
improvement over the year) included environmental policy, objectives and targets, resources
(especially environmental staffing), training and awareness, documentation, compliance auditing,
communications, and management review. Key areas that required additional emphasis included
development of performance indicators, impact and risk analysis at the area level, records
management, and EMS auditing.
Benefits

While the USPS has not made a final decision regarding formal ISO 14001 registration, it does
recognize that there are many tangible benefits from implementing a formal EMS. An EMS
establishes a basic framework for a sound environmental program and subsequent environmental
performance. This in turn should serve to improve the overall condition of the environment by
reducing or eliminating negative impacts. An EMS should also result in more effective
compliance management, by ensuring that field operations are properly identifying and addressing
environmental concerns, allocating resources wisely, coordinating activities with other key
program offices, and reviewing and improving internal processes and procedures.

In addition, there are other compelling reasons for EMS implementation, such as:

•      potential customers may require it (especially in the international marketplace);
       facility neighbors may want it (public image enhancement); and,
•      it may affect relations with regulators and future liabilities (e.g., facilitate permitting,
       reduce frequency and depth of inspections, and reduce severity of fines and penalties
       assessed).

In view of these considerations, the USPS will require the nine remaining area offices to complete
initial EMS self-assessments during 1997. This assessment will give the area environmental
coordinators an indication of where their strengths and weaknesses are, and how much work
needs to be done to meet the requirements for a successful environmental program.  Results of
those EMS assessments will be input into the newly-developed Environmental Management
Information System designed to facilitate high level corporate management review and tracking.
Periodic reassessment results will be used to monitor progress across the USPS as each area
strives to meet all requirements of the ISO 14001 Standard.
Final Thoughts

As with any company, large or small, the USPS knows that the future will likely bring increasing
environmental challenges and opportunities.  By meeting those challenges and opportunities head-
on, the USPS will continue to ensure a safe and healthy environment, present a positive public
image as a high performance organization, reduce overall operating costs, and increase business
opportunities.  Establishment of an EMS will provide an essential tool for continuous refinement
and improvement of its program performance, and will ensure the ultimate realization  of
corporate environmental policy, goals and objectives.

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                       Washtenaw County Government
Background
Washtenaw County's involvement in the EMS Demonstration Project is unique because it was the
only government agency involved. The Sheriff Department was chosen as the pilot facility to
participate in the Demonstration Project on behalf of Washtenaw County.  This department had a
management staff that was committed to the goals of the project and was experienced with the
implementation of quality management principles. In addition, this department had a clear
command structure that designated responsibility  and accountability.

Once the Sheriff Department was established as the facility to participate in the project, the
Director and Senior Environmental Manager from the Department of Environment and
Infrastructure Services met with a Commander in the Sheriff Department to brainstorm concepts
for an EMS and the benefits of having an EMS in place.

The Senior Environmental Manager and the Commander discussed specific issues that would
facilitate a feasible  and effective EMS plan.  These conversations focused on the differences
between EMS implementation in a private company and a public agency, and how an EMS would
fit into the Sheriff Department's command structure.  A policy was created as a result of these
meetings.  The policy is based on the development and maintenance of a quality management
system (QMS) which will include the EMS. The  two systems will be integrated because the
department decided that both a QMS and EMS were necessary. This system will be implemented
based on a holistic set of criteria, including the ISO 14001  Standard as well as Criminal Justice
policies, Corrections Operations policies, and additional standards. This will ensure that these
different standards will not be applied in a piecemeal fashion.
Drivers for Implementing an EMS

The service delivery sector of Washtenaw County is comprised of several departments, and
policies exist to govern these operations. The County is confronted with a need to manage these
areas by utilizing a well-developed, systematic approach to management.

