United States
Environmental Protection
Agency
An Organizational Guide to
Pollution Prevention
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Traditional Approach Checklists
T
here are three sets of checklists for those choosing the Traditional Approach
in Chapter 4 of the companion P2 Guide.
The "Waste Minimization" choice refers to the checklists in Waste
Minimization Opportunity Assessment Manual (EPA/625/7-88/003).
Waste Minimization
When you select the "Facility P2" choice, you will be able to access the
checklists in Facility Pollution Prevention Guide (EPA/600/R-92/088).
Facility P2
The "DOE P2" choice will provide you with the checklists from the Model
Pollution Prevention Assessment Guidance published in 1993 by the U.S.
Department of Energy.
DOEP2
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Back to P2 Checklists
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P2 Checklists
Pollution prevention (P2) checklists are provided on this CD-ROM. You may
print them out and use them in your P2 program. Select the checklists from
the menu bars to the right.
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Trad. Approach Checklists
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Green Zia Worksheets
The following worksheets are in Microsoft Excel (. XLS) format. Use your
Excel-compatible spreadsheet program to view them.
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Back to P2 Checklists
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Minnesota Guide
to
Pollution
Prevention
Planning
May 1999
2nd Edition
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Acknowledgments
The revision and update of the Minnesota Pollution Prevention Planning Guide was a joint effort of the
Minnesota Technical Assistance Program (MnTAP) and the Minnesota Office of Environmental
Assistance (OEA), with assistance from the Minnesota Emergency Response Commission (ERC). In
addition, we received contributions of time and expertise from many other individuals. Their
participation was essential to the creation of this revised document and is greatly appreciated.
Authors
Robert Lundquist, MnTAP
Mark Snyder, OEA
Staff Team
Kenneth Brown, OEA
David Cera, OEA
Cindy McComas, MnTAP
Kevin McDonald, OEA
John Polanski, MnTAP
Editing/Layout
Deb McKinley, MnTAP
Lisa Mlinarcik, MnTAP
Contributors
Terry Foecke, Materials Productivity, LLC
Daniel P. Reinke, Environmental Resources Management
Larry Sibik, Pinnacle Engineering, Inc.
Steve Tomlyanovich, ERC
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Introduction
The Minnesota Guide to Pollution Prevention Planning has been developed to help companies
comply with the Minnesota Toxic Pollution Prevention Act. Compliance is only a minimum for the
company that is serious about being competitive and profitable. Waste is lost profit and pollution
prevention (P2) is another way of saying "no" to waste.
How a company prepares its P2 plan will be related its culture and the way it implements major
projects. A plan may be simply an opportunity to document the amount of waste generated per
product. The Guide is structured as if a company is developing a plan for the first time. It is designed
so that you can "fast forward" to the chapter most appropriate to your needs.
No company or facility is identical in how it operates its processes. However, pollution prevention is a
prescription for any company to increase efficiency as well as avoid environmental regulations and
waste.
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Table of Contents
Chapter 1 Why Pollution Prevention is Good Business page 5
Integrating Pollution Prevention with Business Planning
Chapter 2 Recognizing Pollution Prevention Opportunities page 8
Organizing Pollution Prevention Options
Chapter 3 How to Write a Pollution Prevention Plan page 11
Who is Required to Write a Plan
Basic Requirements of a Plan
Step One: Getting Started
Step Two: Use a Team
Step Three: Determine the Baseline
Step Four: Determine and Analyze Alternatives
Step Five: Set Objectives for Implementation
Step Six: Certification
Chapter 1 Pollution Prevention Progress Reports page 21
Monitor Progress
How Pollution Prevention Progress Report Information is Used
Appendix Pollution Prevention Planning Assistance Programs page 22
Pollution Prevention Fees
Suggested Resources
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Chapter 1 - Why Pollution
Prevention is Good Business
Every company understands the benefits that
come from reducing waste, which include
lowering costs and increasing profits. One way to
achieve these is through pollution prevention,
defined in the 1990 Minnesota Toxic Pollution
Prevention Act as "the elimination or reduction, at
the source, of the use, generation, or release of
toxic pollutants, hazardous substances, and
hazardous wastes." The key words in this
definition are "at the source." The intent of the
Act is that true pollution prevention occurs only
"at the source" which means within any process or
operation that uses or generates a hazardous
material.
To make the distinction between pollution
prevention and pollution control/waste
management more clear, one can ask:
"Does this activity reduce the use, generation or
release of hazardous materials or toxic chemicals
at their source?"
If YES = POLLUTION PREVENTION
-OR-
"Does this activity manage waste after it is
created?"
If YES = NOT POLLUTION PREVENTION
Pollution prevention is preferred over waste
management because it has been repeatedly
shown that preventing the generation of
regulated chemicals can be much less costly in
the long run than managing them as waste or
pollution. While there are waste management
techniques that effectively reduce generation or
release of one waste type, they nearly always
result in a generation or release of another type.
For instance, contaminants removed from
wastewater prior to discharge generally end up
as sludge needing to be landfilled. The
discharge water is cleaner, but the hazard has
been transferred from water to land. To truly
reduce the amount of waste to be managed,
and to avoid shifting hazards between air, water,
and land, companies must implement pollution
prevention techniques. A good way to clearly
identify your options and a good first step is to
develop a pollution prevention plan.
Pollution prevention planning is not a stand-
alone process. It's an activity that complements
existing efforts to improve productivity. By
analyzing current manufacturing processes and
identifying alternatives that reduce or eliminate
the use of a toxic chemical or generate fewer
hazardous wastes, companies can avoid the costs
of managing those chemicals and wastes. They
also escape the regulatory compliance
requirements that using those chemicals and
wastes will trigger.
Pollution Prevention Saves Money
A Minnesota floor cleaning equipment
manufacturer successfully reduced their
discharge of wastewater to the sanitary
sewer by diverting non-contact cooling
water to the washer in their paint system.
This change resulted in savings of
555,800 in reduced sewer and water fees.
The pollution prevention planning process is a
way for businesses to lessen their impact on the
environment. More importantly from a business
perspective, it lets them see how raw materials
can be used more efficiently or how a process
can be changed or replaced to make a product
or service more productive. This is why pollution
prevention is an integral and critical business
activity. Though the environmental manager
may coordinate pollution prevention planning,
every employee has a responsibility to prevent
waste.
Integrating Pollution Prevention with
Business Planning
Most companies are experienced with
developing long-term business plans to ensure
their future growth and success. Developing a
business plan involves identifying the company's
strengths, the competition's weaknesses, and
potential markets where these differences can
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be capitalized on. Performance goals are set
based on the characteristics of the markets
identified and this information is used to create
strategies for manufacturing and marketing that
will achieve the company's goals.
A pollution prevention plan should be integrated
into a business plan. The pollution prevention
plan focuses on developing and then profiting
from the company's good environmental
performance. By thinking of pollution prevention
in terms of business planning and efficient
resource management, it becomes easier for
employees to see why pollution prevention is
good business. When a company eliminates a
hazard or a waste, it also eliminates the costs
and risks associated with them. Companies that
do this will also be able to promote their "clean"
products and take advantage of market
resistance to products perceived to harm people
and the environment. They will also minimize the
costs of public and regulatory burden.
Efficiency and Pollution Prevention
The highest level of efficiency a business can
reach is to generate zero waste. An
unattainable goal? Don't tell that to the
companies that are discharging process water
cleaner than they receive it. If a company
accepts wastes and emissions as inevitable by-
products of its operations, the company will
continue to face rising costs for waste
management and will continue to be at risk for
problems such as permit violations. Every waste
should be seen not only as a problem but as an
opportunity.
With zero waste being the ultimate goal, a
company should look for ways to reduce waste
as much as possible. Changing procedures,
processes or the way products are manufactured
are a few options for waste prevention.
The next level of efficiency is recycling. Recycling
can either be accomplished within the same
manufacturing process by methods such as
distilling a spent solvent for reuse. Or, it may
involve sending waste materials off-site for
recycling if the company is unable to reuse the
material on-site, as in the case of spent lead-
acid batteries. An often overlooked part of
recycling is the need to close the recycling loop
by emphasizing the use of recycled materials
wherever feasible.
Treatment of wastes can include incineration,
neutralization, precipitation, or other chemical or
physical methods to prepare a waste for release
to the environment by making it less hazardous.
The lowest level of efficiency is the release of a
pollutant or waste. This includes incineration,
precipitation, landfilling, air emissions,
wastewater discharges, and treatment. In
practical terms, releasing waste means paying to
buy a resource, and then paying again to get rid
of it. In other words, no further value is gained
from the resource.
Pollution Prevention
Reuse
Recycling
Treatment
Quality and Pollution Prevention
Quality improvement is another important
business factor that should be considered in
conjunction with resource management. Virtually
all management and quality professionals agree
that optimizing resources and reducing wastes
and pollution leads directly to improved product
quality. Therefore, any pollution prevention
planning and implementation should be
integrated in the company's quality program. As
in pollution prevention, all quality schemes are
cyclic. These cycles involve planning, doing,
evaluating, and innovating. These four activities
may have different names, but they are the
essence of improving quality and preventing
pollution. Effective quality programs are
integrated across all company departments just
as pollution prevention planning should be.
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Environmental Management Systems, ISO
11000 and Pollution Prevention Planning
Many businesses that have benefited from
Environmental Management Systems (EMSs) are
exploring the idea of having their facilities ISO
14000-registered. Like other EMSs, ISO 14000 is
a series of specifications that guide
organizations to improved environmental
performance and compliance. ISO 14000 stands
out because its standards for the creation of a
management structure and environmental policy
are internationally recognized. Although ISO
14000 registration does not ensure
environmental compliance, it does certify that
the organization has a working management
system in place that promotes proper
environmental performance and compliance.
Pollution prevention planning is related to ISO
14000 registration in that both have the same
goal of improving environmental performance.
Although successful pollution prevention planning
and implementation requires steps that go
beyond those required for ISO 14000 registration,
there are similarities. The first step is the
self-assessment, where areas of concern are
identified and solutions are proposed. Then, the
proposed solutions are evaluated for feasibility
and those which are chosen are implemented.
Finally, the cycle completes when solutions are
evaluated again for their effectiveness and new
ideas are proposed for implementation where
needed. The ISO process documents waste
which is an opportunity for pollution prevention.
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Chapter 2 - Recognizing
Pollution Prevention
Opportunities
Organizing Pollution Prevention
Options
Pollution con be prevented in many different
ways. All these methods con be organized into
five categories. They are:
• chemical substitution
• material flow
• process control
• automation
• technology
These categories will likely overlap with each
other as they are examined and implemented.
Using these categories will help during the
options analysis step in the pollution prevention
planning process.
Chemical Substitution
Chemicals may be substituted that are less
hazardous and polluting. This can be viewed in
three different ways. First simple substitution can
directly impact the level or hazard of the
pollutant. For example, many facilities replaced
chlorinated solvent cleaning systems several
years ago with aqueous-based cleaning systems
when the Montreal Protocol phased out the
manufacture of chlorinated fluorocarbons and
some other chlorinated solvents due to their
ozone-depletion potential.
Second, less hazardous carrier or solvent
chemicals can be used. Virtually all coating
operations use a carrier to dissolve and transport
(by brushing or spraying) the desired coating.
Waterbased or powder paints may be used
instead of solvent-based paints that contain
volatile organic compounds (VOCs) such as
toluene.
The third situation involves chemicals that are
changed during the process into a more
hazardous polluting material. In this case, there
may be a substitute that will not be transformed
in such a way. An example would be a curing
process where initially non-toxic chemicals are
changed to more hazardous chemicals when
reacting or polymerizing under ultraviolet light.
These situations can be difficult to find
substitutes for because of the many interactions
that are going on in the process and the desired
results.
Whenever chemicals are substituted it will affect
other parameters of the process. Equipment may
have to be modified, the process itself may
need to change, training on how to handle the
new chemical may be needed. Rarely will a
direct substitution not require other process
changes.
Material Flow
Tracking and controlling how a chemical flows
through a facility and its processes is an
important way to prevent pollution. Material flow
includes activities like water conservation
practices, inventory control, efficient use of
chemicals and storage.
In many cases, how water is used and routed
through a facility is intertwined with pollution and
waste issues. Water is prevalent in rinsing,
cleaning and other common industrial
operations. As a result, many pollutants end up
in wastewater, requiring it to be treated before
being discharged from a facility. By tracing
where water enters a facility, where it flows
internally, how it is sent to the various areas for
use and how it is used may reveal ways that
pollutants are introduced. In addition, because
water is a resource that must be paid for, doing a
water flow analysis may reveal areas where
water can be conserved.
Like water, chemicals should also be tracked
through the system to identify areas where use or
generation can be reduced. In chemical process
solutions, optimize the concentrations of
chemicals to the minimum required to obtain the
desired results. Work with vendors to minimize
storing chemicals on site by implementing "just in
time" (JIT) delivery practices. Inspect chemical
transport systems and storage areas for leaks
and other losses. Develop an effective tracking
system of chemicals shipped, stored, transported,
used and treated or emitted. Other typical
factors that must be monitored include expiration
dates, rotation of stock and worker safety.
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Small quantities of chemicals, whether used or
not, are expensive to dispose. Companies
should have a restrictive policy on accepting
samples to avoid the accumulation of small
quantities of obscure or rarely used materials.
Preferably, no samples should be allowed. In
lieu of this, vendors should be required to accept
returns of any unused samples. Vendors may
also suggest installing an entire process line to
test their capabilities. Companies should have a
clear agreement with vendors who will be
responsible for removing any unused or
generated chemicals during the trial period.
Even if a vendor agrees to pay for removal, the
host company is seen as the generator and must
comply with all relevant regulations.
In general, any and all systems that transport,
store, dispense and otherwise move water and
other chemicals through a facility are necessary
for the company to function. These systems must
be given the attention that is required in order to
prevent pollution and losses that make the
company less profitable. Focus on the source of
the waste—at least—as much as on the waste
itself.
Process Control
Process control is about people and ensuring
that jobs are done properly so that waste and
pollution are minimized. It involves examining
the system and work environment to see if it
allows employees to do the job effectively. Key
elements in process control are written
procedures and documentation of completed
tasks, training and auditing to prove that jobs are
being done correctly.
First, determine if the materials that document the
process are accurate, complete and
understandable. This includes process control
sheets, raw material and use logs, training
materials, engineering schematics, and step-by-
step production procedures. From these
documents it should be clear what materials to
use and how to identify, measure, and move
them. The documents should contain all the other
relevant information that describes what must be
done. They should also include information on
what to do if something unexpected happens. If
the process in question is missing any part of the
documentation, then it should be developed.
Once it is clear that all the documentation is
available, then evaluate the method that is used
to communicate this information to the workers.
How are workers trained in the process? Is
training clear and convenient? Is it regularly
updated and completion documented? Is
process-related procedure documentation easily
available at the work site? Are preventative
maintenance procedures being followed? How
do workers provide feedback and suggestions to
supervisors or engineers? Workers must have a
clear understanding of how the job is done and
the consequences—both to themselves and the
company—of not following their training.
Auditing should be done to verify that the
production processes are being performed
properly. If a job is not being done as
prescribed, then the reason why should be
determined. Documentation may be faulty, the
equipment may be malfunctioning or training
may be insufficient. In any case, deviations from
the expected should be analyzed and corrective
action implemented to improve the system.
Results from auditing can be used to plan further
enhancements to the production process. Again,
focus on the source of any waste or pollution.
Automation
Especially for redundant and repetitive
procedures, automation can be used to
eliminate human error or inaccuracies in process
performance. It may decrease worker exposure
to hazardous chemicals. Automated processes
can be controlled or programmed to easily test
and improve a process to minimize waste.
For example, water conservation techniques can
be greatly automated. Inexpensive equipment
such as flow restrictors, timers and solenoid valves
can be used to activate and control processes
that use water. Painting operations can be
precisely controlled with automated spray guns
and conveyorized systems. Many sequential
chemical dipping operations such as plating
have been automated to minimize chemical
wastes and conserve water.
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Technology
The most creative and radical way to prevent
pollution is to change the technology that is
used to make a product. This will involve all four
of the other ways to prevent pollution. It may
mean a totally new mindset in how to do
something. It may mean using no chemicals at
all, instead using mechanical methods to
accomplish what chemicals had done. Due to
the changes in employee roles and
responsibilities that accompany a technology
change, it may be the most difficult but is often
the most effective way to prevent pollution.
Technology changes can also prevent pollution
through the design stage. The concepts of
Design for the Environment (DfE) can be used
either to design a new product or redesign an
existing product. DfE allows design teams to
take a new, creative and resource-efficient look
at specifications and features. The concepts of
DfE consider the environmental impacts of the
design of a product not only in manufacturing but
in its entire life cycle. The benefits of DfE include
improved market position, reduced manufacturing
and user costs and reduced regulations and
liability because the product is designed to
minimize waste from the start.
10
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Chapter 3 - How to Write a
Pollution Prevention Plan
Who is Required to Write a Plan
The 1990 Minnesota Toxic Pollution Prevention Act
(TPPA) provides a definition for pollution
prevention and also establishes a requirement
for certain industrial facilities in Minnesota to
prepare toxic pollution prevention plans. In
addition to preparing pollution prevention plans,
facility managers are required to submit annual
reports detailing progress with their facilities
pollution prevention efforts. Pollution prevention
plans are required for all Minnesota facilities that
are required to submit Form R reports for Toxic
Release Inventory (TRI) chemicals under the state
and federal Emergency Planning and Community
Right-to-Know Act (EPCRA). Pollution prevention
plans are also required of companies
participating in the MPCA Environmental Auditing
(Greenstar) Program.
If you have questions about whether your facility
is required to prepare a pollution prevention
plan, please contact the Emergency Response
Commission (ERC) at 651-297-7372.
For more information on the Greenstar Program
call the MPCA at 651-296-6300 or visit their Web
site at www.pca.state.mn.us/programs/
audit_p.html.
Basic Requirements of a Plan
Required contents of pollution prevention plans
include:
A policy statement expressing management
support for eliminating or reducing the
generation or release of toxic chemicals
(pollutants) at the facility.
A description of the current processes
generating or releasing toxic chemicals
(pollutants) that specifically describes the types,
sources, and quantities of toxic chemicals
(pollutants) currently being generated or
released by the facility.
A description of the current and past practices
used to eliminate or reduce the generation or
release of toxic pollutants at the facility and an
evaluation of the effectiveness of these practices.
An assessment of the technically and
economically practicable options available to
eliminate or reduce the generation or release of
toxic chemicals (pollutants) at the facility,
including options such as changing the raw
materials, operating techniques, equipment and
technology; personnel training; and other
practices used at the facility.
A statement of objectives and a schedule for
achieving those objectives. The TPPA requires
companies to express objectives in numeric terms
wherever technically and economically feasible.
Otherwise, non-numeric objectives can be stated;
however, they must include a clearly stated list of
actions designed to lead to establishing
numeric objectives as soon as they become
feasible. Facility pollution prevention plans must
contain objectives for each chemical for which a
facility submits a TRI Form R report. Pollution
prevention plans may also contain objectives for
other chemicals as well.
An explanation of the rationale for each
objective established for the facility.
A listing of options that were considered not
to be economically and technically feasible.
A certification, signed and dated by the facility
manager and an officer of the company,
attesting to the accuracy of the information in the
plan.
Pollution prevention plans are required to be
updated by January 1 of every even numbered
year.
Step One! Getting Started
How a company gets started on a pollution
prevention program and institutes it in all
business planning and operations will vary.
Implementation must be customized to each
individual facility situation. Many aspects of a
business such as capitalization, number of
employees, organizational structure and location
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may be considered when integrating pollution
prevention into a business. The steps in this
guide ore numbered simply as a way to identify
them. They do not necessarily need to be
carried out in this order, nor do all businesses
need to perform each step.