In Washtenaw County, the current county-wide environmental policies concern waste
management (primarily recycling), purchasing of hazardous substances, and pollution prevention.
Although specific policies exist in these areas, there is a need for environmental policies that are
linked to a managerial approach. Several policies are currently at the planning stage; these polices
relate to sustainable development, economic development that will decrease urban sprawl, and
both quality and environmental management systems.
Expected benefits of an EMS include increased government accountability, and the opportunity to
lead by example.
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Self-Assessment

The Sheriff Department conducted a preliminary and final self-assessment. The assessments
focused on the Jail Operations and Food Services. These services comprise two of the six
sectors within the Corrections Division. They were selected because they involved a high level
of material use, and staff were already documenting some of the material use streams. There
was a need to develop and implement a more advanced method for solid waste management to
replace current operational procedures. The measurables of concern were food service
packaging waste materials, dry cell batteries, and ammunition shell casings.

Once these measurables were identified and documented, they were presented to the staff
working in these areas. The staff agreed that a more effective approach for measurement and
accountability would enhance the quality of their work.  A department-wide "Quality Team"
was formed to assist with the coordination of QMS/EMS policy initiatives.  This diverse group
is comprised  of representatives from various sectors of the department, including officers,
counselors, sergeants from Security Detail and Inmate Interactions Detail, and other divisions.

The Sheriff Department self-assessment identified existing procedures, resulting in a viable
foundation to implement an EMS to target the measurables listed above.  For the food service
packaging waste materials, Food Service staff was already required to count lids and cardboard
for safety purposes. For dry cell batteries, the department currently has a "gate keeper" system
for collecting old batteries and distributing new batteries. This system includes a central
operating station which is operated by one individual. Batteries are used extensively within the
department because they are necessary for flashlights, cellular phones, pagers and other
communication devices, hand held radios, and emergency response equipment. Dead batteries
accumulate and require proper disposal.

The brass ammunition shell casings are captured and recycled at the County practice target
range.  An incentive exists to recycle these because the department returns the casings to the
ammunition suppliers for rebates on new ammunition. Although these initiatives currently exist
with little documentation and little management oversight, it is hoped that the EMS  will
improve and formalize the recycling efforts.
Challenges

In the public sector, political influence establishes policy direction and determines how
resources are utilized. Most private companies have a management component that determines
resource distribution; this allows flexibility in developing and adopting management schemes to
attract customers. Government agencies, on the other hand, are faced with incorporating
policies that are developed at the top level based on public needs.  These policies are then
disseminated to the departmental level.  The County is faced with the challenge of incorporating
an effective EMS within an atmosphere of elected officials and political agendas that
predetermine budgets and resource allocation.
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Implementation

Implementation is now underway. The Senior Environmental Manager is developing the forms
that will provide precise documentation for accountability within the facilities. The department is
also identifying persons who will be responsible for adopting additional duties, or adjusting
current duties, that will facilitate the implementation of procedures.  Once these areas are
developed into a working routine for the targeted facility, a management policy review or auditing
process will follow.  A review process will have two purposes: 1) to identify procedures that are
not effective; and 2) to continue or enhance the development of areas that are achieving the goals
of the EMS.

Once an EMS is documented and achieved, then the approach can serve as an example to be
applied to the additional four segments of the Corrections Division.  This effort will also
eventually be applied to a county-wide EMS implementation program.
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VIII. BIBLIOGRAPHY
Cascio, Joseph, editor.  The ISO 14000 Handbook.  CEEM Information Services with ASQC
Quality Press, 1996.

Diamond, Craig P., "Voluntary Environmental Management System Standards: Case Studies in
Implementation." Total Quality Environmental Management, (Winter 1995/1996), pp. 9-23.

International Organization for Standardization, ISO 14001: Environmental Management Systems
- Specification with Guidance for Use. 1996.

NSF International, Environmental Management Systems: An Implementation Guide for Small
and Medium-Sized Organizations. November 1996.

Tibor, Tom with Ira Feldman, ISO 14000: A Guide to the New Environmental Management
Standards, Irwin Professional Publishing, 1996.
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IX. APPENDICES
Appendix A
Background on ISO 14000, EMS Standards, and Registration
The Development of ISO 14000

The International Organization for Standardization (ISO) is responsible for the development
of the ISO 14000 series of international environmental management standards.  ISO was founded
in 1946 and its headquarters is located in Geneva, Switzerland.  ISO has developed international
voluntary consensus standards for manufacturing, communication, trade, and management
systems. Its mission is to promote international trade by harmonizing international standards.
Over 100 countries have national standards bodies that are members of ISO. The American
National Standards Institute (ANSI) is the U.S. representative to ISO.