One of the required first steps in starting a
pollution prevention program is to gain
management support for the effort. Once
management recognizes the advantages of
pollution prevention, commitment should be
forthcoming for implementation. After a person
or a group has managements support, action can
be taken to investigate and evaluate options for
pollution prevention.
Depending on the size of a business, one person
or a team may be the focal point for
implementing pollution prevention. In any case,
the following should be done to get pollution
prevention activity started.
1. Understand and document operations so that
inefficiencies, as indicated by the amount of
waste or pollution generated, are identified.
This includes identifying the hidden costs and
overhead of waste and pollution.
2. Based on the understanding of a business's
situation and with management's input,
develop a policy for efficient use of resources.
This policy should be as specific as possible
and should set a standard for all future
environmental planning and action.
3. Based on the policy, develop company or
facility-wide goals for pollution prevention
activities. (Specific objectives for targeted
chemicals are set in Step 5).
4. Inform and educate all employees of the
intent and goals of the pollution prevention
program.
Starting and maintaining a pollution prevention
program requires the commitment and
participation of each employee. To sustain this
activity, contributions need to be rewarded.
While progress made in pollution prevention
efforts provides satisfaction for everyone
involved, outstanding individual efforts should be
recognized. Examples of recognition may
include employee awards, commendation at
special functions or a sincere thanks from the
management group. Monetary awards have also
been used, although it is recommended that
these type of awards be shared among all
employees involved in the pollution prevention
program to encourage sharing of ideas and
teamwork.
Step Two! Use a Team
A team approach is recommended for
addressing pollution prevention, and those on
the team must have the influence or be given the
authority to make things happen. A team may
evolve over time depending on changing
circumstances. One way to start forming a team is
to look at the organizational structure of the
business. In an ideal situation, a member from
each level of management and a member from
each production/functional division would be
part of the team. But keep the team a
manageable size (5 to 8 members) by recruiting
interested members from key functions playing
roles such as:
• Accounting: Break out costs associated with
toxic chemical use and waste generation to
educate managers of the financial impacts of
using or generating regulated chemicals.
• Engineering/Design: Evaluate manufacturing
products and processes and propose redesign
ideas to achieve pollution prevention
objectives.
• Finance: Determine cost-effectiveness and
payback for capital-intensive pollution
prevention projects.
• Health and Safety: Evaluate substitute
chemicals for employee health concerns.
Provide training for other groups so they can
get more involved.
• Maintenance: Evaluate maintenance practices
and develop or modify preventive
maintenance schedules to minimize or
eliminate waste generation.
• Production: Evaluate production practices to
determine how and why wastes are generated
and develop ideas for reducing and
eliminating waste.
12
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• Purchasing: Review chemical constituents of
new products purchased by a company
against an approved list and assist with
progress measurement by tracking use of
target chemicals through raw material
purchases.
• Research and Development: Develop and
use innovative process technology to achieve
pollution prevention objectives.
• Sales: Determine marketing advantages
associated with new or modified products that
reduce or eliminate waste generation. Get
customer feedback on proposed alternatives.
These members would then be responsible for
bringing issues to the team that are important for
the area they represent. Many facilities have
achieved great results in their pollution
prevention efforts by involving personnel who
work directly with the manufacturing processes
being evaluated. They often serve as an
excellent source of ideas on how current
processes can be improved. In any case, the
team must be effective at gathering and
analyzing data that leads to the implementation
of pollution prevention activities.
The team should make sure to involve the
company's vendors in the planning process. They
have the technical knowledge about the
chemicals or equipment they supply. They also
may have worked with other customers on similar
projects and can share information and success
stories. In addition, it may be helpful to include
other outside members such as customers that
have an interest in the business operation.
Mechanics of Teams
Teams go through four stages depending on how
well members know each other at the start:
1. A forming stage is characterized by members
being both excited and hesitant. Excited to
be a part of the group but hesitant due to
unknowns about work load and responsibilities.
2. A storming stage where tasks appear larger
and more time-consuming than expected.
Members may feel anxious and frustrated as
little progress is made. Members focus on
their own strengths and weaknesses as they
get to know each other better.
3. As more communication takes place, a
norming stage develops when the team starts
to function as a cohesive unit. Individual
skills, experiences and creativity are
recognized and used to solve problems.
Things start to happen.
4. In the performing stage, team goals are
being met and results become visible to the
whole organization.
An important team activity is brainstorming.
When brainstorming, make clear:
• Any and all ideas are valid.
• No judgement or criticism is allowed
during the brainstorming session.
• Build on the ideas generated by others.
• All ideas are written down so all
participants can see them.
Brainstorming sessions work by describing
problems in order to gain insight for solutions.
The types of questions that are asked involve
what is happening, how is it happening, and why
is it happening. Examples include:
• What is the waste?
• Where in the process is it created?
• Why is it created?
• What can be changed to reduce or
eliminate it?
In addition to brainstorming, the team also
engages in problem solving. The most important
activity in problem solving is to maintain
communication among the team members.
Without communication, participants will not feel
involved in the process and will lose interest.
Because ideas and learning occur through
dialogue and discussion, maintaining a sense of
ownership among the team members is a crucial
component for success. As the problem solving
process takes place, some obvious problems will
be identified. Those can be fixed immediately
while the team continues to look upstream in the
process for sources of waste. Throughout the
planning process the team will need to
document progress as it occurs and problems
that arise. Equally important will be to monitor
changes in production levels and customer
needs, as these can affect the direction that
pollution prevention planning takes.
13
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Step Three! Determine the Baseline
Any benchmark or baseline should be expressed
as a pollution to production ratio. It will also be
used to determine the cost of the pollution per
unit of product.
A baseline needs a relevant unit of product for
each product that is manufactured with the
chemicals being studied. The unit of product
must be an accurate measure of a characteristic
of the product. If a process is used for the same
part all the time, then number of pieces will
make a good unit of product. However, if the
process works on several parts, then a more
specific measure will be needed, such as surface
area or weight.
Units of Measure
How much waste is produced per product?
Identifying the correct means of measuring the
performance of a manufacturing process is one of
the most important steps in pollution prevention
planning. The measurement accurately portrays
what is happening in the process and provides
meaningful data to use in the options analysis
step. Without measurement, pinpointing and
solving problems would be difficult, as would
documenting the impact of pollution prevention.
Feedback from measurement will also help in
making decisions on facility policies, developing
new technologies, and choosing additional
pollution prevention options.
The unit of product must be carefully chosen.
Generally, valid units of product are count
(numbers of pieces), surface area (square feet),
volume (cubic feet), etc. Examples of units that
are nol valid are sales and run time. The unit of
product must relate directly to the product or
service being measured. In addition, in order to
obtain accurate data on the amount of pollution
generated during a production run or during a
measured time period, rejected product must be
included in the calculation of the production
volume. This is why sales is not a good indicator
of production rate. Conversely, run time is not a
good indicator of production because a machine
or a process may be operating, but product is
not necessarily being produced nor is waste
being generated. Sales underestimates
production volume and run time overestimates it.
The Production Ratio
It is necessary to develop a basis of comparison
for chemical waste generated in the production
process over time. Simply comparing waste
generated from year to year can be misleading
if there was a significant change in the levels of
production involving the chemical being
targeted. Production ratio (PR) is used to
normalize changes in production levels. It is
calculated by dividing the production level for
the reporting year by the production level for the
previous year. Once a production ratio is
determined, it is used as a factor when
comparing target chemical waste generated
between the two years.
Production Ratio Example
Production level change
none
10% increase
10% decrease
PR
1
1.1
0.9
Note: A good resource for determining production ratio:
Malkin, M., Baskir, J. (1997). Developing and Using Production
Adjusted Measurements of Pollution Prevention. U. S.
Environmental Protection Agency, order it
(EPA/600/R-97/048). To order call 513-569-7562.
Example 3-1:
A facility paints 1,600 parts in 1997. It paints
1,800 parts in 1998. The production ratio is:
1,800/1,600=1.13
Simply using units to determine the PR may
not give an accurate result if the parts are not
identical. In that case, a more specific
attribute must be used such as surface area,
weight or other relevant measure.
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Example 3-2:
A facility fabricates control housings from
sheet metal. There are two production lines in
operation. One fabricates the front panel
and the other fabricates the sides and back
of the housing. The exteriors of the two parts
are coated and then screwed together. The
exterior surface area of the front panel is 12
square inches and the exterior surface area of
the back and sides is 36 square inches.
Number of parts manufactured:
1998
1997
1,093
Line 1 (front panels) 1,254
Line 2
(back and sides) 1,208 1,006
Note: numbers include parts rejected
Total surface area coated per production line
(sq. in.):
Line 1
Line 2
Totals:
1998
15,048
43,488
58,536
1997
13,116
36,216
49,332
The Production Ratio is:
58,536/49,332=1.19
Data Gathering
Either during or after a team has been
organized, the performance of the current
manufacturing processes must be determined. As
a minimum, the processes that use or generate
TRI chemicals are targeted for pollution
prevention. This will be critical for the team to
calculate a baseline for future comparisons and
must be done prior to options analysis. An
important first step is to decide the accurate and
relevant units of measurement for the processes
involved. The next section provides more details
on measuring waste and pollution generation.
Data Gathering for Current Operations
For each and every process that uses a chemical
reportable on the TRI Form R, gather and verify
information related to the chemical's waste
generation and releases. This information must
be comprehensive in order to be as accurate
and useful as possible. It should include
information related to the product being
manufactured, the process, the volume produced,
and all associated costs.
Product Data - There should be a description of
the product(s) or service(s) related to the
chemical being addressed. This may include
information about desired quality and the reason
why the product manufacture requires the use of
a TRI chemical. Customer input may be desired or
required for specifications. Pollution prevention
planning is a good way to question the design
of a product and ask why the chemical is
needed. Are there customer specifications or
product quality issues that need to be
considered? These will be factors when options
are analyzed for pollution prevention.
Process Data - In order to further pinpoint how
and why a chemical waste is being generated,
process information must be gathered. Data on
the process should include a description of the
major steps.
Finding out how employees are involved in the
process is often helpful. This can include
information on employee function, training and
safety/health considerations. Also, obtain
whatever documentation is available about the
process such as vendor literature, chemical
analysis, preventive maintenance schedules,
equipment specifications, etc. Any or all of the
information will be needed for the options
analysis step that studies the alternatives for
making the process more efficient, thereby using
less raw material or generating less waste or
pollution.
Chemical Handling Data - Because waste can be
generated as a result of transfers and spills, data
should be gathered on how chemicals are
stored, transferred, packaged and otherwise
dispensed. These operations may be a part of
the manufacturing process or they may be
auxiliary operations that occur elsewhere in the
facility.
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Cost Data- During option analysis, in order to
calculate the costs, savings and payback of any
pollution prevention changes must be gathered
on all operations that involve the TRI chemicals
in question. Many hidden costs in the use of a
chemical are instituted in overhead or
department charges. However, these numbers
must be isolated and identified in order for the
option analysis to be comprehensive.
Some costs to consider are those related to
"environmental compliance." This includes
compliance issues such as analysis of waste,
treatment of waste, license fees and the cost of
disposal. As burdensome as these costs might
be, they are only a fraction of the cost to
manage TRI chemicals.
Many of these environmental compliance
functions can be done externally or internally. If
they are internal costs, remember to include the
cost of the time it takes staff to perform these
tasks.
Another cost is the purchase of the chemical. Add
to this the cost to transport the chemical. This
must include not only any external charges to get
the chemical to the facility but the internal cost to
transport it within the facility. Then add the cost
to store the material, including the cost of the
space it occupies.
Auxiliary costs to properly store and maintain the
chemical must be included. Add any cost for
temperature or humidity controls required for the
chemicals storage and use. In addition, there
might be costs to maintain the equipment that
stores or transports the chemical, including
preventive maintenance. Costs for risk
management: insurance to protect against losses
caused by accidental release and injury; health
and safety equipment and training requirements
so employees can work with the chemical as
safely as possible; and for some chemicals
significant costs due to absenteeism caused by
perceived or real health effects of the chemical.
Finally, intangible costs should be assessed and
recorded by asking:
• Are there any community concerns?
• Are there employee health or safety concerns
about using the chemical?
• Are there emergency response concerns
regarding the use of the chemical?
• Does the chemical contribute to unpleasant
production work areas (i.e. odors)?
• Are there product marketing disadvantages?
In order to obtain a good baseline of the
present situation, all this information must be
gathered and be effectively organized. This can
be done with charts, graphs, matrices, etc. Each
facility will have a unique system to organize the
data to fit its needs.
Production ratios and baselines must be
determined for each process that generates the
chemical being studied.
In addition to determining a baseline for
measuring the cost of waste generation per unit
of product, it is also essential to identify and
document current and past pollution prevention
efforts. Documenting these will allow the
pollution prevention team to avoid repeating
work unnecessarily and also provides the
groundwork for future feasibility studies if changes
in technology or increasing costs of
environmental management make yesterday's
discarded ideas more attractive today.
Next is to sum all the chemical waste generated
data and divide it by the amount of production
that generated those chemicals. The result of
this operation is the amount of waste or pollution
that is generated per unit of product.
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Exomple 3-3:
From Example 3-1, toluene is used to thin the
point at one pound of toluene per gallon of
paint. This toluene is released to the air as
the paint dries. In 1997,100 pounds of
toluene was released in this way when the
1,600 parts were painted. So if 1997 is the
baseline year, the pollution to production
ratio is 100 divided by 1,600 or 0.063 pound
of toluene released per part painted. If the
toluene costs a dollar per pound, the cost is
6.3 cents per part painted.
During 1997, tests were performed and it was
discovered that paint quality did not
deteriorate by using 0.80 pound of toluene
per gallon of paint. This reduced use of
toluene per gallon of paint released 90
pounds in 1998. The pollution/production
ratio is 90 divided by 1,800 or 0.05 pound of
toluene released per part painted, and the
cost is 5 cents per part. So compared to the
baseline year, this is a savings of 1.3 cents per
part, or $23.40 for 1,800 parts.
Sources for Data Gathering of Waste and
Pollution Information
Waste generated from production processes can
assume a variety of forms. Most notable among
these are air emissions, process wastewaters,
hazardous waste and scrap. It is important to be
aware of all forms of waste that are produced
through manufacturing to ensure an accurate
assessment of a production process. One good
approach for gathering this information is to
develop a material balance or process map for
target chemicals to account for each waste
stream that comes from the process. This can
start with a sketch showing the flow of raw
materials, products, wastes and releases
involving the target chemical. Make sure to
include streams for wastes that are recycled,
treated or otherwise managed on-site.
A common engineering principle is that what
goes into a system must come out in some form
or another. By measuring the material inputs, the
total outputs that must be accounted for can be
identified and through process of elimination, the
unknowns can be determined. In some cases, the
data needed to fully measure the amount of
each waste stream may not be available. In
these cases, it becomes necessary to use
engineering judgement and knowledge of the
production process to develop reasonable
estimates of how the system is operating. This
occurs more often with water and air releases,
particularly "fugitive" (non-stack) air releases.
Hazardous Waste - The primary information
source for waste shipped off-site, whether to be
recycled, treated, or disposed, is the hazardous
waste manifest. The manifest provides the type
and quantities of hazardous wastes shipped. For
mixed wastes or sludges that contain target
chemicals, a useful tool for determining the
fraction of the mixture that consists of the target
chemical is to review the waste profile submitted
to the off-site hazardous waste management firm
when the waste stream was approved for
acceptance. The waste management firm your
facility is contracted with should supply, upon
request, copies of the results of waste analysis
that was performed when a shipment was
received.
Scrap - Information for scrap waste can be found
on the bill of lading for each shipment. These
are often used in place of the hazardous waste
manifest for wastes such as scrap metals, scrap
circuit boards or spent lead-acid batteries that
are sent to a metals recycler. Similar to the
hazardous waste manifest, it will provide the type
and quantities of scrap materials shipped.
Product design specifications may be needed to
help estimate the amount of the target chemical
contained in the total waste shipped.
Wastewater Discharged to POTW - To discharge
wastewater to a publicly-owned treatment works
(POTW) generally requires an Industrial Discharge
permit, which will include limits on the pollutant
concentrations allowed in the wastewater
discharge. Facilities are required to perform
periodic sampling and analysis of their
wastewater discharge to ensure compliance with
the limits set. This information can also be used
to estimate annual levels of a target chemical
that is discharged to a POTW by using the
concentration levels determined in sampling
along with the cumulative volume of wastewater
discharge from the facility. Some facilities
perform in-house sampling and analysis on a
17
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more frequent basis than required by their
permit. These results provide a good tool for
estimating the volume of a target chemical that is
discharged to a POTW.
Stack Air Emissions - Facilities that are required to
hold air emissions permits should find that their
permit application contains a great deal of
information to help estimate a target chemical's
volume of releases through stack air emissions.
Each manufacturing process that vents emissions
through a stack is required to be thoroughly
described in the air permit application, with
information regarding the chemicals used, the
throughput of the process and the emissions
associated with the process. The calculations
contained in an air permit application are
performed on a basis for "potential to emit,"
which assumes constant operation of the
manufacturing process equipment and does not
include emissions reductions due to pollution
control equipment. Therefore, any use of air
permit application data must include
appropriate changes to reflect the actual
operating conditions of the process.
Facilities that are not required to hold air
emissions permits may estimate their stack air
emissions using their knowledge of process
conditions and materials balances. Quarterly or
annual tests of stack emissions may be
worthwhile to perform to provide data to
compare to estimates.
Fugitive Air Emissions - Fugitive (non-stack) air
emissions can be difficult to determine directly.
They are commonly estimated through a
materials balance with fugitive emissions
representing the last remaining unknown after all
other outputs have been directly measured or
estimated. If a facility employs an industrial
hygienist, he or she may have information on
employee exposure levels that can also be used
in estimating fugitive air emissions.
On-site Waste Management - There are several
ways that wastes are managed on-site. Some
wastes can be recycled, such as spent solvents or
used oils and lubricants. Most facilities keep
track of how many batches are processed by the
recycling equipment or of the amount of
regenerated material. Also track the amounts of
solvents, used oils, or other flammable materials
that are incinerated on-site. These should be
identified in the air emissions permit application.
Other wastes are treated on-site prior to
disposal, such as spent acids and caustics or
polymer waste. Information for measuring the
amounts of waste generated should be
obtained either from the treatment process
description, or from direct observation of the
process.
Some employees may be hesitant to take all of
the necessary steps involved in gathering the
information needed for a complete material
balance, as it can initially appear to be a
daunting task. A recommended first step in
performing the material balance is to simply
document material inputs minus the materials
included in the product stream. This result will
show the amount of waste that is generated and
can serve as a driving force for finding the
specific sources of waste in a process.
Step Four! Determine and Analyze
Alternatives
Once there is a good baseline of how the
present processes generate waste or pollution
and how much it costs, options for reducing these
may be explored. The analysis of these options
can be done concurrently with the gathering and
analysis of the data, but a meaningful options
analysis will need the data analysis done and a
baseline determined before the options can be
effectively screened.
Options analysis is the heart of the pollution
prevention planning process. All other steps and
all benefits will be affected by how well
this step is done.
Options analysis should include an examination
of all the methods of pollution prevention
covered in Chapter 2: Looking at substitutes for
the chemical, how the chemical moves through
the manufacturing system, how a process is
performed, automation and alternative
technologies for the manufacture of the product.
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This analysis may also include developing
criteria for determining which alternatives may be
implemented. These will depend on the culture
of the company and other factors. However,
some tangible factors to consider are how much
an alternative will reduce Form R reporting
requirements, how much an alternative will
reduce hazardous waste generation and the
return on investment for a project. Other
considerations include compatibility of the
pollution prevention option with the current
manufacturing process, ability to maintain
product quality requirements and storage or
process layout considerations.
Just like costs associated with current
manufacturing processes that are determined in
the baseline research, costs will be associated
with each pollution prevention idea and should
be considered during options analysis. Among
these include costs for design, testing and
implementation. These should be weighed
against the savings that would result if the option
is selected. Savings can come from reductions in
chemical purchases, compliance costs and
disposal costs. Changes in labor cost should also
be taken into account.
Tap all the available public and private resources
for information on alternatives and how they
meet your criteria. These include technical
assistance sources such as the Minnesota
Technical Assistance Program (MnTAP), the
Minnesota Office of Environmental Assistance
(OEA), trade/professional groups, trade
publications and vendors. In addition, regulatory
agencies can help determine how alternatives
may impact compliance and fees.
After a complete options analysis, the option(s)
that meet the criteria for acceptance should get
a final verification for feasibility. The reasons
that the other options were not selected should
be obvious at the conclusion of the analysis.
Each step of the options analysis needs to be
documented, including whether options are
rejected on technical or economic grounds. By
maintaining records of all options that have been
explored and why some were rejected, it will be
easier to revisit these should future
developments warrant further consideration.
Step Five! Set Objectives for
Implementation
Once the most promising option(s) has been
chosen for implementation, objectives can be
determined. Some broad objectives may have
already been set during the formation of the
pollution prevention team or policy development
at the start of the planning process. In that case,
this stage can consist of refining those objectives
and developing the implementation schedule for
the option(s) chosen. But whenever the
objectives are set, they should have the following
characteristics.
As detailed in Minnesota statute 1150.07(5), the
objective(s) should be numeric. The TPPA allows
non-numeric objectives if it is not possible to
establish numeric objectives. However, they must
include a clearly stated list of actions designed
to lead to establishing numeric objectives as
soon as feasible. A good starting point for
objective setting may be with the waste
generation levels reported on the TRI Form R.
The objective should state the planned
reduction in the TRI waste generation for the
chemical involved. It should be clear how this
reduction relates to the waste generated per unit
of production. Remember that pollution
prevention requires not the absolute reduction
of waste generated, but the reduction of waste
generated per unit of product.
The objective should state the schedule for the
planned reductions. This may include the use of
a timeline or other tool to clarify when
implementation is planned. The objective
should state how much the organization may
benefit as a result of full implementation. This
may include not only cost savings, but other
tangible and intangible benefits upon reaching
the objective. In addition, all assumptions and
rationale used in setting these objectives should
be documented in the plan.
Finally, list the options that were not chosen for
implementation and brief summary explaining
why they were not selected.
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Objectives are not legally binding or
enforceable in any way by any organization.
They should be considered as reasonable yet
challenging goals that will make a process or
company more profitable.
Step Six! Certification
Two company officers must put their signatures on
the plan to certify the accuracy of it. In almost all
cases, this will NOT be the environmental
manager. It can be the facility or general
manager, the president, a vice-president, or
other responsible ranking position. For a sole
proprietorship, the owner's signature will suffice.
20
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Chapter 4 - Pollution
Prevention Progress Reports
Monitor Progress
As implementation ensues, data should continue
to be gathered to compare against the original
baseline. This will show actual reductions and
savings and will be needed to generate the
progress report. Pollution prevention planning is
an on-going, cyclic process.
Pollution Prevention Progress Report
Requirements
Pollution Prevention Progress Reports (P2PRs) are
required to be submitted in conjunction with the
Form R for each chemical reported.
Every year, each facility should get a preprinted
or electronic progress report form from the
Emergency Response Commission (ERC). Basic
facility information should be preprinted on the
forms based on information currently in the ERC
database. If the information is incorrect, changes
should be made in the appropriate places on
the form.
The five requirements of the progress report are
explained below. Refer to the progress report
instructions for details on how to prepare it.
1. Summary of each objective
Each chemical reported must have a pollution
prevention objective in the plan. Summarize
these objectives and their schedules for
implementation in the progress report.
2. Summary of progress made for each
objective
Indicate what progress has been made, even
if none has been made. This should include
the amount of generation or releases reduced
per unit of production.
3. Methods used to reduce pollution
Describe how pollution prevention was
implemented.
4. Obstacles to reaching objectives
Describe any barriers in implementing
pollution prevention objectives.
5. Certification
The P2PR forms need to be certified by a
facility manager (defined as the highest
ranking manager responsible for operations/
production at the facility) and by a
responsible officer (defined as the company
officer with responsibility for facility
management and who is authorized to certify,
on behalf of the company, that all statements
are believed to be true, accurate, and
complete). Both certifications should be
accompanied by the date of certification and
a phone number for contacting the signatories.
How Pollution Prevention Progress
Report Information Is Used
Pollution Prevention Progress Report information is
summarized with Toxic Release Inventory data in
the annual ERC Right-To-Know Chemical
Information Report (Form R). This report is
prepared to provide citizens awareness about
toxic chemicals in their communities and enhance
accessibility to data.
OEA and MnTAP review the P2PRs for the
purposes of understanding statewide trends,
targeting technical assistance and identifying
companies who have had success, including
those who could be candidates for the Governors
Awards for Excellence in Pollution and Waste
Prevention.
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Appendix
Pollution Prevention Planning
Assistance Programs
In addition to planning requirements, the TPPA
also features provisions for establishing a
pollution prevention assistance program, known
as the Minnesota Technical Assistance Program
(MnTAP). The Minnesota Office of Environmental
Assistance (OEA) coordinates a Governors Awards
for Excellence in Pollution and Waste Prevention,
and an Environmental Assistance Grant program.
A pollution prevention fees collection program for
facilities that are identified as TRI reporters or as
large quantity generators (LQGs) of hazardous
waste is jointly administered by the ERC and the
OEA to help fund these programs.
Minnesota Technical Assistance Program
MnTAP implements the technical assistance
provisions of the Waste Management Act (WMA)
and TPPA. It is a non-regulatory organization that
helps businesses prevent pollution, manage
waste better and save money. MnTAP is located
at the University of Minnesota and has a staff
with a solid background in science and
engineering, plus many years of industry
experience. MnTAP's main services include:
On-site consultations to identify pollution
prevention opportunities.
A student intern program which helps companies
dive deeply into examining pollution prevention
problems and solutions.
Seminars, workshops, training programs and other
similar activities designed to provide pollution
prevention information and assistance.
From 1996 to 1998 MnTAP helped companies
reduce waste by over 48 million pounds and
save companies over $2.5 million.
To learn more about how MnTAP can assist in your
facility's pollution prevention and waste reduction
efforts, please contact them at 612-624-1300 or
at 800-247-0015 or visit their Web site at
www.mntap.umn.edu.
The Minnesota Office of Environmental
Assistance
The OEA is a service organization that helps
businesses, local governments, institutions and
others solve environmental problems.
The Governors Awards for Excellence in Waste and
Pollution Prevention honor private and public
organizations that have demonstrated
outstanding achievements in pollution and waste
prevention. Nominees are evaluated by a panel
of judges selected by the OEA. Judges are
chosen to represent industry, government, and
environmental and community organizations.
Applications are evaluated on environmental
and economic benefits, innovation, and
commitment and leadership displayed in the
area of waste and pollution prevention.
Preference is shown to applications and
organizations that can serve as models for others.
In addition to administering the Governors Awards
program, the OEA also administers an
Environmental Assistance Grant program.
Businesses and other organizations can apply for
grant funds for the purpose of researching,
developing, and implementing projects or
practices related to pollution prevention and
other environmental improvement initiatives.
Grant requests for proposal are sent out in July
each year, with applications due in October.
Since 1985, the OEA has awarded more than $10
million in grants to organizations throughout
Minnesota.
The OEA also can provide technical assistance
resources such as the DfE toolkit, which provides a
systematic method for incorporating
environmental attributes into the design of a
product.
For more information about the Governors Awards
program, the DfE toolkit or the Environmental
Assistance Grant program, please contact the
OEA at 651-296-3417 or at 800-657-3843 or visit
their Web site at www.moea.state.mn.us. The OEA
works with management and trade associations
to identify issues and barriers to implementing
pollution prevention.
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Pollution Prevention Fees
Pollution Prevention Fees ore used to fund the
state's technical assistance and research activities
with regards to waste reduction and pollution
prevention. As mentioned above, a portion of
MnTAP's funding comes from pollution prevention
fees. In addition, these fees also fund the states
efforts in identifying priority chemicals for
pollution prevention initiatives, as well as
identifying priority industries for offering technical
and financial assistance.
The pollution prevention fees program is
administered jointly by ERC and OEA. ERC
collects fees from TRI reporters and OEA collects
fees from large quantity generators (LQGs) of
hazardous wastes. The fees are calculated as
follows:
LQGs: Flat fee of $500 per facility.
TRI reporters:
5150 for each toxic pollutant reported to TRI, plus
$500 for facilities reporting less than 25,000
pounds of releases and off-site transfers or a
graduated fee of two cents per pounds for
facilities that report releases and off-site transfers
in excess of 25,000 pounds. (Releases and off-
site transfers are determined from the sum of
Section 5 and 6 from the EPA Form R reports
submitted by a facility.)
Example A-l:
A facility submits Form R reports for one
chemical, with total releases and transfers of
110,860 pounds. The fees due are:
a. 5150.00 for each chemical reported: 5150.00
plus
b. 50.02 per pound for > 25,000 pounds of
releases and transfers: 52,217.20
c. Total: 52,367.20
Example A-2:
A facility submits Form R reports for two
chemicals, with total releases and transfers of
20,873 pounds. The fees due are:
a. 5150.00 for each chemical reported:
5300.00
plus
b. 5500.00 for < 25,000 pounds of releases
and transfers: 5500.00
c. Total: 5800.00
Example A-3:
A facility submits Form R reports for eight
chemicals, with total releases and transfers of
960,784 pounds. The fees due are:
a. 5150.00 for each chemical reported:
51,200.00
plus
b. 50.02 per pound for > 25,000 pounds of
releases and transfers: 519,215.68
c. Total: 520,415.68
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Suggested Resources
The following ore only examples that barely scratch the surface of a very large and growing body of
literature on resource management, business management and quality.
Brown, K. (1993). Source Reduction Now. Minnesota Office of Environmental Assistance, (available at
www.moea.state.mn.us/berc/srn.cfm).
Callenbach, E., Capra, R, Goldman, L, Lutz, R., Marburg, S. (1993). EcoMonogement. Berrett-Koehler
Publishers, Inc.
Cattanach, R., Holdreith, J., Reinke, D., Sibik, L. (1995). The Handbook of Environmentally Conscious
Manufacturing. Irwin Professional Publishing.
Graedel, I, Allenby, B., (1995). Industrial Ecology. Prentice Hall Publishers.
Hawken, P. (1993). The Ecology of Commerce. HarperBusiness.
Malkin, M., Baskir, J. (1997) Developing and Using Production Adjusted Measurements of Pollution
Prevention. U.S. Environmental Protection Agency order # (EPA/600/R-97/048).
Mclnerney, R, White, S. (1995). The Total Quality Corporation. Truman Talley Books/Dutton.
Mullins, L. J. (1996). Management and Organizational Behavior. Pitman Publishing.
Prokop, M. (1992). Managing to be Green. Pfeiffer & Co.
Schonberger, R. (1982). Japanese Manufacturing Techniques. Rree Press.
Shiba, S., Graham, A., Walden, D. (1993). A New American TQM. Productivity Press.
Walton, M. (1986). The Deming Management Method. Perigee Books.
Willig, J. (1994). Environmental TQM. McGraw-Hill, Inc.
Yarwood, J., Eagan, P., Kurk, R (1998). Design for Environment Toolkit. Minnesota Office of
Environmental Assistance (available at www.moea.state.mn.us/berc/DREtoolkit.cfm).
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Please Note:
This is the first page of this Sample P2 Plan.
TABLE OF CONTENTS
Certification of Completeness 1
Executive Summary 3
Chapter 1 - Purpose 5
Chapter 2 - Policy Statement 7
Chapter 3 - Applicability and Scope 9
Chapter 4 - Description of Activity 11
Chapter 5 - Management Responsibilities and Practices 13
Introduction 13
Implementing the Pollution Prevention Plan 13
Provisions for Updating the Plan and Measuring/Reporting Progress 14
Hazardous Materials Management Procedures 15
Pollution Prevention Training and Awareness 16
Introduction 16
Scope 16
Policy 17
Program Responsibilities. 17
Awareness Requirements 19
Training Requirements 20
Project Completion Path 20
External Information Sources. 21
Training Sources 22
References 23
Publications 24
Chapter 6 - Planned Process Improvements 27
Pollution Prevention Proj ects 31
Vortex Generator Gun, 1234 TEELCM-01 31
Eliminate 1,1,1-Trichloroethane for Cleaning, CLSOGN-0.2 33
Particle Counter, PC-1236-TEHYEQ-01 35
Water Treatment Plant, MILCON-1237-FATRTW-O.l 37
Eliminate Chromic Acid Anodize Coating on Aluminum,
1238-COANCM-01 39
Aircraft Fuel Cell and Fuel Tank Repair, 1210-CLENOT-O.l 41
Aliphatic Naphtha Replacement, 1110-CLAEPC-O.l 43
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Table of Contents (cont'd) Page
Post Strip Solvent, 1110-COPRPT-02 45
Spray Paint Equipment Solvent, 1110-CLEQOT-O.l 47
Recycling P-D-680, 1241-RCSOOT-O.l 51
Substitution of Methyl Ethyl Ketone (MEK), 1243-CLSOGN-01 53
Substitution of Toluene, 1242-CLSOGN-01 55
Methylene Chloride Elimination/Replacement, 1300-READOT-02 57
Aircraft Fuel Systems Pressure/Leak Testing, 1233-TEFULK-01 59
Electrocoat Primer Demo, 1110-COPRPT-O.l 61
Powder Coat, 110-COPRPT-03 63
PMB/Chemical Strip, 1110-REPAAE-03 65
Cadmium Plating Replacement, COEPCD-0.1 67
Elimination of 1,1,1-Trichloroethane from Bearing Cleaning,
CLBEEN-01 69
Eliminate Freon-113 in Bearing Cleaning, CLBEEN-0.2 73
Eliminate Methylene Chloride in Bearing Cleaning CLBEENrQ3 77
Elimination of Methylene Chloride in Bearing, CLBEEN-.04 81
CircuitBoard Cleaning, 1300-CLELCB-01 83
PMB/Chemical Strip, 1110-REPAAE-O.l 85
Methylene Chloride Replacement, 1110-REPAAE-0.5. 87
Low VOC Coating, 1110-COPAAE-02 89
High Volume Low Pressure Paint Spray Guns, COPAEQ-0.1 93
Refrigerant Replacement, SFOPRF-0.1 99
Ultra High Pressure Waterjet Stripper, RECOGN-0.1 101
Methylene Chloride Elimination/Replacement, 1300-READOT-O.l 103
Eliminate Freon-113 from Instrument Bearing Cleaning,
CLSOCM-01 105
Elimination of Silver Cyanide Plating, COEPAG-0.1 107
Removal of Plated Metal Coatings, RECOEP-01 109
Eliminate Chromate-type Conversion Coating on Aluminum,
COINCV-01 Ill
Elimination of Chrome Containing Chemical Conversion Coating on
Magnesium, COINCX-01 113
Chapter 7 - Priorities. 115
Chapter 8 - Potential Barriers to Plan 117
Chapter 9 - Other Relevant Plan Requirements 119
Solid Waste Annual Report FY-94, Recycling Revenue. 121
Cost Avoidance (by Reducing New Product Procurement) 122
Cost Avoidance (by Reducing Landfill Disposal) 123
Coast Avoidance (by Reducing Hazardous Waste Disposal) 124
Total Revenues Received or Saved 125
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Table of Contents (cont'd) Page
Appendix A - Targeted Chemicals References. 127
NADEP Shop Survey Reports 129
in
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CERTIFICATION OF COMPLETENESS
I hereby certify to the best of my knowledge that this Pollution Prevention Plan meets the
requirements of Executive Order 12856. As documented by this plan, the Naval Aviation
Depot (NADEP) Jacksonville, as a tenant of the Naval Air Station, Jacksonville, Florida,
will reduce total production unit releases and off-sight transfers of toxic chemicals by 50
percent by the end of 1999. Based on 1994 data, I further certify that the information
provided herein is correct and complete, and that I have the authority to commit the
NADEP's corporate resources necessary to implement this plan.
D. S. RICE, Captain, USN Date
Commanding Officer
Naval Aviation Depot
Naval Air Station
Jacksonville, Florida
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NAVAL AVIATION DEPOT
JACKSONVILLE, FLORIDA
POLLUTION PREVENTION PLAN
EXECUTIVE SUMMARY
INTRODUCTION
Pollution prevention offers a cost-effective means of meeting environmental objectives
in an era in which federal facilities are subject to stricter levels of regulation, greater public
scrutiny of their environmental records, and tighter budgetary constraints. The cost of
failing to prevent pollution in the federal sector have become dramatically evident; in some
cases, cleanup costs are estimated in the hundreds of billions of dollars.
On August 3, 1993, the President signed Executive Order (E.O.) 12856 that directed
all federal agencies to comply with the Emergency Planning and Community Right-to-
Know Act of 1986 (EPCRA) and the Pollution Prevention Act of 1990 (PPA). The E.O.
emphasized that the Federal Government must demonstrate pollution prevention (P2)
leadership by improving facility management, incorporating environmental principles in
acquisition practices, establishing comprehensive P2 Plans, and developing innovative
technologies.
E.O. 12856 requires federal facilities to prepare P2 Plans. E.O. 12856 also calls on
federal agencies to develop a 50 percent reduction goal by 1999 for their releases of toxic
chemicals, with the baseline being no later than 1994.
The PPA establishes a new environmental management hierarchy as national policy.
This hierarchy, also incorporated into E.O. 12856, calls for the following:
* Pollution should be prevented or reduced at the source whenever possible;
* Pollution that cannot be prevented should be recycled in an environmentally safe
manner whenever feasible;
* Pollution that cannot be prevented or recycled should be treated in an
environmentally safe manner whenev feasible; and,
* Disposal or other release into the environment should be employed only as a last
resort and should be conducted in an environmentally safe manner.
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This Pollution Prevention Plan will implement our program to coordinate and manage
our P2 efforts which will minimize the adverse impact on human health and the
environment and meet the requirements of E.O. 12856.
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CHAPTER 1
PURPOSE
This Pollution Prevention (P2) Plan has been developed to assist the Naval Aviation
Depot (NADEP), Jacksonville, in reducing by a minimum of 50 percent, the release or
offset transfer of the toxic pollutants referenced in appendix A, based on production units.
This reduction, based on baseline 1994 data, will be achieved by 31 December 1999, and
will be accomplished by:
* Identification of the measures and management procedures that will be used to
comply with the requirements of DOD and DoN directives and federal, state, and
local codes, standards, and regulations.
* Identification of all majoprocesses that use toxic chemicals or generate hazardous
wastes that are transferred off-site; and,
* Development of technically and economically feasible options for reducing the
transfer of pollutants referenced in appendix A.
It is also the purpose of this plan to document past performance in the area of P2 and
to account for our current volume of work so that fluctuations in this important parameter
can be considered when measuring progress toward our goal.