In June 1991, ISO created the Strategic Advisory Group on the Environment (SAGE).
SAGE assessed the need for international  environmental management standards and
recommended that ISO move forward with their development.  In January 1993, ISO created
Technical Committee 207 (TC 207) which is charged with the development of the ISO 14000
series of standards.  TC 207 is comprised  of various subcommittees and working groups.
Representatives from the ISO member countries contribute their input to TC 207 through national
delegations.

In the United States, the U.S. Technical Advisory Group (U.S. TAG) develops the U.S.
position on the various ISO 14000 standards. The U.S. TAG is comprised of approximately 500
members representing industry, government, not-for-profit organizations, standards organizations,
environmental groups, and other interested stakeholders. The U.S. TAG has the largest number of
members of ISO member delegations.   There are several organizations involved in the
administration of the U.S. TAG's input to TC 207, including: ANSI; the American Society for
Quality Control (ASQC); the American Society of Testing and Materials (ASTM); and NSF
International.

TC 207 developed the ISO 14001 Standard which specifies requirements for an environmental
management system (the ISO 14001 Standard is the only standard in the ISO 14000 series which
is designed to be audited - such a document is called a specification standard).  ISO 14001
contains 17 elements that comprise an EMS.  In addition to ISO 14001, several guidance
documents are also being developed by TC 207. ISO 14001, ISO 14004 (an EMS guidance
document), and three environmental auditing guidelines (ISO 14010, ISO  14011, and ISO
140012), were published in September 1996. Other documents in the areas of environmental
labeling, life-cycle assessment, and environmental performance evaluation are under development.
Published ISO standards must be reviewed and revised every five years.
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The Emergence of EMS Standards

Numerous factors have contributed to the emergence of EMS standards. The following is a brief
overview of some of the major factors.
ISO 9000

The ISO 9000 series of international quality management standards was published in 1987. The
standards were created to promote consistent quality practices and to facilitate international trade.
The ISO 9000 series of standards has been adopted by more than 80 countries and is used as a
benchmark for quality management by industry and government bodies worldwide.  In some
cases, ISO 9000 registration has become a prerequisite for doing business domestically and
internationally. In North America, over 13,000 companies are registered to ISO 9000.

The quality management system framework can serve as a foundation for environmental
management systems. In essence, an EMS is the application of quality management system
principles to the management of environmental affairs.  While the ISO 9000 and ISO 14001
standards have different focuses, they share many similar requirements. The three specification
documents for ISO 9000 series are ISO 9001, ISO 9002, and ISO 9003.  The key difference
between ISO 9000 and ISO 14001 is that ISO 14001 requires planning steps to identify
environmental aspects and significant environmental impacts which become the basis of continual
improvement.
Sustainable Development

In 1987, the World Commission on Environment and Development (Brundtland Commission)
coined the term "sustainable development" in its report entitled Our Common Future.  This report
emphasized the need to balance environmental protection and economic growth.

In 1991, the International Chamber of Commerce (ICC) created the Business Charter for
Sustainable Development.  The ICC Charter is comprised of sixteen Principles for environmental
management that foster sustainable development. The Principles in this document include some
of the basic elements of environmental management systems.

In 1992, the United Nations Conference on Environment and Development (UNCED) was held in
Rio de Janeiro. The conference, also called the Earth Summit (or Rio Summit), resulted in two
noteworthy documents — Agenda 21 and the Rio Declaration.  Agenda 21 is a comprehensive
guidance document for sustainable development, while the Rio Declaration  is a set of 27
principles for achieving sustainable development.

These international initiatives on sustainable development marked the dawning of a new age in
environmental protection. The business community worldwide was asked to  consider its impact
on the environment and to take steps to mitigate that impact.