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CHAPTER 2
POLICY STATEMENT
For the past 5 years, this command has supported the Naval Aviation Systems Team
policy that Pollution Prevention through source reduction is our primary strategy for
achieving compliance with environmental law. When source reduction is not possible, we
will recycle/reuse materials or capture and dispose of materials in an environmentally sound
and regulatory compliant manner. We will maintain solid relationships with our regulatory
agencies and we will promote environmental awareness among Depot personnel and
provide training to ensure understanding of our environmental goals.
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CHAPTER 3
APPLICABILITY AND SCOPE
NADEP Jacksonville is a tenant command of the Naval Air Station (NAS),
Jacksonville. This plan addresses all processes within the NADEP utilizing chemicals
referenced in appendix A and is a sub-set of the NAS Jacksonville P2 Plan. NAS
Jacksonville meets the definition of "facility" as defined by the Emergency Planning and
Community Right-to-Know Act (EPCRA) and is required to report toxic releases annually
to the Environmental Protection Agency (EPA) and to the State of Florida. NADEP
Jacksonville provides Toxic Release Inventory (TRI) reports to the NAS Facilities &
Environmental Department for inclusion in the NAS TRI report. Contractors working
within the Depot are regulated by the Regional Officer-in-Charge of Construction
Command (ROICC) residing aboard NAS Jacksonville. NAS Jacksonville and NADEP
Jacksonville are under the auspices of the following regulatory agencies:
* Environmental Protection Agency Region IV, Atlanta, Georgia
* Florida Department of Environmental Protection, Tallahassee, Florida
* Florida Department of Environmental Protection, Jacksonville, Florida
* Bio-Environmental Services, City of Jacksonville, Florida
* St. Johns River Water Management District, Jacksonville, Florida
The Naval Air Station as the host for NADEP Jacksonville, is the holder of all require
environmental discharge and operating permits concerning water and waste. Air permits
for the NADEP are held by the NADEP. Within Naval Air Station's purview, NADEP
operates under the environmental statutes and regulations as defined by the NADEP
Environmental Management Plan.
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10
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CHAPTER 4
DESCRIPTION OF ACTIVITY
The Naval Aviation Depot, Jacksonville, is a tenant command of the Naval Air Station,
Jacksonville, Florida. The base is located in the northeast corner of Florida along the
western bank of the massive St. Johns River on the southern edge of the City of
Jacksonville in Duval County. In 1939, the citizens of Jacksonville voted a million dollar
bond issue to purchase the site for the Naval Air Station, Jacksonville (NAS JAX). The
Naval Aviation Depot, Jacksonville (NADEP JAX), began operating in 1940 as an
Overhaul and Repair Department maintenance facility and during World War II there were
7,300 working at the facility, 4,500 of them military. Today, the Depot has a total land
area of 102 acres on NAS JAX and occupies 51 buildings having a total area of 36 acres.
NADEP JAX is today the largest industrial employer in Northeast Florida, employing over
3,200 civilian and 33 military personnel.
The mission of NADEP JAX is to provide a full range of the highest quality
maintenance, engineering, logistics, and support services to the fleet at a competitive price.
The mission is carried out under the authority of the Aircraft Maintenance Program
directives issued by the Naval Air Systems Command (NAVAIR). The NADEP performs
rework on aircraft, engines, avionics, aeronautical components, ground support equipment,
aircraft accessories and systems. These operations include Standard Depot Level
Maintenance (SDLM), emergency repair, overhaul, conversion, modernization, and
analytical rework. Support functions include evaluation and examination, testing and
calibration, manufacture of parts and equipment, inspection and flight test, preservation and
packaging, maintenance, automatic test equipment test equipment and electronic systems.
11
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12
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CHAPTER 5
MANAGEMENT RESPONSIBILITIES AND PRACTICES
INTRODUCTION
This chapter describes management roles, responsibilities, and practices for
implementation, tracking and reporting, training and awareness, and annual updating.
IMPLEMENTING THE POLLUTION PREVENTION PLAN
Implementation of the P2 Plan will be directed and coordinated as part of the NADEP
Environmental Management Plan (EMP). The EMP is a compilation of the aggregate
environmental goals and objectives of the various functional organizations within NADEP.
The EMP is managed by the NADEP Environmental Management Board (EMB) as defined
in the EMP with organizational structure shown on Figure(s) 5.1 and 5.2 of the EMP.
The EMB, headed by the Commanding Officer (CO), establishes policy and ensures
compliance with environmental regulations. The EMB is comprised of senior management
and is structured to assure close coordination of resources among the departments having
first line responsibility to execute the plan through technical and managerial efforts. The
EMB is supported by the NADEP JAX Pollution Prevention Team headed by the Director
of Operations with members from Materials Engineering (Code 340), Production
Engineering (Code 46), the Environmental Program Manager (Code 003), the
Environmental Control Center (Code 723), and the Occupational Safety and Health Office
(Code 001). This team reports monthly progress and brings to the EMB resources or other
issues impending progress for resolution. Team members have responsibilities
commensurate with their normal functions as follows:
* The Environmental Program Manager, working directly under the Commanding
Officer and Executive Officer, keeps the Command aware of current and pending
regulations and Depot compliance posture. Code 003 is also responsible for
translating regulations into functional requirements and ensuring the responsible
organization is aware of resulting environmental goals.
* Materials Engineering writes technical process requirements, tests and approves
new materials for implementation and advises the team on the technical feasibility
of using alternative processes. Assisting in this effort is the Lead Maintenance
Technology Center for the Environment (LMTCE) (Code 343), a NAVAIR
corporate resource residing at NADEP Jacksonville as a functional element of the
Materials Engineering Laboratory. The LfflCE serves as a focal point for
identifying and fulfilling NAVAIR requirements for compliance with environmental
regulations through P2 initiatives and leads in the development of the P2 Plan.
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* The NADEP Legal Counsel serves as a resource to the overall EMB and provides
legal advice on the meaning and intent of various environmental statutes and
regulations.
* Production Engineering designs, specifies, procures and installs equipment,
optimizes process and workflow, and plans for new wbtoad being accepted by
the Depot.
* The Environmental Control Center (ECC) is discussed below under "Hazardous
Materials Management Procedures".
* The Occupational Safety and Health Office ensures that all operations in the Depot
comply with local, state, and federal regulations to ensure worker safety.
The EMB will also be responsible for ensuring that the plan elements are included in all
installation Plan of Actions and Milestones (POA&Ms) and in the Program Objective
Memorandum (POM) process to ensure funding requirements are submitted for F Y-96 and
subsequent years.
PROVISIONS FOR UPDATING THE PLAN AND MEASURING/REPORTING
PROGRESS
As directed by the EMB, the NADEP P2 Plan will be updated annually by the end of
the first quarter of the calendar year. The update will require revision of the project
completion path for all Projects listed in Chapter 6 as well as documentation of any new
initiatives taken or planned since the last update. Annual summary reports will be issued to
NAVAIRSYSCOM in graphic form documenting the amount, in pounds, of emissions or
off-site transfers for the following:
* Hazardous Air Pollutants (HAPS)
* HAPS amounts broken out by EPA top 17 chemicals (minus Benzene)
* Class I and II ODS materials
* Resource Conservation and Recovery Act (RCRA) listed materials
* EPCRA chemicals
The success of the program will be measured in one or a combination of the following
methods:
* Changes in waste shipped off-site or treated on-site
* Changes in quantity of materials brought on-site
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* Changes in quantity of waste generated
* Analysis of changes made to specific processes
* Analysis of specific pollution prevention projects
* Changes in the amount of toxic constituents released
* Changes in material toxicity
* Changes in production levels that could affect material/waste levels
These changes will be reported and documented using a combination of the activity's
hazardous waste annual reports, material procurement records, toxic release inventory
Form R reports, and hazardous material authorized use lists.
Comparison of these reports with similar reports from previous years and TRI reports
will provide a method for measuring progress in meeting P2 goals.
HAZARDOUS MATERIALS MANAGEMENT PROCEDURES
NADEP Jacksonville's Environmental Control Center (ECC) is a leading edge
prototype for efficient management of the hazardous material life cycle. The ECC, located
in Code 723, controls the authorization, requisitioning, warehousing and physical
distribution of all hazardous materials used by the Depot. The ECC manages associated
programs such as the Hazard Communication Program (labels, Material Safety Data
Sheets, and the Authorized Use List), the Reutilization Program (diverting excess
HAZMAT from the waste stream), and the Emergency Response Program (NADEP spill
response team).
The ECC also manages the command's Hazardous Waste Program, servicing all waste
accumulation sites, screening waste containers for regulatory compliance, coordinating
waste stream testing, and transferring waste to the appropriate permitted storage facility.
Used oil is collected and recycled by the ECC, generating direct revenue and avoiding
waste disposal costs.
The ECC has implemented stringent controls on access to HAZMAT type and quantity.
The "Just-in-Time" concept stages HAZMAT in production shops in quantities sufficient to
meet short-term production requirements. When standard supply channels cannot provide
small enough containers, the ECC dispenses hazardous materials into new packages and
issues the appropriate quantities to production shops.
These controls have enabled a major reduction in HAZMAT procurement costs. From
a baseline of $7 million in FY-91, the ECC reduced the command's HAZMAT cost to $3.6
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million in FY-94. The reutilization program diverted $259K worth of HAZMAT from the
waste stream, and allowed a cost avoidance of $82K for waste drums. The used oil
recycling program generated savings of $412K over the same 3-year period. Conventional
recycling (paper, cardboard, plastic, etc.) generated another $15K. The total cost savings
(direct reduction + avoidance) achieved by the Depot over 3 years was approximately
$4.09 million. HAZMAT procurement costs have been reduced by almost 50 percent over
3 years with the command's workload remaining steady state.
The ECC is currently involved in implementing a new, state-of-the-art information
system that will allow on-line control and management of all hazardous material, chemical
processes, and hazardous waste streams. This system will also generate menu-driven
EPCRA reports (tier one, tier two, Form R). The system is designed to support a
pharmacy-type distribution system, permitting HAZMAT to be issued only as needed, and
only as authorized.
POLLUTION PREVENTION TRAINING AND AWARENESS
INTRODUCTION
Training and awareness are important elements of the Naval Aviation Depot (NADEP)
Jacksonville's Pollution Prevention Program. A solid training and awareness program will
promote sound management decisions and improve maintenance procedures. The result
will be less hazardous waste and significant cost reductions in operations. In keeping with
this understanding, NADEP will ensure that training is made available to its personnel at all
levels.
While top echelons of management will have the responsibility to drive programmatic
issues, many waste reductions will only be possible by training those at the shop level.
Since personnel in the shops are directly involved with using hazardous materials, training
them is a key to waste reduction at its very source. Training will also be provided for all
other personnel on base so there is a common understanding of the advantages of a
successful pollution prevention program.
In order for personnel at NADEP to stay aware of pollution prevention issues and what
they can do to make beneficial changes, management will foster an environment of
cooperation and proactive involvement amongst its various activities and supporting
contractors. At a time of dwindling human and financial resources, sharing ideas and
coordinating communication efforts will be a priority at NADEP.
SCOPE
This section of the pollution prevention plan will outline a Pollution Prevention Training
and Awareness Program. The goal is to provide a plan to educate personnel on pollution
prevention topics and to achieve measurable and significant reductions in the use of
hazardous materials through better communication.
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Specifically, the contents of this chapter will include an Introdiort, Scope, Policy,
Program Responsibilities, Awareness Requirements, Training Requirements, External
Technical Information Sources, Training Sources, References, and Publications.
A training matrix under the "Training Requirements" section of this chapter will
specifically detail what training will be provided to personnel. Project Completion Paths will
also be included in this section to outline the steps and completion dates for the development
of each training package identified or a schedule for hands-on training.
POLICY
Education about pollution prevention issues and technology will be made available to
help develop a common understanding of the advantages of a successful program and to
instill environmentally conscious thinking in everyday decision making. Educational materials
will include videos, posters, training guides, pamphlets, etc., developed in-house or through
outside government agencies and contractors.
PROGRAM RESPONSIBILITIES
The Pollution Prevention Training and Awareness Prograwill be managed by the
Environmental Program Manager (code 003). It will be the responsibility of the base
commanding officer and executive officer to make sure that this office has the resources and
command support to manage a successful program.
Management of the program by Code 003 will include the following responsibilities:
1) Staying abreast of pollution prevention issues and technology.
Staying current on pollution prevention issues and technology, and knowing what future
training and awareness is needed at NADEP will be accomplished three ways.
First, Code 003 will keep up-to-date DoD and Navy environmental training policies and
guidelines, and a variety of current environmental periodicals in an in-house library. These
government references, which are listed in the "References" section of this chapter, will be
used to comply with DoD and Navy goals. The periodicals listed in the "Publications"
section of this chapter will be used to provide insight into important pollution prevention
issues, as well as identify sources of information and training.
Second, Code 003 personnel will familiarize themselves with new industrial technologies,
materials and techniques that are scheduled to be implemented as a result of this plan. This
will be accomplished by coordinating their efforts with the Lead Maintenance Technology
Center for the Environment (LMTCE), Code 343 at the NADEP JAX. It will be Code O03's
responsibility to provide needed information or training materials to shop personnel to
support these industrial process improvements. Technical training and awareness materials to
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be developed are identified in the "Training Requirements" and "Awareness Requirements"
sections, respectively.
Third, Code 003 will establish and chair a Environmental Training Team (ETT) made up
of representatives who can assist with planning, coordinating and producing information
materials in support of the training and awareness program.
2) Update training and awareness materials as necessary to keep pace with changing
environmental regulations andfechnology.
At a minimum, all training and awareness materials will be updated every two years.
Code 003 will be responsible for maintaining accurate records to track the need for and to
schedule the development of new training and awareness materials to meet future
information needs.
The Naval Air Station Human Resources Office (HRO) will play a role in the Depot's
pollution prevention program. As a supporting agency, they will:
1) Maintain records of all pollution prevention training and awareness efforts
conducted on base.
HRO will keep records of all pollution prevention training conducted at NADEP. These
records will include information on how many hours of pollution prevention training are
given to each Depot employee and in what topic areas.
As previously mentioned, Code 003 will form a ETT to support training and awareness
efforts. This ETT will be made up of one member each from HRO (code 009T), and Depot
codes 003 (Environmental Program Manager), 343 (LMTCE), 005 (Public Affairs Office),
225 (Communications Services Branch), 723 (Environmental Control Center Branch). The
team's responsibilities will include:
1) Identify and coordinate the production of all future pollution prevention training
and awareness needed by Depot employees. That includes videos, posters and training
guides outlined for developmenlater in this plan.
The ETT will meet monthly to discuss training and awareness issues. Environmental
technical representatives will be responsible for identifying training and awareness
requirements. Other members will provide guidance on the costs and production elements
related to the training and awareness products discussed.
The type of information that will be conveyed to employees through the efforts of the
ETT will include:
a. The definition of pollution prevention
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b. The intent of Executive Order 12856
c. Department of Defense pollution prevention policy
d. The potential for pollution prevention to avoid costs, increase efficienq^prove
readiness, increase product quality, and reduce the risk of environmental non
compliance
e. New and emerging materials and technology, good ideas, and lessons learned by
neighboring activities that can be used to further source reduction
f. Command goals for reduction, including specific targeted chemicals and the inteof
the Depot's pollution prevention plan
g. The command's expectations of each individual who has a role in the pollution
prevention plan's execution
h. Progress toward the command's source reduction goals
AWARENESS REQUIREMENTS
Code 003 will make every effort to improve awareness of pollution prevention issues to
Depot personnel. Specific goals will include:
Goal 1 - Publish a pollution prevention related article in the base newsletteY^fwor^)
quarterly.
Goal 2 - Coordinate production of a poster with a pollution prevention theme at least
twice a year (the first poster is to be completed three months after receiving the final version
of this plan). The posters will be displayed throughout the Depot.
Goal 3 - Plan and conduct a special event in recognition of Earth Day each year. The
event will feature pollution prevention efforts at NADEP JAX.
Goal 4 - Publicize the pollution prevention incentives program in the Depot newsletter,
Plan of the Day, and flyers quarterly.
Goal 5 - Supply information on pollution prevention issues to the base Public Affairs
Office so it can be included in the base's weekly newslettefa^r Air News).
Goal 6 - Submit press releases quarterly to the local community newspapefi7(?m/a
Times Union) to keep the community abreast of pollution prevention efforts at NADEP
JAX.
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TRAINING REQUIREMENTS
In keeping with the commitment to offer pollution prevention training at all levels at the
Depot, NADEP JAX will provide the following training:
PROJECT COMPLETION PATH
NADEP PA2 PROGRAM VIDEO/GUIDE
ACTION
Define scope of worl
Identify who will
develop products
Develop products
Conduct Training
CODE
003/343/723
003/005/225/343/723
TBD
003/009T/A11 Codes
BCD
04/95
05/95
10/95
12/95
MH ESTIMATE
40
80
TBD
TBD
PROJECT COMPLETION PATH
NAVY ENVIRONMENTAL PROGRAM VIDEO
ACTION
Obtain video copies
Conduct training
CODE
003/NAVSEA
003/009T/A11 Codes
ECD
03/95
05/95
MH ESTIMATE
2
TBD
PROJECT COMPLETION PATH
HVLP SPRAY GUN USE
ACTION
Perform artisan
training
CODE
343/941/942/951/962
ECD
04/95
MH ESTIMATE
124
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PROJECT COMPLETION PATH
PARTICLE COUNTER USE
ACTION
Perform artisan
training
CODE
343/941/952/963
BCD
04/95
MH ESTIMATE
21
PROJECT COMPLETION PATH
VORTEX GENERATOR GUN USE
ACTION
Perform artisan
training
CODE
343/654/942/943/944
ECD
12/95
MH ESTIMATE
9
Special emphasis in the future will be placed on providing specific technical training to
those employees working in shops that use hazardous materials. Since these industrial
operations generate the vast majority of hazardous waste at the Depot, they are a key to
waste reduction at its very source.
EXTERNAL INFORMATION SOURCES
During the technical review of hazardous materials used at the Depot and the
development of this pollution prevention plan, a number of external activities were called
upon to lend assistance. Since they represent continuing sources of expertise in the area of
pollution prevention, they will be used by NADEP JAX in the future to answer questions or
offer advice. In addition, there are activities on board NAS Jacksonville that are included
that might be of assistance because of their unique capabilities or environmental role. They
include:
Naval Facilities Engineering Command
Southern Division
P.O.Box 190010
2155 Eagle Drive
North Charleston, SC 29419-9010
COM: (803) 743-0571
DSN: 563-0571
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Naval Supply Systems Command
Code 452
Washington, D.C. 20376-5000
COM: (703)607-0312
DSN: 327-0312
Naval Aviation Depot
Marine Corps Air Station
Cherry Point, NC 28533-5030
Attn: Code 354
COM: (919)466-7346
DSN: 582-7346
National Defense Center for Environmental Excellence
1450 Scalp Avenue
Johnstown, PA 15904
COM: (814)269-2803
Naval Facilities Engineering Service Center
1001 Lyons Street, Suite 1
Port Hueneme, CA 93043
COM: (805) 982-4897
DSN: 551-4897
Human Resources Office (Training & Services Dept.)
NAS Jacksonville
Jacksonville, FL 32212
COM: 772-3316
Navy Publishing & Printing Services Detachment Office (NPPSO)
NAS Jacksonville
Jacksonville, FL 32212
COM: 772-3447
Regional Environmental Coordinator (COMNAVAVNACTS JAX)
NAS Jacksonville
Jacksonville, FL 32212
COM: 772-5216
TRAINING SOURCES
In support of its training efforts, Code 003 will use existing DoD training when practical.
The following activities have been identified as the primary DoD environmental training
schools and will be sources of information regarding courses or training materials that have
been developed or are being developed:
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ARMY
Army Corps of Engineers, Army Environmental Training Support Center, P.O. Box,
1600, Huntsville, Alabama, 35807-4301, (205) 722-5837.