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Private Sector Programs & Public Concern for the Environment

Private sector programs, such as the Chemical Manufacturers Association's Responsible Care"
program, the Global Environmental Management Initiative (GEMI), and the Coalition for
Environmentally Responsible Economies (CERES) Principles (formerly the Valdez Principles),
resulted in model codes of conduct that encourage environmental stewardship. In addition, public
concern for the environment has provided strong motivation for the development of EMS
standards.
National EMS Standards & EMAS

In 1992, the British Standards Institute (BSI) published BS 7750, the first national standard for
environmental management systems.  BSI had previously published BS 5750 (a quality
management system standard in the United Kingdom) which was a significant contribution to the
development of ISO 9000. ISO 14001 was largely based on BS 7750, and the two standards
share many similar requirements.  The BS 7750 Standard, however, is viewed by many to be more
stringent than ISO 14001. For example, BS 7750 requires that an organization compile a register
of its significant environmental effects, and a register of all legislative, regulatory, and other policy
requirements. In addition, BS 7750 requires  an organization to make its environmental
objectives publicly available.

Following the publication of the United Kingdom's BS 7750, a proliferation of national EMS
standards emerged, including standards from Ireland, France, South Africa, and  Spain. These
various EMS standards did not all share the same requirements, and in some cases the
requirements were contradictory.  It became clear that in order to facilitate international trade,
there would have to be one international EMS standard that would be accepted around the globe.

In addition to the national EMS standards, European legislation was  developed.  The Eco-
Management and Audit Scheme (EMAS) was adopted by the European Union (EU) in 1993.
EMAS is a regulation that enables industries to voluntarily implement formal environmental
management systems in order to improve their environmental performance.  While ISO 14001 and
BS 7750 apply to organizations (or parts thereof), EMAS is restricted to site-specific industrial
activities. EMAS participants must prepare an environmental statement specific to each site
concerned and provide information to the public about their environmental aspects. Third-party
verification of the EMS is an essential component of EMAS. Participating organizations are
included on the EU list of participating sites.
The Registration Process

EMS registration is the process whereby a non-biased "third-party" attests that an organization's
EMS conforms with the requirements of an EMS standard, such as ISO 14001. It is important to
note that the ISO 14001 Standard does not require third-party registration, but market forces and
regulatory incentives may provide strong encouragement for registration.  The third-party

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organization that performs the registration services is called a "registrar." The type of
registration services that will be offered for ISO 14001 will be similar to those offered for the ISO
9000 series of quality management system standards.  In North America, over 13,000 companies
have been registered to ISO 9000.

The ISO 14001 Standard does not require that an organization implement the EMS at the
corporate level. For example, one organization may choose to implement the Standard
throughout the entire organization, while another may implement the Standard in one particular
facility.  Therefore, an organization can elect to register the entire organization, a division(s),
selected facilities, a particular facility, or selected operations within a facility.  The key factor in
choosing the organizational unit for registration purposes is that it has its own functions and
administration.

A registrar can be "accredited" by a third-party accreditation body that is independent of the
registrar. Accreditation is the process by which a registrar's competence is evaluated by a third-
party accreditation body with national or governmental recognition. Accreditation greatly
enhances a registrar's credibility.

Registrars may have different registration processes and may offer different types of services.  The
following description of the registration process is fairly typical of the process used by many
registrars.  It is provided for illustrative purposes:

Step 1: Application for Registration
The organization that wishes to obtain EMS registration submits an application indicating the activities and
facilities of the organization or site to be registered.

Step 2: Review of EMS Documentation /Desk Audit
The organization submits documentation of its EMS, which includes its environmental policy and
documentation that indicates how it meets each clause in the ISO 14001 Standard. The documentation is
reviewed by a designated lead auditor. The auditor generates a written report which indicates conformance or
nonconformance of the documented EMS to each clause of the Standard.

Step 3: On-site EMS Readiness Review
The lead auditor conducts an on-site visit in order to resolve any EMS documentation nonconformances and
to verify that the facility is prepared for a full registration audit. The on-site visit is also used to assess the
resources and logistics necessary for the full registration audit.