Army Logistics Management College (ALMC), Fort Lee, fginia, 23801-6040, (804)
765-4965, DSN 539.
Army Artillery Center and Fort Sill, Center for Environmental Initiatives and Hands-On
Training (CEIHOT), Fort Sill, Oklahoma, 73503-5100, (405) 442-2111, DSN 639.
NAVY
Naval School, Civil Engineer Corps Officers (CECOS), 3502 Goodspeed Street, Suite 1,
PortHueneme, California, 93043-3366, (805) 982-5655, DSN 551.
Naval Occupational Safety and Health, and Environmental Training Center, 9080 Breezy
Point Crescent, Norfolk, Virginia, 23511-3998, (804) 445-8778, DSN 565.
AIR FORCE
Air Force Institute of Technology (AFIT), School of Civil Engineering and Services,
Wright-Patterson Air Force Base, Dayton, Ohio, 45433-7765, (513) 255-8388, DSN 785.
Air Force School of Aerospace Medicine, 2513 Kennedy Circle, Brooks Air Force Base,
San Antonio, Texas, 78235-5123, (210) 536-3831, DSN 240.
REFERENCES
The following references will be included in Code 003's environmental library:
OPNAVINST 5090. IB, Environmental and Natural Resources Program
NTP X-90-9201, Environmental and Natural Resources Program Navy Training Plan
NTP S-40-8603B, Navy Occupational and Safety, and Hazardous Material Control
and Management Navy Training Plan
OPNAVINST 4110.2, Hazardous Material Control and Management
CNETINST 1500C, Catalog of Navy training courses
OPNAVINST 1500.8M, Navy Training Plan Process
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Directory of Environmental Training Courses (published by the Army Environmental
Training Support Center in Huntsville, Alabama)
PUBLICATIONS
Code 003 will sere as the base repository for a variety of environmentally-related
periodicals and other publications. Those to be kept will be determined by the Environmental
Program Manager. However, a suggested listing of possible publications to consider include
the following:
CFC-Halon News
NAVSEASYSCOM, Code 03VZ
2531 Jefferson Davis Highway
Arlington, VA 22242-5160
COM: (703) 602-0547
DSN: 332-0547
Air'/Water Pollution Report
Business Publishers, Inc.
951 Pershing Drive
Silver Springs, MD 20910-4464
Hazardous Technical Information ServictflttlS) Bulletin
Defense General Supply Center
8000 Jefferson Davis Highway
Richmond, VA 23297-5670
The Environmental Manager's Compliance Advisor
Business and Legal Reports, Inc.
39 Academy Street
P.O.Box 1523
Madison, CT 06443-9988
Environmental Manager
Executive Enterprises
22 West 21st Street
New York, NY 10160-0172
Environmental Products Guide
General Services Administration Centralized Mailing List Service (7CAFL)
P.O. Box 6477
Ft. Worth, TX 76115
24
-------
Marketips
General Services Administration Centralized Mailing List Service (7CAFL)
P.O. Box 6477
Fort Worth, TX 76115
Ozone Depleter
Thompson Publishing Group
1725 K Street, N.W., Suite 200
Washington, D.C. 20006
Clean Air Permits
Thompson Publishing Group
1725 K Street, N.W., Suite 200
Washington, D.C. 20006
RCRA Update
Waste Resource Associates, Inc.
2576 Seneca Avenue
Niagara Falls, NY 14305
Regulatory Update
JJ. Keller and Associates, Inc.
P.O. Box 368
Neenah, WI 54957-0368
The Minimizer
Naval Facilities Engineering Service Center (NFESC)
560 Center Drive
PortHueneme, CA 93043-3366
COM: (805) 982-4067
DSN: 551-4832
XCHANGE
Naval Aviation Depot
Naval Air Station
Jacksonville, FL 32212-0016
Attn: LMTCE, Code 343
COM: (904)772-2481
DSN: 942-2457
Federal Facilities Environmental Journal
Executive Enterprises Publication Company, Inc.
22 W 21st Street
New York, NY 10010-6904
25
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The Southerner
Government Supply Administration
8400 Tatum Road
Palmetto, GA 30268
26
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CHAPTER 6
PLANNED PROCESS IMPROVEMENTS
This chapter contains information relative to planned process improvements resulting
from analysis of the survey data packages shown in appendix B. The data packages were
generated by the shop artisans with assistance from the P2 Project coordinator from the
Regulated Processes Branch, Code 343. The packages contain documentation on processes
performed, materials used, and wastes generated in the shop. The materials list was then
compared to an eight-quarter report of materials actually ordered by the shop. A "targeted"
materials list for each shop was then generated for all materials used by the shop meeting the
criteria for prioritization as listed in Chapter 7. The amounts of materials used in each
process were then converted to "amount in pounds" in order to arrive at the desired units.
Due to a targeted material possibly appearing in numerous shops, it was decided that
elimination/substitution of these materials would be approached from a pollution prevention
project standpoint. The information contained in this chapter documents P2 projects in
process as well as planned, the associated project completion path and responsible parties,
and the shops within NADEP that will be affected by the project. A copy of the P2 Project
report is also inserted into the shop survey data package. The resulting P2 Projects and
project engineer/technician are as follows:
POLLUTION PREVENTION PROJECTS
PROJECT TITLE
1. VORTEX GENERATOR GUN
2. ELIMINATION OF
1,1,1 -TRICHLOROETH ANE
3. PARTICLE COUNTER
4 WATER TREATMENT PLANT
5. ELIMINATE CHROME ACID
ANODIZE COATING /ALUMINUM
6 AIRCRAFT FUEL CELL/TANK
REPAIR
7. NAPHTHA REPLACEMENT
8. POST STRIP SOLVENT
9. SPRAY PAINT EQUIPMENT
SOLVENT/CLEANER
PROJECT #
1234-TEELCM-01
CLSOGN-02
1236-TEHYEQ-01
1237-FATRTW-01
1238-COANCM-01
1210-CLENOT-01
1110-CLAEPC-Ol
1110-COPRPT-02
1110-CLEQOT-Ol
PROJECT LEAD
TERRY TAYLOR
JIM DIXON
CLARA HAGADORN
JOHN DINKINS
BRUCE MOBLEY
ANDREW YANG
CARIDAD ROQUE
CARIDAD ROQUE
CARIDAD ROQUE
27
-------
PROJECT TITLE
PROJECT #
PROJECT LEAD
10. RECYCLING P-D-680
11. MEK SUBSTITUTION
12. TOLUENE SUBSTITUTION
13. METHYLENE CHLORIDE
REPLACEMENT
14. AIRCRAFT FUEL SYSTEMS
PRESSURE/LEAK TESTING
15. ELECTROCOAT PRIMER DEMO
16. POWDER COAT
17. PMB/CHEMICAL STRIP
18. CADMIUM PLATING
REPLACEMENT
19. ELIMINATE 1,1,1-TRICH/
BEARING CLEANING
20. ELIMINATE FREON-1137
BEARING CLEANING
21. ELIMINATE METH CHLORIDE/
BEARING CLEANING
22. ELIMINATE METH CHLORIDE/
BEARING CLEANING
23. CIRCUIT BOARDS CLEAN
24. PMB/CHEMICAL STRIP
25. METHYLENE CHLORIDE
REPLACEMENT
26. LOW VOC COATING
27. HVLP PAINT EQUIP.
28. REFRIGERANTS REPLACEMENT
29. ULTRA-HIGH PRESSURE
WATERJET
30. METH-CHL /POTTING
REPLACEMENT
1241-RCSOOT-01
1243-CLSOGN-01
1242-CLSOGN-01
1300-READOT-02
1233-TEFULK-01
1110-COPRPT-Ol
1110-COPRPT-03
1110-REPAAE-03
COEPCD-01
CLBEEN-01
CLBEEN-02
CLBEEN-03
CLBEEN-04
1300-CLELCB-01
1110-REPAAE-01
1110-REPAAE-05
1110-COPAAE-02
COPAEQ-01
SFOPRF-01
RECOGN-01
1300-READOT-01
CARIDAD ROQUE
ANDREW YANG
ANDREW YANG
ANDREW YANG
LAURA ROSSI
HANK BIRDSONG
HANK BIRDSONG
STEVE HARTLE
MIKE ROMANELLI
ROLLEN/BROOKS
SOMORA/ROLLIN
BROOKS/ROLLEN
ROLLEN/SOMORA/PATIN
MIKE LINN
RICK BARNES
RICK BARNES
DAVID BROCK
DAVID BROCK
CLARK/GREY/WOOD
R. JOHNSON/S. HARTLE
MIKE LINN
28
-------
PROJECT TITLE
31. FREON-113 ELEMINATION/
INSTRUMENT BEARINGS
32. SILVER CYANIDE PLATE
33. REMOVAL OF PLATED METAL
COATINGS (ENSTRIP)
34. ELIMINATE CHROMATE
PROJECT #
CLSOCM-01
COEPAG-01
RECOEP-01
COINCV-01
CONVERSION COATING/ALUMINUM
35. ELIMINATE CHROME CHEMICAL COINCX-01
COATING/MAGNESIUM
PROJECT LEAD
JOYCE ROLLEN
MIKE ROMANELLI
ESRA McDANIEL
JOHN DEITZEL
JIM DIXON
29
-------
(Blank)
30
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Vortex Generator Gun
1234-TEELCM-01
Terry Taylor
(904)772-4519
343
PROJECT DESCRIPTION: Avionics components are often tested for thermal
intermittance using a CFC or HCFC freezing compound. Testing of a component cooler that uses
a vortex generator principal is complete and an Local Process Specification is currently going
through TDRS. Equipment requirements include hoses, filters, adaptors, and other vortex
generator guns. Line air pressure must be increased from current 30 PSI to 80 - 100 PSI.
RDT&E REQUIRED: Complete
SPECIAL FUNDING: None
PROJECT COST
EQUIPMENT
$287/station
INSTALLATION
4hrs/station
MATERIAL
-0-
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
Current material cost = $13.50/lb x 192 Ibs
$2,592
None
None
PROJECT COMPLETION PATH
ACTION
Issue LPS
Order Guns
Install
Implement
CODE
343
Shops (49)
650
49
ECD
10/94
03/95
10/95
12/95
MH
ESTIMATE
40
4
80
31
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Vortex Generator Gun
1234-TEELCM-01
Terry Taylor
TARGETED MATERIALS/PROCESSES
SHOP#
65400
94217
94217
94217
94243
94244
94342
94462
P
#
1
1
2
4
1
1
2
2
NUN
LL-HAZ-0495
01-333-1841
01-333-1841
01-333-1841
01-333-1841
01-333-1841
01-333-1841
01-333-1841
TOTAL
NOMENCLATURE
Freeze Mist li (Aerosol)
Freon, Quick Freeze
Freon, Quick Freeze
Freon, Quick Freeze
Freezing Compound
Freezing Compound
Freon, Quick Freeze
Freon, Quick Freeze
LBS
IN
1
12
12
12
6
5
18
126
192
LBS
OUT
1
12
12
12
6
5
18
126
192
LBS
SAVED
1
12
12
12
6
5
18
126
192
32
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Eliminate 1,1,1-Trichloroethane for Cleaning
CLSOGN-02
Jim Dixon
(904)772-4516/3444
342
PROJECT DESCRIPTION: CDS elimination - 1,1,1-Trichloroethane is used throughout
the Depot for handwiping and general'Tme" cleaning to remove residual oils, maskants,
fingerprints, and other contaminants. Implementation of water/detergent wash, isopropyl in
water, terpene-based cleaners and other non-ODS products will replace 1,1,1-Trichloroethane.
RDT&E REQUIRED:
SPECIAL FUNDING:
None; research complete.
PROJECT COST
EQUIPMENT
None
INSTALLATION
None
MATERIAL
None
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
PROJECT COMPLETION PATH
ACTION
Identify shops
Identify use/purpose
Provide alternatives
Follow-up
Issue report
CODE
340/03/723
340
340
340
340
ECD
11/94
01/95
02/95
04/95
06/95
MH
ESTIMATE
80
480
120
120
40
33
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Eliminate 1,1,1-Trichloroethane for Cleaning
CLSOGN-02
Jim Dixon
TARGETED MATERIALS/PROCESSES
SHOP#
94338
96225
95300
94325
TOTALS
P
#
NUN
292-9625
476-5613
476-5613
476-5613
NOMENCLATURE
1,1,1 -Trichloroethane
1,1,1 -Trichloroethane
1,1,1 -Trichloroethane
1,1,1 -Trichloroethane
LBS
IN
71.5
500
4179
1770
6520.5
LBS
OUT
71.5
500
4179
1770
6520.5
LBS
SAVED
71.5
500
4179
1770
6520.5
34
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Particle Counter
PC-1236-TEHYEQ-01
Clara Hagadorn
(904) 772-2457
343
PROJECT DESCRIPTION: CFC-113 or P-D-680 is currently used to dilute
hydraulic fluid samples for patch test analysis. A particle counter is a piece of electronic
equipment in which a hydraulic fluid sample is placed in the counter chamber where a tube
retrieves it and an electronic sensor counts the number of particles. This number is
displayed by channel on a LED display and the reading is matched to NAVAIR standards
for acceptance.
RDT&E REQUIRED:
SPECIAL FUNDING:
None, RDT&E is complete
$65K
PROJECT COST
EQUIPMENT
$ 65,000 (3 units)
INSTALLATION
$0
MATERIAL
$0
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
TBD
PROJECT COMPLETION PATH
ACTION
Procure Counters
CODE
343
ECD
03/94
10/94
09/95
MH ESTIMATE
24
35
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Particle Counter
PC-1236-TEHYEQ-01
Clara Hagadorn
TARGETED MATERIALS/PROCESSES
SHOP#
94121
94121
94121
95245
96351
TOTALS
P
#
1
2
3
1
1
NUN
00-274-5421
002745421
002745421
002858011
002745421
NOMENCLATURE
P-D-680
P-D-680
P-D-680
P-D-680
P-D-680
LBS
IN
24
74
74
353
4807
5332
LBS
OUT
24
24
74
353
4807
5332
LBS
SAVED
24
74
74
353
4807
5332
36
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Water Treatment Plant
MILCON-123 7-F ATRTW-01
John Dinkins
(904) 772-4455
624
PROJECT DESCRIPTION: Military construction projects have been established
for three hazardous waste sources to remove and/or recover contaminants at the source,
and hence eliminate discharge to the NAS Jacksonville industrial waste water treatment
plant and ultimately the St. Johns River. The three closed-looped projects eliminate the
discharge of:
(1) electroplating and metal cleaning waste streams, (2) chemical (wet) paint stripping and
metal finishing waste, and (3) paint waste. Treatment plants (2) and (3) are 100 percent
operational. Treatment plant (1) is under construction.
RDT&E REQUIRED: None
SPECIAL FUNDING: None
PROJECT COST
EQUIPMENT
$14.2M *
INSTALLATION
(Included in $1 4. 2M)
MATERIAL
* For Equipment and Installation for Treatment Plant (2) and (3)
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
Reduced operational/disposal cost by $300K
year
$750,000.00
PROJECT COMPLETION PATH
Note: None available for Treatment Plant (1)
ACTION
NAVFAC
SOUTHDIV
CODE
ECD
None
MH ESTIMATE
37
-------
PROJECT TITLE:
PROJECT NUMBER
PROJECT ENGINEER:
Water Treatment Plant
MILCON-123 7-F ATRTW-01
John Dinkins
TARGETED MATERIALS/PROCESSES
SHOP#
94111
94112
94344
96223
96225
96233
TP2&3
P
NUN
NOMENCLATURE
Hazardous Waste Sludge
LBS
IN
600K
LBS
OUT
LBS
SAVED
38
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
Eliminate Chromic Acid Anodize Coating on
Aluminum
1238-COANCM-01
Bruce Mobley
(904)779-3831
621
PROJECT DESCRIPTION: Currently, chrome is used for Type I anodize coating on
aluminum. The current process would require MACT in order to continue the operation. The
current process will be replaced with sulfuric boric acid anodize, a compliant process. Initially the
process will be prototyped in the Plating Shop area on the "J" line. Process will be expanded to
large scale operation by the end of CY-96 and fully implemented by the end of CY-97.
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
RDT&E REQUIRED:
SPECIAL FUNDING:
None; RDT&E is complete.
None available
PROJECT COST
(For prototype only)
EQUIPMENT
$25,000
INSTALLATION
$5,000
MATERIAL
$2,000
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
PROJECT COMPLETION PATH
ACTION
Acquire signed
license agreement
Procure materials
Retrofit tanks
Set up line
Prototype process
Issue instructions
Expand process
Implement
CODE
007
96225
600
96225
343/96225
342
46/342
ECD
02/95
02/95
03/95
03/95
05/95
05/95
12/96
12/97
MH
ESTIMATE
4
2
80
16
360
40
200
180
39
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Eliminate Chromic Acid Anodize Coating on
Aluminum
1238-COANCM-01
Bruce Mobley
TARGETED MATERIALS/PROCESSES
SHOP#
94113
TOTALS
P
#
NUN
00-264-3939
NOMENCLATURE
Chromic Trioxide
LBS
IN
1500
1500
LBS
OUT
1500
1500
LBS
SAVED
1500
1500
40
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Aircraft Fuel Cell and Fuel Tank Repair
1210-CLENOT-01
Andrew Yang
(904)772-4519
343
PROJECT DESCRIPTION: Aircraft fuel tank and fuel cell repair/overhaul require
general cleaning, cleaning prior to and after sealing/cementing. These cleaning solvents are used in
other non-fuel applications which require cleaning prior to other critical processes such as sealing,
cementing, bonding, coating, etc. The cleaning solvents/cleaners currently used are either ozone
depleting substances (ODS's) or hazardous air pollutants (HAPS). Alternative non-ODS and non-
HAP solvents/cleaners are currently available in industry, and will be recommended for these
applications.
RDT&E REQUIRED:
SPECIAL FUNDING:
Compatibility and mechanical testing
CDS Elimination Project ($75K fromNAWC-AD
Warminster
PROJECT COST
EQUIPMENT
-0-
INSTALLATION
- 0 -
MATERIAL
$3500
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
TBD
TBD
From ODS's & HAP's to non-ODS and non-
HAP
PROJECT COMPLETION PATH
ACTION
Identify
cleaners/solvents
Testing
Prototype
Implement
CODE
343
343
49
49
ECD
01/95
06/95
08/95
08/95
MH
ESTIMATE
120
250
80
80
41
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Aircraft Fuel Cell and Fuel Tank Repair
1210-CLENOT-01
Andrew Yang
TARGETED MATERIALS/PROCESSES
SHOP#
94120
94131
94131
94131
94131
94135
94135
94135
94135
94136
94136
94136
94136
94221
94325
94336
94337
94344
95300
95300
P
#
1
1
2
1
2
1
2
4
0
1
2
3
4
1
1
3
2
3
1
1
NUN
00-476-5612
00-664-0388
00-664-388
00-930-6311
00-306-11
00-2812-762
00-2812-762
00-281-2762
00-2812-762
00-664-0388
00-664-0388
00-6640-388
00-6640-388
00-6640-388
00-4765-613
00-476-5612
00-476-5612
00-476-5162
00-476-5613
00-551-1487
Total
NOMENCLATURE
1, , -Trichloroethane
1, , -Tricholorethane
1, , -Tricholorethane
1, , -Tricholorethane
1, , -Tricholorethane
Methyl Ethyl Ketone
Methyl Ethyl Ketone
Methyl Ethyl Ketone
Methyl Ethyl Ketone
1,1,1 -Trichloroethane
1,1,1 -Trichloroethane
1,1,1 -Trichloroethane
1,1,1 -Trichloroethane
Solvent, 1,1,1-Trichloro thane
Solvent, 1,1,1 -Trichloroethane
1,1,1 -Trichloroethane
1,1,1 -Trichloroethane
1,1,1 -Trichloroethane
Solvent, 1,1,1 -Trichloroethane
Solvent, 1,1,1 -Trichloroethane
LBS
IN
80
200
24
32
20
50
10
10
70
5
5
5
5
325
1770
28
27
55
2969
1210
6900
LBS
OUT
80
200
24
32
20
50
10
10
70
5
5
5
5
325
1770
28
27
55
2969
1210
6900
LBS
SAVED
80
200
24
32
20
50
10
10
70
5
5
5
5
325
1770
28
27
55
2969
1210
6900
42
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Aliphatic Naphtha Replacement
1110-CLAEPC-Ol
Gary Roque
772-4519
343
PROJECT DESCRIPTION: Aliphatic naphtha, TT-N-95, is widely used to clean aircraft
and components prior to painting to remove heavy organic soils. Moreover, naphtha is the only
approved solvent for cleaning canopy transparencies. The CAAA Aerospace NESHAP will
impose compliance with either composition requirements or have a vapor pressure less than 45
mm Hg for these types of hand-wipe cleaning operations. Because of distillation procedures, TT-
N-95 contains certain per cent of haps; also, its vapor pressure is higher than the 7 mm Hg allowed
for petroleum distillates.
RDT&E REQUIRED:
SPECIAL FUNDING:
Materials compatibility and performance
$34,120
PROJECT COST
EQUIPMENT
None
INSTALLATION
None
MATERIAL
1000
YEARLY CBA: TBD
ANNUAL DISPOSAL COST: TBD
MEDIA SHIFT: TBD
PROJECT COMPLETION PATH
ACTION
Application testing
Shop prototype
Compatibility testing
Issue instructions
Implementation
CODE
343
343/003/72300/
applicable shops
343/NAWC
343
343/applicable
shop/72300
ECD
04/95
08/95
08/95
09/95
10/95
MH
ESTIMATE
80
120
80
18
60
43
-------
PROJECT TITLE
PROJECT NUMBER:
PROJECT ENGINEER:
Aliphatic Naphtha Replacement
1110-CLAEPC-Ol
Gary Roque
TARGETED MATERIALS/PROCESSES
SHOP#
94115
94116
94116
94116
94242
94242
94337
94342
95113
96226
TOTALS
P
#
1
2
o
J
5
1
2
1
2
1
3
NUN
00-265-0664
00-265-0664
00-265-0664
00-2650664
00-238-8119
00-238-8119
00-238-8119
00-265-0664
00-265-0664
00-265-0664
NOMENCLATURE
TT-N-95
Naphtha
Naphtha
Naphtha
Naphtha, Aliphatic
Naphtha, Aliphatic
Naphtha
Naphtha
Naphtha
Naphtha
LBS
IN
2811
415
277
185
8
7
18
44
94
188
4047
LBS7
OUT
2108
311
208
139
6
5
14
33
71
141
3036
LBS2
SAVED
2811
415
277
185
8
7
18
44
94
18S
4047
NOTE: 1 Assume 25% loss due to evaporation i.e. emitted to the air.
2 Assume that pounds saved will be pounds of high vapor pressure
solvent saved by substituting with compliant material.
44
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Post Strip Solvent
1110-COPRPT-02
Gary Roque
(904)772-4519
343
PROJECT DESCRIPTION: Currently the only suitable solvent for cleaning residual
primer from aircraft exteriors after stripping and stripper residue contains approximately 35%
Hazardous Air Pollutants (HAP). The CAAA Aerospace NESHAP will require that this material
be changed to a hap-free solvent or that hard controls be placed over the operation to capture
pollutants in addition to extensive daily reporting. This project will attempt to define a new
method of removing primer and stripper residues after stripping operations with zero hap content.
RDT&E REQUIRED:
SPECIAL FUNDING:
Evaluate alternatives
37,000
PROJECT COST
EQUIPMENT
None
INSTALLATION
None
MATERIAL
1000
YEARLY CBA:
ANNUAL DISPOSAL COST: TBD
MEDIA SHIFT: TBD
PROJECT COMPLETION PATH
ACTION
Test plan
Application testing
Compatibility
Prototype in shop
Evaluate feasibility
Write instructions
Implement
CODE
343
343
343/NAWC
343/94111
343/003
343
003/72300/94111
ECD
01/95
05/95
05/95
07/95
06/95
08/95
09/95
MH
ESTIMATE
60
120
120
40
13
16
20
45
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Post Strip Solvent
1110-COPRPT-02
Gary Roque
TARGETED MATERIALS/PROCESSES
SHOP#
94111
94111
94111
TOTALS
P
#
1
2
o
J
NUN
00-165-5592
00-165-5592
00-165-5592
NOMENCLATURE
Thinner, Butyrate
Thinner, Butyrate
Thinner, Butyrate
LBS
IN
3285
6570
9855
19710
LBS1
OUT
1149.75
2299.5
3449.25
6899
LBS2
SAVED
3285
6570
9855
19710
NOTES:
Pounds out are only those released into the air and are estimated from
evaporation, assuming 35% (by wt.) hazardous air pollutants content.
The rest of the material is currently processed through the closed-loop
water treatment plant.
Pounds saved refer to pounds of non-compliant solvent saved by
substituting with a compliant solvent.
46
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Spray Paint Equipment Solvent
1110-CLEQOT-Ol
Gary Roque
(904)772-4519
343
PROJECT DESCRIPTION: Paint gun cleaning is currently carried out using either MIL-
T-81772 paint thinner or MIL-T-6096 , Butyrate solvent. Both solvents contain hazardous air
pollutants (HAP). The CAAA Aerospace NESHAP will not only require that paint guns be
cleaned in a closed paint gun washer, but it will also require that the cleaning solvent be either a
HAP-free solvent or extensive daily reporting will be mandated.
RDT&E REQUIRED: Prototype, at a production scale, proposed HAP-free
alternative.
SPECIAL FUNDING: 49,080
PROJECT COST
EQUIPMENT
1,000
INSTALLATION
1,000
MATERIAL
1000
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
$422 (See calculation and note at the end)
$3149
TBD
PROJECT COMPLETION PATH
ACTION
Test plan
Application testing
Prototype in shop
Write instructions
Full implementation
CODE
343
343/72300
343/941 15/941 167
96226
343
343/72300/96226/
94116/95113/003
ECD
02/95
03/95
09/95
09/95
10/95
MH
ESTIMATE
24
80
344
24
40
47
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Spray Paint Equipment Solvent
1110-CLEQOT-Ol
Gary Roque
TARGETED MATERIALS/PROCESSES
SHOP#
96226
96226
96226
96226
96226
94116
94116
94116
95113
TOTALS
P
#
1
6
7
6
7
2
4
6
1
NUN
00-165-5591
00-165-5591
00-165-5591
00-165-5591
00-165-5591
00-165-5592
00-165-5592
00-165-5592
00-165-5591
NOMENCLATURE
Thinner, Butyrate
Thinner, Butyrate
Thinner, Butyrate
Thinner, Butyrate
Thinner, Butyrate
Thinner, Butyrate
Thinner, Butyrate
Thinner, Butyrate
Thinner, Butyrate
LBS
IN
35
35
35
35
35
754
660
1697
212
3498
LBS
OUT
35
35
35
35
35
754
660
1697
212
3498
LBS1
SAVED
12.25
12.25
12.25
12.25
12.25
263.9
231
593.95
74
1224.1
NOTE: 1. Pounds saved refers to pounds of HAP saved that otherwise would be
emitted to the air via evaporation (assume 100% evaporation old; 35% hap
content by weight) of the cleaning solvent.
COST BENEFIT ANALYSIS
Specific gravity of MIL-T-6096:
Specific gravity of proposed alternative:
Cost of disposal:
7.17Lb/gal
7.46 Ib/gal
$1.20 per pound (same cost for both materials
since RCRA i.e. flash point less than 140 deg F.
Cost of business now:
3498 Ibs used of butyrate = 488 gallons
Assume 25% loss due to evaporation during handling (vapor pressure appr. 76 mm Hg) :
488 gal - 25% (loss) = 366 gal used and disposed off.
Cost of disposal: 366 gal x 7.17 Ib/gal = 2624 Ib x $1.20/lb = $3149
Cost of material procurement: 488 gal @ $300/55 gal = $2662
Total cost: $2662 + $3149 = $5811
Cost of new process:
488 gallons of butyrate needed hence assume same quantity of new material needed.
Assume 30% reusability/recycle: 342 gal needed.
Assume 5% loss due to evaporation during handling (vapor pressure less than 7 mm Hg):
342 gal - 5% (loss) = 325 gal used.
Disposal cost: 325 gal x 7.46 Ib/gal = 2425 Ib x $1.2 /Ib = $2909
48
-------
PROJECT TITLE: Spray Paint Equipment Solvent
PROJECT NUMBER: 1110-CLEQOT-Ol
PROJECT ENGINEER: Gary Roque
Total cost:
Material procurement: 342 gal @ $400/55gal = $2480
Material + Disposal: $2480 + $2909 = $5389
SAVINGS FROM CHANGING PROCESS/MATERIAL:
$5811 -$5389 =$422
NOTE: Cost savings do not reflect savings from daily reporting requirements.
49
-------
(Blank)
50
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Recycling P-D-680
1241-RCSOOT-01
Gary Roque
(904)772-4519
343
PROJECT DESCRIPTION: Dry cleaning/degreasing solvent consisting of petroleum
distillates. These solvents are widely used for degreasing machine parts in equipment maintenance
and as general cleaning of aircraft components. P-D-680 could be recycled/reused.
RDT&E REQUIRED:
SPECIAL FUNDING:
TBD
None available
PROJECT COST
EQUIPMENT
TBD
INSTALLATION
TBD
MATERIAL
None
YEARLY CBA: TBD
ANNUAL DISPOSAL COST: $23365
MEDIA SHIFT: N/A
PROJECT COMPLETION PATH
ACTION
TBD
CODE
TBD
ECD
TBE
MH
ESTIMATE
TBD
51
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Recycling P-D-680
1241-RCSOOT-01
Gary Roque
TARGETED MATERIALS/PROCESSES
SHOP#
65630
94111
94111
94111
94118
94118
94118
94118
94118
94118
94118
94118
94120
94121
94121
94121
94131
94131
94133
94133
94221
94332
94342
94342
94342
96103
96108
96108
96108
96108
96108
96351
96352
99013
TOTALS
P
#
1
1
2
3
1
2
3
4
1
2
3
4
1
3
1
2
1
2
2
1
1
2
1
2
3
1
1
2
3
4
5
1
1
1
NUN
00-2745-421
00-285-8011
00-285-8011
00-2858-011
00-274-5421
00-274-5421
00-285-8011
00-274-5421
00-285-8011
00-285-8011
002858011
002858011
002745421
002745421
002745421
002745421
002745421
002745421
002858011
002858011
002745421
002745421
002745421
002745421
002745421
002745421
002745421
002745421
002745421
002745421
002745421
002745421
002858011
002858011
NOMENCLATURE
Dry Cleaning Solvent
Dry Cleaning
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
Dry Cleaning Solvent
LBS
IN
235
117
234
351
51
9
36
171
1085
181
760
3617
10
74
24
74
532
332
617
617
167
134
64
65
65
434
7
10
7
7
o
6
4807
352
4222
19471
LBS
OUT
235
117
234
351
51
9
36
171
1085
181
760
3617
10
74
24
74
532
332
617
617
167
134
64
65
65
434
7
10
7
7
3
4807
352
4222
19471
LBS7
SAVED
70.5
35.1
70.2
105.3
15.3
2.7
10.8
51.3
325.5
54.3
228
1085.1
o
5
22.2
7.2
22.2
159.6
99.6
185.1
185.1
50.1
40.2
19.2
19.5
19.2
130.2
2.1
3
2.1
2.1
.9
1442.1
105.6
1266
5841
NOTE: 1. Assume 30% reusability.
52
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE: Substitution of Methyl Ethyl Ketone (MEK)
PROJECT NUMER: 1243-CLSOGN-01
PROJECT ENGINEER: Andrew Yang
PHONE NUMBER: (904) 772-4519
SHOP: 343
PROJECT DESCRIPTION: Methyl Ethyl Ketone (MEK), ASTM D 740-94 (formerly
federal specification TT-M-261) is primarily used as a solvent or thinner for protective coatings,
but also in adhesives, printing inks, varnish removers, and other chemical intermediates. In
addition, it is also referenced in many Navy repair manuals as a cleaning solvent prior to sealing,
cementing, bonding, coating, etc. Although MEK is specified as a solvent and/or cleaner in many
aircraft repair operations, it is a hazardous air pollutant (HAP) which will be heavily regulated
under OSHA requirements and EPA's targeted list of chemicals for reduction/elimination. As a
result of these requirements, it is advantageous to seek alternatives for those cleaning applications
where more environmentally compliant solvents are technically feasible.
RDT&E REQUIRED:
SPECIAL FUNDING:
Yes.
None currently identified.
PROJECT COST
EQUIPMENT
Unknown
INSTALLATION
Unknown
MATERIAL
Unknown
YEARLY CBA:
ANNUAL DISPOSAL COST
MEDIA SHIFT:
TBD
TBD
From MEK (HAP) to non-HAP solvent.
PROJECT COMPLETION PATH
ACTION
Identify replacement
solvents
Fund RDT&E
R&D
T&E
Implement
CODE
343
AIR 8.0Y
NAWC
NADEP
NADEP
ECD
06/95
10/95
10/95
04/96
09/96
MH
ESTIMATE
120
NA
1000
200
80
53
-------
PROJECT TITLE:
PROJECT NUMER:
PROJECT ENGINEER:
Substitution of Methyl Ethyl Ketone (MEK)
1243-CLSOGN-01
Andrew Yang
TARGETED MATERIALS/PROCESSES
SHOP#
94115
94135
94135
94135
94135
94242
94242
94243
94243
94337
94342
94344
TOTALS
P
#
1
1
2
4
0
1
2
1
2
1
o
J
3
NUN
00-281-2762
00-281-2762
00-281-2762
00-281-2762
00-281-2762
00-281-2762
00-281-2762
00-281-2762
00-281-2762
00-281-2762
00-281-2762
00-687-8429
NOMENCLATURE
Methyl Ethyl Ketone
Methyl Ethyl Ketone
Methyl Ethyl Ketone
Methyl Ethyl Ketone
Methyl Ethyl Ketone
Methyl Ethyl Ketone
Methyl Ethyl Ketone
Methyl Ethyl Ketone
Methyl Ethyl Ketone
M.E.K. Technical
M.E.K. Technical
Methyl Ethyl Ketone
LBS
IN
68
50
10
10
70
17
50
20
7
34
14
20
370
LBS
OUT
68
50
10
10
70
17
50
20
7
34
14
20
370
LBS
SAVED
68
50
10
10
70
17
50
20
7
34
14
20
370
54
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Substitution of Toluene
1242-CLSOGN-01
Andrew Yang
(904)772-4519
343
PROJECT DESCRIPTION: Toluene, TT-T-548, is used as a solvent or thinner for
organic coatings, various resins, and chlorinated rubber. It is also used as a diluent for some
cellulosic lacquers and dopes. Toluene is specified as a solvent and/or cleaner in many aircraft
repair operations, but it is a hazardous air pollutant (HAP) which will be heavily regulated under
OSHA requirements and EPA's targeted list of chemicals for reduction/elimination. As a result of
these requirements, it is advantageous to seek alternatives.
RDT&E REQUIRED:
SPECIAL FUNDING:
Yes.
None currently identified
PROJECT COST
EQUIPMENT
Unknown
INSTALLATION
Unknown
MATERIAL
Unknown
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
TBD
TBD
From toluene (HAP) to non-HAP solvent.
PROJECT COMPLETION PATH
ACTION
Identify replacement
solvents
Fund RDT&E
R&D
T&E
Implement
CODE
343
AIR 8.0Y
NAWC
NADEP
NADEP
ECD
06/95
10/95
1095
04/96
09/96
MH ESTIMATE
120
NA
1000
200
80
55
-------
PROJECT TITLE:
PROJECT NUMER:
PROJECT ENGINEER:
Substitution of Toluene
1242-CLSOGN-01
Andrew Yang
TARGETED MATERIALS/PROCESSES
SHOP#
94116
94120
94135
94135
94217
94217
94332
94337
95111
95113
94116
94116
94332
94336
94337
95113
96103
TOTAL
P
#
6
1
3
0
2
3
2
1
1
1
4
6
2
3
2
1
1
NUN
00-281-2002
00-281-2002
00-281-2002
00-281-2002
00-281-2002
00-281-2002
00-281-2002
00-281-2002
00-281-2002
00-281-2002
00-579-8431
00-579-8431
00-579-8431
00-579-8431
00-579-8431
00-579-8431
00-711-2185
NOMENCLATURE
Toluene, Technical
Toluene, Technical
Toluene, Technical
Toluene, Technical
Toulene, Technical
Toulene, Technical
Toulene, Technical
Toulene, Technical
Toulene, Technical
Toluene, Technical
Toluene, Technical
Toluene, Technical
Toulene, Technical
Toulene, Technical
Toulene, Technical
Toluene, Technical
Technical Toloune
LBS
IN
92
11
85
72
4
4
416
69
15
239
58
50
508
108
108
112
1
1952
LBS
OUT
92
11
85
72
4
4
416
69
15
239
58
50
508
108
108
112
1
1952
LBS
SAVED
92
11
85
72
4
4
416
69
15
239
58
50
508
108
108
112
1
1952
56
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE: Methylene Chloride Elimination/Replacement
PROJECT NUMBER: 1300-READOT-02
PROJECT ENGINEER: Andrew Yang
PHONE NUMBER: (904) 772-4519
SHOP: 343
PROJECT DESCRIPTION: Methylene chloride is used to remove potting materials from
electrical connectors. Since this chemical is a hazardous air pollutant, and one that is going to be
regulated heavily under OSHA requirements, it is advantageous to seek alternatives. Though the
immediate cost payback for limited use at NADEP JAX does not warrant the RDT&E cost, it may
be cost effective if worked on a corporate level. Though this project is still in the RDT&E phase,
NADEP Jacksonville will implement alternatives as they are developed.
RDT&E REQUIRED:
SPECIAL FUNDING:
Yes
Non currently identified.
PROJECT COST
EQUIPMENT
Unknown
INSTALLATION
Unknown
MATERIAL
Unknown
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
TBD
TBD
From HAP's to non-HAP
PROJECT COMPLETION PATH
ACTION
Define RDT&E
requirements
Fund RDT&E
Perform R&D
Perform T&E
Implement
CODE
343
AIR-8.0Y
NAWC/NADEP
NADEP
NADEP
ECD
05/95
10/95
10/96
06/96
07/96
MH
ESTIMATE
20
1500
100
40
57
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Methylene Chloride Elimination/Replacement
1300-READOT-02
Andrew Yang
TARGETED MATERIALS/PROCESSES
SHOP#
94241
94241
94336
94337
94344
TOTALS
P
#
o
5
i
o
3
2
o
J
NUN
00-244-0290
00-244-0290
00-244-0290
00-244-0290
00-244-0290
NOMENCLATURE
Dichloromethane, Technical
Dichloromethane, Technical
Dichloromethane, Technical
Dichloromethane, Technical
Dichloromethane, Technical
LBS
IN
7
6
88
88
499
688
LBS
OUT
7
6
88
88
499
688
LBS
SAVED
7
6
88
88
499
688
58
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Aircraft Fuel Systems Pressure/Leak Testing
1233-TEFULK-01
Laura Rossi
(904) 772-2457
343
PROJECT DESCRIPTION: Class II CDS submstances are currently used for pressure
leak testing of aircraft fuel systems after installation and aircraft rework/repair. Ozone depleting
substances are being phased-out of use by the Navy. It would be advantageous to seek more
environmentally compliant materials and/or other methods to leak test aircraft fuel systems.