Step 4: Registration Audit
An audit team will conduct an on-site audit to evaluate and verify through objective evidence (interviews,
procedures, records, etc.) that the EMS conforms to the requirements in the ISO 14001 Standard, is
effectively implemented, and has sufficient provisions to be maintained.

Step 5: Registration Determination
A final report containing the results of the registration audit is submitted to the organization. To receive a
Certificate of Registration,  an organization must successfully meet the requirements of the ISO 14001
Standard, as well as the registration policies of the registrar.

Step 6: Surveillance


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Surveillance audits are typically performed semi-annually to verify continued conformance. During the
surveillance audits, the audit team may only audit certain elements of the EMS.  Over a three year period,
however, all of the elements of the EMS must be reviewed to ensure continued conformance to the
requirements of the ISO 14001 Standard.

Registration Audit Results
There are essentially three possible results from a registration or surveillance audit. The registrar can
determine that the applicant is:

1)     Recommended for registration
       There are no major nonconformities;

2)     Recommended for registration following verification of corrective action
       There are one or more major nonconformities which can be corrected and verified without a full re-
       audit; or

3)     Recommended for an on-site reassessment
       There are several major nonconformities which indicate a breakdown of the EMS.  Another full on-
       site audit is required.

Note: A major nonconformity is the absence or complete breakdown of an EMS element. A large number of
minor nonconformities for one element may be considered a major nonconformity. A minor conconformity is
a single observed nonconformity.
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Appendix B
Questions Asked of Project Participants at the Conclusion of the Project
      What factors are motivating/driving your company to implement an EMS?

      What have been the barriers/challenges to EMS implementation encountered thus far, and
      how has your organization addressed them?

      What specific requirements in ISO 14001 are questionable (i.e., unclear, of limited value, or
      too difficult to implement) and why?  Please provide a reference to the actual language
      when answering this question.

      Has (or will) implementing the EMS helped your organization develop more effective
      approaches for managing environmental compliance activities?

      Has implementing the EMS improved your organization's overall environmental
      performance? Which specific environmental impacts have been affected?

      Has implementing the EMS reduced overall environmental management costs? Which
      costs in particular?

      Has implementation brought or maintained domestic or international trade opportunities?
      If so, explain.

      In what ways have you integrated your EMS with ISO 9000 or other existing management
      systems  (e.g., health & safety)?  Please explain.

      Have you attempted to calculate the costs of EMS implementation? If so, how did you
      define your implementation "starting point" (i.e., was this project the EMS starting point,
      or some time before that)? What costs were considered in the calculation?

      What other benefits have you received, or expect to receive, from EMS implementation?

      What advice would you offer to regulators (federal, state) as they look for ways to use the
      EMS approach and ISO 14001 in their interactions with the regulated community?
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Appendix C
Elements of the ISO 14001 Standard: A Snapshot
Environmental policy - Develop a statement of the organization's commitment to the
environment. Use this policy as a framework for planning and action.

Environmental aspects - Identify environmental attributes of the organization's products,
activities, and services.  Determine those that could have significant impacts on the environment.

Legal and other requirements - Identify and ensure access to relevant laws and regulations (and
other requirements to which the organization adheres).

Objectives and targets - Establish environmental goals for the organization, in line with its policy,
environmental impacts, views of interested parties, and other factors.

Environmental management program - Plan actions to achieve objectives and targets.

Structure and responsibility - Establish roles and responsibilities, and provide resources.

Training, awareness and competence - Ensure that employees are trained and capable of carrying
our their environmental responsibilities.

Communication - Establish processes for internal and external communications on environmental
management issues.

EMS documentation - Maintain information on the EMS and related documents.

Document control - Ensure effective management of procedures and other system documents.

Operational control - Identify, plan, and manage operations and activities in line with the
organization's policy, objectives, and targets.

Emergency preparedness and response - Identify potential emergencies and develop procedures
for preventing and responding to them.

Monitoring and measurement - Monitor key activities and track environmental performance.

Nonconformance and corrective and preventive action - Identify and correct  problems and
prevent recurrences.

Records - Keep adequate records of EMS performance.

EMS audit - Periodically verify that the EMS is functioning as intended.