RDT&E REQUIRED:
SPECIAL FUNDING:
Yes
None currently identified.
PROJECT COST
EQUIPMENT
Unknown
INSTALLATION
Unknown
MATERIAL
Unknown
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
TBD
TBD
From ODS to non-HAP
PROJECT COMPLETION PATH
ACTION
Define RDT&E
Requirement
Fund RDT&E
Perform R & D
Perform T & E
Implement
CODE
343
AIR-8.0Y
NAWC/NADEP
NADEP
NADEP
ECD
05/95
10/95
10/96
06/96
09/96
MH
ESTIMATE
20
N/A
1000
200
40
59
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Aircraft Fuel Systems Pressure/Leak Testing
1233-TEFULK-01
Laura Rossi
TARGETED MATERIALS/PROCESSES
SHOP#
95312
TOTALS
P
#
1
NUN
LL-HAZ-1058
NOMENCLATURE
Detector, Leak (Gen Solvent)
LBS
IN
52
52
LBS
OUT
52
52
LBS
SAVED
52
52
60
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE: Electrocoat Primer Demo
PROJECT NUMBER: 1110-COPRPT-Ol
PROJECT ENGINEER: Hank Birdsong
PHONE NUMBER: (904) 772-2469
SHOP: 343
PROJECT DESCRIPTION: This project seeks to demonstrate the
application of electrocoat primer to naval aviation parts repaired or
manufactured within NADEP. The part is placed in a tank containing
specialy formulated electrocoat suspension. Voltage is applied and the
coating of resin and pigment is deposited on the part. The deposited film is
cured in an oven to obtain final film properties.
RDT&E REQUIRED: This is a demonstration effort sponsored by
NAWCADWAR
SPECIAL FUNDING: This project has been funded $50K
FY95.NADEP JAX must invest in this technology to demonstrate leadership,
improve product quality, reduce costs and prevent pollution. To be succesfull this
project requires the Depot to: (1) allow utilization of existing equipment/shop
space, Building 794 C-line, tanks C-3 through C-15, which has been stood down
due to process changes is a probable location, (2) provide engineer/artisan labor
resources to modify equipment and set-up process.
PROJECT COST
EQUIPMENT
INSTALLATION
MATERIAL
YEARLY CBA:
ANNUAL DISPOSAL COST: $71,714.16 (57,834 Ibs solid waste x
$1.24/lb for disposal cost
MEDIA SHIFT: NONE
61
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Electrocoat Primer Demo
1110-COPRPT-Ol
Hank Birdsong
PROJECT COMPLETION PATH
ACTION
Document equip.
requirements
Estimate location
Buy equipment
ID parts
Install equipment
Develop instructions
Start demonstration
CODE
343
621
343
343
620
343
343
ECD
04/17/95
05/03/95
05/22/95
07/14/95
08/04/95
08/04/95
09/29/95
MH ESTIMATE
180
20
80
160
140
100
TARGETED MATERIALS/PROCESSES
SHOP#
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
94221
94321
96226
96226
96226
TOTALS
P
#
1
1
1
1
1
1
1
1
1
1
1
1
6
1
6
NUN
00-877-6415
01-265-9142
01-265-9143
01-265-9151
01-285-3048
01-285-3554
01-3296752
01-334-45119
00-181-8079
LL-HAZ-O88O
01-265-9151
00-558-5177
01-0306162
01-285-3035
LL-LOR-6343
NOMENCLATURE
Paint Gray
Paint Poly
Paint Poly
Paint Poly
Paint Poly
Paint Poly
Paint Poly
Paint Alum
Thin Poly
Paint Aery
Paint Poly
Paint Enam
Glyp Reduc
Paint Poly
Glyp Clr
LBS
IN
231
463
7279
4816
450
468
216
485
631
416
184
300
40
52
158
16,189
LBS*
OUT
159
301
4,731
3,130
293
304
140
315
410
271
120
195
26
34
103
10,523
LBS
SAVED**
72
162
2548
1686
157
164
76
170
221
145
64
105
14
18
55
5,657
* Lbs Out based on 35 percent transfer efficiency for Ibs in coating material.
**Lbs Saved not applicable until Depot-wide implementation.
62
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE: Powder Coat
PROJECT NUMBER: 1110-COPRPT-03
PROJECT ENGINEER: Hank Birdsong
PHONE NUMBER: (904) 772-2469
SHOP: 343
PROJECT DESCRIPTION: This project seeks to demonstrate
Powder Coat application of coatings to NADEP reworked and
manufactured parts.
RDT&E REQUIRED: This is a demonstration project sponsored by
NAWCADWAR
SPECIAL FUNDING: This project has special funding of $25K
FY-95. The NADEP will be required to invest in this technology by: (1) allocating
shop space and (2) providing engineer/artisan labor.
PROJECT COST
EQUIPMENT
$25,000
INSTALLATION
MATERIAL
YEARLY CBA: TBD
ANNUAL DISPOSAL COST: $71,714.16 (57,834 Ibs solid waste x
$1.24/lb for disposal cost
MEDIA SHIFT: NONE
63
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Powder Coat
1110-COPRPT-03
Hank Birdsong
PROJECT COMPLETION PATH
ACTION
Document equip.
requirements
Establish location
Buy equipment
ID parts
Install equipment
Develop instructions
Start demonstration
CODE
343
624
343
343
620
343
343
ECD
04/17/95
05/03/95
05/22/95
07/14/95
08/04/95
08/04/95
09/29/95
MH ESTIMATE
120
4
6
160
120
80
TARGETED MATERIALS/PROCESSES
SHOP#
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
94221
94321
96226
96226
96226
TOTALS
P
#
1
1
1
1
1
1
1
1
1
1
1
1
6
1
6
NUN
00-877-6415
01-265-9142
01-265-9143
01-265-9151
01-285-3048
01-285-3554
01-3296752
01-334-45119
00-181-8079
LL-HAZ-O88O
01-265-9151
00-558-5177
01-0306162
01-285-3035
LL-LOR-6343
NOMENCLATURE
Paint Gray
Paint Poly
Paint Poly
Paint Poly
Paint Poly
Paint Poly
Paint Poly
Paint Alum
Thin Poly
Paint Aery
Paint Poly
Paint Enam
Glyp Reduc
Paint Poly
Glyp Clr
LBS
IN
231
463
7279
4816
450
468
216
485
631
416
184
300
40
52
158
16,189
LBS*
OUT
150
301
4,731
3,130
293
304
140
315
410
271
120
195
26
34
103
10,523
LBS
SAVED**
81
162
2548
1686
157
164
76
170
221
145
64
105
14
18
55
5,666
* Lbs Out based on 35 percent transfer efficiency for Ibs in coating material.
**Lbs Saved not applicable until Depot-wide implementation.
64
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PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
PMB/Chemical Strip
1110-REPAAE-03
Steve Haiti e
(904)772-2457/4516
340
PROJECT DESCRIPTION: Elimate Use of PMB and Chemical
Paint removers for Depainting
aircraft
RDT&E REQUIRED:
SPECIAL FUNDING:
$850,000
None
PROJECT COST
EQUIPMENT
$2.2 million
INSTALLATION
$20,000
MATERIAL
$20,000
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
$1.3 million
$5,000
Chemical/PMB to Ash
PROJECT COMPLETION PATH
ACTION
Obtain funds
Contract
System assembly
System testing
System install
System demo
System validation
System improve
System training
System
implementation
CODE
343
343
Contractor/343
Contractor/343
Contractor/46
Contractor/343
Contractor/343
Contractor/46
Contractor/940
940/46/343
ECD
04/95
06/95
10/95
12/95
06/96
08/96
12/96
04/97
08/97
01/98
MH ESTIMATE
100
150
150
100
200
180
300
100
600
400
65
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PMB/Chemical Strip
1110-REPAAE-03
Steve Haiti e
TARGETED MATERIALS/PROCESSES
SHOP#
94112
TOTALS
P
#
NUN
8010-01-380-2330
8010-01-023-0343
8010-01-341-0793
8010-00-926-1489
NOMENCLATURE
Paint Remover
LBS
IN
321,000
321,000
LBS
OUT
321,000
321,000
LBS
SAVED
321,000
321,000
66
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PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
PROJECT DESCRIPTION:
Cadmium Plating Replacement
COEPCD-01
Mike Romanelli
(904) 772-3444
342
Cadmium plating - about 80 percent of cadmium plating has
been replaced with IVD aluminum. However, ZnNi is being researched to determine if it can be a
viable substitute for the remaining 20 percent of the formerly cadmium plated items.
RDT&E REQUIRED:
SPECIAL FUNDING:
PROJECT COST
EQUIPMENT
INSTALLATION
MATERIAL
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
PROJECT COMPLETION PATH
ACTION
Acquire test material
Pilot process
Prototype in shop
Issue LPS
Implement
Final report
CODE
342
342
342/96225
340
340/96225
340
ECD
06/95
12/95
06/96
07/96
12/97
01/98
MH ESTIMATE
4
320
80
40
80
80
67
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Cadmium Plating Replacement
COEPCD-01
Mike Romanelli
TARGETED MATERIALS/PROCESSES
SHOP#
96225
TOTALS
P
#
NUN
6810-01-051-3150
NOMENCLATURE
Cadmium Oxide
Sodium Cyanide
Sodium Hydroxide
LBS
IN
50
150
1411
1611
LBS
OUT
50
150
1411
1611
LBS
SAVED
50
150
1411
1611
68
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PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
Elimination of 1,1,1-Trichloroethane from Bearing
Cleaning
CLBEEN-01
Joyce Rollen/Carol Brooks
(904) 772-3444
Code 342/Code 624
PROJECT DESCRIPTION: CDS Elimination. 1,1,1 Trichloroethane is used in the
Bearing Shop, 94133 in the initial cleaning step. New tanks will be installed to accomodate VVL-
800 to replace TCA in this step.
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
RDT&E REQUIRED:
SPECIAL FUNDING:
None, RDT&E is complete
None available
PROJECT COST
EQUIPMENT
$24,000
INSTALLATION
$6,000
MATERIAL
$25,000
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
$21,201 after equipment procurement &
installation, materials cost increase
Waste oil can be disposed of at no cost
Eliminate 1,1,1-Trichloroethane; replace
with VV-L-800 oil and P-D-680 dry cleaning
solvent
PROJECT COMPLETION PATH
ACTION
Order tanks
Install
Order materials
Optimize process
Issue LPS
CODE
624
624/650
720/94133
342/94133
342
ECD
06/95
08/95
08/95
11/95
12/95
MH ESTIMATE
100
300
20
300
40
69
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Elimination of 1,1,1-Trichloroethane from Bearing
Cleaning
CLBEEN-01
Joyce Rollen /Carol Brooks
TARGETED MATERIALS/PROCESSES
SHOP#
94133
TOTALS
P
#
NUN
476-5613
NOMENCLATURE
1,1,1 Trichloroethane
LBS
IN
3445
3445
LBS
OUT
3445
3445
LBS
SAVED
3445
3445
70
-------
PROJECT TITLE: Elimination of 1,1,1-Trichloroethane from Bearing
Cleaning
PROJECT NUMBER: CLBEEN-01
PROJECT ENGINEER: Joyce Rollen/Carol Brooks
CBA - 1,1,1-Trichloroethane Vapor Degreaser Replacement
Based on : (1) 8 quarter procurement pull, per S. Gillman , 10/11/94
(2) NSN prices - Don Greene, code 340, 12/94
(3) Waste estimate - K. Wood, code 003, 12/94
(4) Estimate from 503 bearing manual and estimated usage
Current Technology - Materials Cost per Year
1,1,1-Trichloroethane , #00-476-5613, 54-gal drum @ $875 per drum
$875/drx 3 dr = $2,625 (3 dr) (54 gal/dr) (8.33 Ib/gal) (1.32) = 1775 Ibs
1,1,1-Trichloroethane, #00-476-5612, 5-gal can @ $68 per can
$68/can x 5 cans = $340 (5 cans) (5 gal/can) (8.33 Ib/gal) (1.32) = 164 Ibs
Total materials weight = 1939 Ibs
Total materials cost = $2,625 + $340 = $2,965
Current Technology - Disposal Costs per Year
950 Ibs waste 1,1,1-Trichloroethane @ $1.24/lb = $1,178
$4,143 Old
New Technology - Materials Cost per Year
VV-L-800 , #00-281-2060, 55-gal drum @ $251 per drum
Change tank every 2 weeks: 135 gal tank x 26 changes = 3,510 gals
3,510 gal divided by 55 gals = 64 drums
$25 I/drum x 64 drums = $16,064
P-D-680, #00-285-8011, 55 gal drum @ $145 per drum
Change tank every 2 weeks: 135-gal tank x 26 changes = 3,510 gals
3,510 gals divided by 55 gals = 64 drums
$145/drum x 64 drums = $9,280
New Technology - Disposal Costs per Year
Waste will be waste oil and can be disposed of at no cost
- $25.344 New
= -$21,201 CBA
71
-------
(Blank)
72
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
PROJECT DESCRIPTION:
Elimination of Freon-113 in Bearing Cleaning
CLBEEN-02
Bill Somora (624)/Joyce Rollen (342)
(904) 772-4453
94133
Bearings are currently dried using Freon-113 in an ultrasonic
vapor degreaser. The Freon-113 vapor degreaser will be replaced by an isopropyl alcohol (IPA)
dryer. The replacement equipment must be procured and installed and the process optimized
before the existing degreaser can be removed.
RDT&E REQUIRED:
SPECIAL FUNDING:
PROJECT COST
EQUIPMENT
$165,000
INSTALLATION
$15,000
MATERIAL
$740
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
+$7,412 (for materials)
$447
Waste will shift from Freon-113 to isopropyl
hoi
PROJECT COMPLETION PATH
ACTION
Procure equipment
Procure materials
Install dryer
Optimize process
CODE
624
94133/720
624/650
94133/342/624
ECD
08/31/95
09/30/95
10/31/95
12/31/95
MH ESTIMATE
200
20
600
300
73
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Elimination of Freon-113 in Bearing Cleaning
CLBEEN-02
Bill Somora (624)/Joyce Rollen (342)
TARGETED MATERIALS/PROCESSES
(Per year)
SHOP#
94133
TOTALS
P
#
1/2
NUN
00-551-0854
NOMENCLATURE
Freon-113
LBS
IN
2919
2919
LBS
OUT
715
715
LBS
SAVED
715
715
CBA - Freon-113 Vapor Degreaser Replacement
Based on: (1) 8 quarter procurement pull, per S. Gillman, 10-11-94
(2) NSN prices - Don Green, 12/94
(3) Waste estimate - K. Wood, code 003, 12/94
(4) Estimate of IPA usage
Current Technology - Materials Cost per Year
Freon-113, #00-551-0854, 15 gal drum @ $458 per drum
$458/15-gal drum x 11 drums = $5,038 (11 dr) (200 Ib/dr) = 2,200 Ibs
Freon-113, #00-983-0182, 55 gal drum @ $2,088 per drum
$2,088/55-gal drum x 1 drum = $2,088 (1 dr) (55-gal/dr) (1.57) = 719 Ibs
Total materials weight = 2,919 Ibs
Total materials cost = $7,126
Current Technology - Disposal Costs per Year
715 Ibs waste Freon-113 @ $1.24/lb = $1,473
5,599 Old
New Technology - Estimated Materials Cost per Year
Isopropyl Alcohol, #00-543-7915, 55 gal drum @ $185 per drum
$185 per 55-gal drum x 4 drums = $740 (4 dr) (55-gal/dr) (.78) = 1,429 Ibs
74
-------
PROJECT TITLE: Elimination of Freon-113 in Bearing Cleaning
PROJECT NUMBER: CLBEEN-02
PROJECT ENGINEER: Bill Somora (624)/Joyce Rollen (342)
New Technology - Estimated Disposal Cost per Year
1 55-gal drum waste IPA = (1 drum) (55 gal) (8.3 Ib/gal) (.78) = 357 Ibs
357 Ibs IPA x $1.24/lb = $447
$U87New
+$7,412 CB
75
-------
(Blank)
76
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Eliminate Methylene Chloride in Bearing Cleaning
CLBEEN-03
Carol Brooks (624)/Joyce Rollen (342)
(904) 772-44537(904) 772-3444
94133
PROJECT DESCRIPTION: Carbon on engine bearings is currently removed with a
cleaner containing methylene chloride. This halagenated hydrocarbon, hazardous air pollutant
(methylene chloride) will be replaced with a more environmentally compliant, non-halogenated
solvent cleaner. The tanks must be bought and installed and the process optimized before the old
system is completely removed.
RDT&E REQUIRED:
SPECIAL FUNDING:
PROJECT COST
EQUIPMENT
$24,000
INSTALLATION
$6,000
MATERIAL
$4,788
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
7,152 (materials)
$8,407
Halogenated hydrocarbon solvent to a mixed
organic emulsion system.
PROJECT COMPLETION PATH
ACTION
Research materials
Research VOC/HAPS
Purchase tanks
Evaluate materials
Install tanks
Procure materials
Set up new process
Optimize & evaluate
Procure large materials
Transfer process
CODE
342
342
624
342
624/650
94133/342
94133/232/624
94133/342
94311/720
94133/342/624
ECD
05/30/95
08/28/95
09/31/95
09/31/95
11/31/95
11/31/95
01/31/96
03/30/96
06/31/96
08/28/96
MH ESTIMATE
20
25
100
80
300
20
200
300
20
100
ECD update from originator
77
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Eliminate Methylene Chloride in Bearing Cleaning
CLBEEN-03
Carol Brooks (624)/Joyce Rollen (342)
TARGETED MATERIALS/PROCESSES
SHOP#
94133
94133
TOTALS
P
#
2
2
NUN
00-550-7453
00-610-9188
NOMENCLATURE
Cold Carbon Cleaner
Methylene Chloride**
LBS
IN
3784='
1800
5584
LBS
OUT
5893
1800
7693
LBS
SAVED
5893
1800
7693
* Amount from 8 quarter pull is low
** Used to replenish Mecl2 lost from cdd carbon cleaner
CB A - Cold Carbon Cleaner Replacement
Based on: (1) 8 quarter procurement pull, per S. Gillman, 10-11-94 (7 drums is very low
for cold carbon cleaner)
(2) NSN prices - Don Green, 12/94
(3) Waste estimate - past usage of tanks
(4) Estimated usage of new materials
Current Technology - Materials Cost per Year
Cold Carbon Cleaner, MIL-C-19853, #00-550-7453, 55 gal drum @ $395 per drum
$395/drum x 7 drums = $2,765 (7 dr) (55 gal) (8.33 Ib/gal) (1.18) = 3,784 Ibs
Methylene chloride 00-616-9188 - 55-gal drum @ $256 per drum
$265/drum x 3 drums = $768 (3 dr) (55 gal) (8.33 Ib/gal) (1.31) = 1,800 Ibs
Total materials cost = $2,765 + $768 = $3,533
Current Technology - Disposal Costs per Year
* 540 gal cold carbon cleaner (8.33 Ib/gal) (1.31) = 5,893 Ibs waste cold carbon cleaner
100 gal contaminated cleaning water (8.33 Ib/gal) = 833 Ibs cleaning water
5,893 Ibs + 833 Ibs = 6,726 Ibs x $1.25/lb = $8,407
* Two 135-gal tanks twice a year
$11,940 Old
New Technology - Materials Cost per Year
Envirosolv 654CR, #01-388-9744 55-gal drum
$798 x 6 drums = $4,788
$798 per drum
$4.788 New
78
-------
PROJECT TITLE: Eliminate Methylene Chloride in Bearing Cleaning
PROJECT NUMBER: CLBEEN-03
PROJECT ENGINEER: Carol Brooks (624)/Joyce Rollen (342)
New Technology - Disposal Costs per Year
Biodegradable
+ $7,152CBA
79
-------
(Blank)
80
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE: Eliminate Methylene Chloride in Bearing Cleaning
PROJECT NUMBER: CLBEEN-04
PROJECT ENGINEER: Joyce Rollen (342)/Bill Somora (624)/Thad Patin (650)
PHONE NUMBER: (904) 772-34447(904) 772-44537(904) 772-3438
SHOP: 94133
PROJECT DESCRIPTION: Following the cold carbon cleaning the engine bearings are
rinsed in water with nonionic soap and sodium chromate. This rinse water is contaminated with
trace amounts of cold carbon cleaner which contains methylene chloride. The waste water is
currently shipped out as hazardous waste. We hope to have this 120-gallons of contaminated
water treated in the new waste treatment plants.