Management review - Periodically review the EMS with the goal of continual improvement.
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Appendix D
Excerpts from NSF's EMS Self-Assessment Tool
This appendix contains two items:

• the first page of the checklist from NSF's EMS Self-Assessment Tool; and
• descriptions of the five implementation levels used in the tool.

These excerpts from the assessment tool are provided here to illustrate the format of the EMS
self-assessments and independent assessments that were conducted as part of the EMS
Demonstration Project. The sample page taken from the checklist contains the exact language
from the ISO 14001 Standard. The actual checklist, which contains EMS requirements from the
entire Standard, is approximately nine pages in length.

As discussed in Section IV of the report, the checklist breaks down the 17 elements of ISO 14001
into 63 individual requirements.  The sample page provided contains the first eight of these
requirements. The numbers that appear with each requirement are not found in the actual
Standard; they were developed solely for use in NSF's EMS Self-Assessment Tool.
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Appendix D
                   Checklist for ISO 14001: Sample Page
Requirement
Implementation Level
Yes
No
Comments
4.2 ENVIRONMENTAL POLICY
Top management shall define the organization's environmental policy and ensure that it:
4.2.1 is appropriate to the nature, scale and
environmental impacts of its activities,
products or services;
4.2.2 includes a commitment to continual
improvement and prevention of pollution;
4.2.3 includes a commitment to comply with
relevant environmental legislation and
regulations, and with other requirements to
which the organization subscribes;
4.2.4 provides the framework for setting and
reviewing environmental objectives and
targets;
4.2.5 is documented, implemented and
maintained and communicated to all
employees; and
4.2.6 is available to the public.
ncoivi
DES
ncoivi
DES
DCOIV1
DES
DCOIV1
DES
DCOIV1
DES
DCOIV1
DES
DMA
DIN
DPAR
DMA
DIN
DPAR
DMA
DIN
DPAR
DMA
DIN
DPAR
DMA
DIN
DPAR
DMA
DIN
DPAR






 4.3  PLANNI,
4.3.1 Environmental Aspects
4.3.1.1 The organization shall establish and
maintain (a) procedure(s) to identify the
environmental aspects of its activities,
products or services that it can control and
over which it can be expected to have an
influence, in order to determine those which
have or can have significant impacts on the
environment.
4.3.1 .2 The organization shall ensure that
the aspects related to these significant
impacts are considered in setting its
environmental objectives.
DCOIV1
DES
DCOIV1
DES
DMA
DIN
DPAR
DMA
DIN
DPAR


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Appendix D
                              EMS Assessment Checklist
                          Implementation Level Descriptions
Described below are the five implementation levels used in NSF's EMS Self-Assessment Tool.
Achievement levels NA, IN, and PAR indicate that the requirement has not been met - this is
categorized as "NO" on the assessment checklist. Levels COM and ES indicate that the
requirement has been met - this is categorized as "YES" on the checklist.
No Action (NA) - No significant or formal actions have been taken by the organization to plan or
implement activities that would meet this requirement.


Initiation (IN) - The organization has begun to plan or undergo specific activities that would
contribute to fulfilling this requirement.  Activities might include one or more of the following:

• general planning has begun or been assigned;
• a written action plan or outline is prepared, or being prepared;
• draft policies, procedures or initiatives are under development or review;
• responsibilities for specific planning or design activities have been assigned; or
• pilot activities to assist in the design process are underway.


Partial Implementation (PAR) - Implementation of an action plan has begun, but major gaps in
implementation exist in the organization. Specific activities that contribute to fulfillment of this
requirement have been implemented in only parts of the organization; and/or some but not all of
the necessary activities have been implemented; and/or activities are fully deployed but are not
implemented effectively.


Complete Implementation (COM) - All specific activities necessary to fulfill this requirement
have been effectively implemented in all parts of the organization.


Evaluated & Sustained (ES) - Specific polices, procedures, or activities that contribute to
fulfillment of this requirement have been reviewed and  evaluated, and improvements, where
appropriate, have been introduced. Activities have been documented, sustained over time (e.g.,
one full business cycle), and have been  fully integrated into routine business operations.
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