RDT&E REQUIRED:
SPECIAL FUNDING:
Feasibility study
None
PROJECT COST
EQUIPMENT
None
INSTALLATION
None
MATERIAL
None
YEARLY CBA: $73, 468
ANNUAL DISPOSAL COST: $82,048
MEDIA SHIFT: N/A
PROJECT COMPLETION PATH
ACTION
Access Feasibility
* Approve
* Execute
CODE
650/624/342
003/624/650
94133/650
ECD
11/94
01/15/96
01/31/96
MH ESTIMATE
20
20
20
* Updated codes & ECD's, page 17
81
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Eliminate Methylene Chloride in Bearing Cleaning
CLBEEN-04
Joyce Rollen (342)/Bill Somura (624)7
Thad Patin (650)
TARGETED MATERIALS/PROCESSES
SHOP#
94133
TOTALS
P
#
2
NUN
N/A
NOMENCLATURE
Waste stream
LBS
IN
N/A
LBS
OUT
* 66,167
66,167
LBS
SAVED
66,167
66,167
* Error on page 16
CB A - Redirection of Contaminated Rinse Water to Water Treatment Plant II
Based on (1) Estimate of gallons dumped per week
(2) Cost of processing in treatmenplant
Current Technology - Waste Disposal Costs per Year
One 135-gal rinse water tank weekly - containing sodium chromate, nonionic soap and
traces of cold carbon cleaner
(135-gal/wk) (52 wk/yr) (8.5 Ib/gal) = 59,670 Ib/yr contaminated rinse water
(15 gal/wk) (52 wk/yr) (8.33 Ib/gal) = 6,497 Ib/yrcontaminated cleaning water
66,167 Ibs/yr waste
x $1.24 per Ib
$82,048 waste cost
New Technology - Waste Treatment Plant #2
(165 gal waste/wk) (52 wks/yr) ($l/gal treatment cost) = $8,580
+ $73,468
82
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Circuit Board Cleaning
1300-CLELCB-01
Michael Linn
(904) 772-2469
343
PROJECT DESCRIPTION: Circuit boards require cleaning after soldering with rosin
solder fluxes. Traditionally, the cleaning solvent used has been a Class I CFC but has recently been
changed to isopropyl alcohol (IPA). Though IPA does an adequate job, it is not the ideal cleaner
for rosin based fluxes. Detergents and terpenes used in conjunction with automatic spray washing
equipment provides a better product, automates the cleaning process and reduces the use of IPA, a
flammable material. Four washers will be strategically located in 101 U so that all shops can
conveniently utilize automated washers.
RDT&E REQUIRED:
SPECIAL FUNDING:
None; RDT&E is complete.
None available
PROJECT COST
EQUIPMENT
$ 32 K (4 units)
INSTALLATION
$ 10K
MATERIAL
0
YEARLY CBA: TBD
ANNUAL DISPOSAL COST:
MEDIA SHIFT: NONE
PROJECT COMPLETION PATH
ACTION
ID equipment
ID cleaners
Procure 1
Prototype
Procure 3
Implement
CODE
343/46
343
46
940
46
940
ECD
06/95
07/95
01/96
03/96
09/96
10/96
MH ESTIMATE
40
2
40
80
40
83
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Circuit Board Cleaning
1300-CLELCB-01
Michael Linn
TARGETED MATERIALS/PROCESSES
SHOP#
94212
94215
94241
94241
94241
94242
94242
94243
94243
94244
TOTALS
P
#
1
1
1
2
o
5
i
2
1
2
1
NUN
6150-00-286-5435
6150-00-286-5435
6150-00-286-5435
6150-00-286-5435
6150-00-286-5435
6150-00-286-5435
6150-00-286-5435
6150-00-286-5435
6150-00-286-5435
6150-00-286-5435
6150-00-286-5435
NOMENCLATURE
IPA
IPA
IPA
IPA
IPA
IPA
IPA
IPA
IPA
IPA
IPA
LBS
IN
53
40
34
12
20
190
53
20
45
21
965
LBS
OUT
53
40
34
12
20
190
53
20
45
21
965
LBS
SAVED
53
40
34
12
20
190
53
20
45
21
965
84
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
PMB/Chemical Strip
1110-REPAAE-01
Rick Barnes
(904)772-2457/4516
340
PROJECT DESCRIPTION: Reduction of PMB and Chemical
Paint Removers
RDT&E REQUIRED: None
SPECIAL FUNDING: $85,000
PROJECT COST
EQUIPMENT
$85,000
INSTALLATION
N/A
MATERIAL
Water
YEARLY CBA
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
$50,000 waste reduction
$2,000
PMB/chemical to water
PROJECT COMPLETION PATH
ACTION
Coordinate WR/ALC
Literature search
Coordinate with
NAVAIR
Define facility
requirements
Contract and
purchase
Installation
CODE
340
340
340
620
620
620
ECD
01/95
03/95
06/95
06/96
09/96
05/97
MH ESTIMATE
60
20
60
20
40
20
85
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PMB/Chemical Strip
1110-REPAAE-01
Rick Barnes
TARGETED MATERIALS/PROCESSES
SHOP#
94112
TOTALS
P
#
NUN
8010-01-380-2330
8010-01-341-0793
8010-01-023-0343
8010-01-341-0793
NOMENCLATURE
Paint Remover
LBS
IN
321,000
321,000
LBS
OUT
321,000
321,000
LBS
SAVED
321,000
321,000
86
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Methylene Chloride Replacement
1110-REPAAE-05
Rick Barnes
(904)772-2457/4516
343
PROJECT DESCRIPTION: Elimination Of Methylene Chloride
Paint Remover
RDT&E REQUIRED:
SPECIAL FUNDING:
Industry/Navy Cooperative Effort
None
PROJECT COST
EQUIPMENT
None
INSTALLATION
None
MATERIAL
$147,000
YEARLY CBA:
ANNUAL DISPOSAL COST
MEDIA SHIFT:
500,000
$275,000
Reduction of 750,000 gallons of
water to offsite treatment 80 tons of
HAPS
PROJECT COMPLETION PATH
ACTION
Process
documentation
Implementation
HGR MODS
CODE
340
94110
650
ECD
01/01/95
06/30/95
09/30/95
MH ESTIMATE
40
N/A
200
87
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Methylene Chloride Replacement
1110-REPAAE-05
Rick Barnes
TARGETED MATERIALS/PROCESSES
SHOP#
94112
TOTALS
P
#
NUN
8010-01-380-2330
8010-00-926-1489
8010-01-380-3258
8010-01-341-0793
NOMENCLATURE
Paint Remover
LBS
IN
321,000
321,000
LBS
OUT
5,266K*
5,266K*
LBS
SAVED
5,266k
5,266k
*5,266K Ibs include HO and stripper without HAPS
88
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE: Low VOC Coating
PROJECT NUMBER: 1110-COPAAE-02
PROJECT ENGINEER David Brock
PHONE NUMBER (904) 772-4519
SHOP: 343
PROJECT DESCRIPTION Hexavalent chromium is a known carcinogen. The EPA is
currently writing regulations which will lower emissions limits to near zero levels. OSH permitted
exposure levels will likely follow suit. This project seeks to transition previous R&D performed by
NAWC Warminster to DEPOT level production use. Ultimately it is desired to remove hexavalent
chrome from priming operations.
RDT&E REQUIRED NAWC Warminster has been the primary R&D POC
thus far. It is expected thatthey will continue to be
heavily involved in product formulation.
SPECIAL FUNDING: FY-95 - $35,000
PROJECT COST
EQUIPMENT
0
INSTALLATION
0
MATERIAL
$10,000
YEARLY CBA: $72640 one time cost, $ 300,000 one time
cost avoidance,
$ 75,000 annual maintenance avoidance
ANNUAL DISPOSAL COST: No change
MEDIA SHIFT: None
89
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER
Low VOC Coating
1110-COPAAE-02
David Brock
PROJECT COMPLETION PATH
ACTION
Provide lab sample
Perform local evaluation
Feedback to NAWC
Coordinate Prototype sample
Coordinate Prototype aircraft
Coordinate line run in 941 15
Provide feedback to NAWC
Warminster
Create specification for material
Propose specification to G-8
Establish Procurement Plan
Production capability established
CODE
NAWC Warminster
343/941
343
NAWC Warminster/343
343/371/CFA
343/941
343/941
343/NAWC Warminster
343
723/343
940/94 1/94 1 1 5/94 1 1 61962261
94221343/624
BCD
2/95
6/95
8/95
10/95
10/95
12/95
1/96
6/96
7/96
12/96
6/97
MH ESTIMATE
40
80
24
40
40
24
8
100
60
80
240
90
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER
Low VOC Coating
1110-COPAAE-02
David Brock
TARGETED MATERIALS/PROCESSES
SHOP#
94115
94115
94115
94116
94116
94116
94116
94116
94116
94116
94116
94221
94221
94332
94337
94337
94463
95111
95113
95113
TOTAL
P#
1
1
1
o
J
5
6
2
4
3
5
6
1
1
2
1
1
0
1
1
1
NUN
00-082-2450
01-218-0856
01-218-7354
00-082-2450
00-082-2450
01-048-6539
01-218-0857
01-218-0857
01-218-7354
01-218-7354
01-218-7354
01-218-0858
LL-HAZ-0918
LL-HAZ-0918
01-218-0858
LL-HAZ-0918
00-082-2450
LL-HAZ-0918
01-218-0856
01-218-7354
NOMENCLATURE
Primer, Epoxy Type I Class I
Epoxy, Primer Green
Primer W/B
Primer, Epoxy
Primer, Epoxy
Primer, Epoxy
Primer, W/B
Primer, W/B
Primer, W/B
Primer, W/B
Primer, W/B
Primer, W/B
Paint, Zinc Chromate Primer
Primer, Zinc Chromate
Primer, W/B
Primer, Zinc Chromate
Primer, Epoxy
Primer, Zinc Chromate
Primer, Epoxy Green
Primer, W/B
LBS
IN
117
96
3951
704
470
52
3440
1529
2492
1661
1453
6
20
90
6
30
90
310
32
231
LBS
OUT
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
LBS CHROME
SAVED
60.8
15.4
632.2
366.1
244.4
27.0
550.4
244.6
398.7
265.8
232.5
1.0
9.0
14.4
1.0
13.5
46.8
139.5
16.6
37.0
3316.6
91
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER
DETAIL 1
Low VOC Coating
1110-COPAAE-02
David Brock
na/i
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83
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43
43
24
8
103
63
83
20
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930
930
930
930
930
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930
930
930
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92
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE: High Volume Low Pressure Paint Spray Guns
PROJECT NUMBER COPAEQ-01
PROJECT ENGINEER: David Brock/Carol Brooks
PHONE NUMBER (904) 772-4519
SHOP: 343/624
PROJECT DESCRIPTION NADEP Jacksonville currently uses conventional high
pressure air spray guns to apply paint and coatings to aerospace equipment primed and painted.
This project will replace the conventional guns with a more efficient gun commonly called "high
volume low pressure" (HVLP). HVLP vendors claim paint transfer efficiencies of 65 percent as
compared to the typical 20-40 percent associated with conventional equipment. This equates to a
30-50 percent reduction in the coating material required to perform a particular task. A
corresponding reduction in volatile organic compounds released occurs.
RDT&E REQUIRED HVLP technology is a relatively mature technology,
R&D is not required. Test and evaluation of available equipment should be performed in
the actual shops which will implement the technology. While this is required in order to
evaluate the performance of equipment it is more important for the shop to be involved in
all purchase decisions in order to insure artisan support. The project completion path is
approximately 70 percent complete.
SPECIAL FUNDING:
FY93 - $35,000
FY94 - $45,000
FY95 - -0-
PROJECT COST
EQUIPMENT
$ 69,300
INSTALLATION
$ 3,720
MATERIAL
$ 9,025
YEARLY CBA:
ANNUAL DISPOSAL COST:
$82,045 one time cost, thereafter $ 121,691
annual savings
$-3156
MEDIA SHIFT:
None
93
-------
PROJECT TITLE:
PROJECT NUMBER
PROJECT ENGINEER:
High Volume Low Pressure Paint Spray Guns
COPAEQ-01
David Brock/Carol Brooks
PROJECT COMPLETION PATH
ACTION
Perform market survey of available
equipment.
Select potential equipment for Lab
evaluation
Perform lab evaluation/intro to shop
Select strongest candidate for shop
trial
Perform shop trial on components
Prime aircraft/Topcoat aircraft
Evaluate air supply/determine
adjustments
Coordinate procurement
Facilitate shop distribution
Perform Artisan training
CODE
343/624
343/624
343/624/941
343/624/941
343/624/941
343/624/941
343/624/941
343/624
941
343/941
ECD
12/93
01/94
06/94
08/94
09/94
09/94
09/94
02/95
03/95
06/95
MH ESTIMATE
60
8
50
8
40
80
40
40
40
124
TARGETED MATERIALS/PROCESSES
SHOP#
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
P#
NUN
00-082-2450
00-597-9770
00-877-6415
01-218-0856
01-218-7354
01-265-9142
01-265-9143
01-265-9151
01-265-9154
01-285-2495
01-285-3038
01-285-3048
01-285-3554
01-329-6298
01-329-6300
01-329-6304
01-329-6752
01-344-5119
01-344-5311
NOMENCLATURE
Primer, Epoxy Type I Class I
Paint, Phosphorescent Tt-P-54
Paint, Gray 16376
Epoxy, Primer Green
Primer W/B
Paint, Polyurethane, Gray, 16440
Paint, Polyurethane, White, 17925
Paint, Polyurethane, Gray
Paint, Polyurethane, Red
Paint, Polyurethane, Blue
Paint, Polyurethane, Orlyel
Paint, Polyurethane, Black
Paint, Polyurethane, Black
Paint, Polyurethane, Orange
Paint, Polyurethane
Paint, Polyurethane
Paint, Polyurethane, Gray
Paint, Alum. Heat Resistant
Gray Silicone Enamel
LBS
IN
117
26
231
96
3951
463
7279
4816
139
23
139
450
468
89
64
164
216
485
46
LBS
OUT
75
17
148
61
2529
296
4659
3082
89
15
89
288
300
57
41
105
138
310
29
LBS
SAVED
42
9
83
35
1422
167
2620
1734
50
8
50
162
168
32
23
59
78
175
17
94
-------
SHOP#
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
94115
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
P#
3
5
6
o
5
i
4
3
5
6
o
J
3
o
J
5
6
4
5
3
o
J
3
o
J
5
o
J
3
5
5
o
6
4
o
J
5
o
J
3
o
J
3
6
5
NUN
01-350-4742
01-356-5171
LL-HAZ-0880
LL-HAZ-0886
LL-HAZ-0909
LL-HAZ-0940
LL-HAZ-0972
LL-HAZ-0980
LL-HAZ-1548
LL-HAZ-1553
LL-HAZ-1653
LL-HAZ-1807
LL-HAZ-1849
00-082-2450
00-082-2450
01-048-6539
01-058-0143
01-218-0857
01-218-0857
01-218-7354
01-218-7354
01-218-7354
01-265-9140
01-265-9142
01-265-9143
01-265-9143
01-265-9143
01-265-9151
01-265-9151
01-265-9152
01-265-9154
01-285-2495
01-285-3035
01-285-3035
01-285-3048
01-285-3554
01-285-3554
01-285-3555
01-329-6301
01-329-6304
01-329-6752
01-336-3036
01-340-8717
01-356-5171
LL-HAZ-0666
LL-HAZ-0717
LL-HAZ0728
LL-HAZ-0832
NOMENCLATURE
Epoxy, Coating Kit
Paint, Polyurethane Clear
Paint, Acrylic
Activator
Primer, Clear
Primer, Epoxy, Low Density
Paint, Polyurethane, Dk Green
Coating, Thermal Lag
Paint, Poly Alkyd Enamel, Note:
Imron
Paint, Teflon Enamel
Paint, Imron
Paint, Imron Poly Enamel
Primer, Polyamide
Primer, Epoxy
Primer, Epoxy
Primer, Epoxy
Coating, Polyurethane Blue
Primer, W/B
Primer, W/B
Primer, W/B
Primer, W/B
Primer, W/B
Paint, Polyurethane, 35237
Paint, Polyurethane Gray, 16440
Paint, Polyurethane White
Paint, Polyurethane White
Paint, Polyurethane White
Paint, Polyurethane Gray, 36375
Paint, Polyurethane Gray, 36375
Paint, Polyurethane, 35320
Paint, Polyurethane Red, 11136
Paint, Polyurethane Blue, 35237
Paint, Polyurethane, 17925
Paint, Polyurethane White
Paint, Polyurethane Black, 17038
Paint, Polyurethane Black, 37038
Paint, Polyurethane Black, 37038
High Solid Polyurethane, 37038
Paint, Polyurethane Orange, 12 197
Paint, Polyurethane, 15044
Paint, Polyurethane Gray, 36231
Paint, Polyurethane Green, 34102
Paint, Unicoat, 36375
Paint, Polyurethane Clear
Paint, Gold
Paint, Polyurethane Scarlet
Agent, Flattening
Primer, Polyurethane High Solid
LBS
IN
51
87
416
56
208
1066
34
280
139
664
125
56
84
704
470
52
9
3440
1529
2492
1661
1453
47
1204
2776
1851
1619
554
553
143
105
576
25
25
172
111
74
40
44
109
108
690
18389
26
9
12
4
496
LBS
OUT
o o
5 j
56
266
36
133
682
22
179
89
425
80
36
54
451
301
33
6
2202
979
1595
1063
930
30
771
1777
1185
1036
355
354
92
67
369
16
16
110
71
47
26
28
70
69
442
11769
17
6
8
3
317
LBS
SAVED
18
31
150
20
75
384
12
101
50
239
45
20
30
253
169
19
3
1238
550
897
598
523
17
433
999
666
583
199
199
51
38
207
9
9
62
40
27
14
16
39
39
248
6620
9
3
4
1
179
95
-------
SHOP#
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94116
94221
94221
94221
94221
94221
94221
94221
94221
94221
94221
95113
95113
95113
95113
96226
96226
96226
96226
96226
96226
96226
96226
96226
96226
Total
P#
5
3
5
5
o
6
4
5
5
6
3
o
5
6
6
6
1
6
6
1
1
1
6
6
NUN
LL-HAZ-0886
LL-HAZ-0909
LL-HAZ-0940
LL-HAZ-0954
LL-HAZ-0970
LL-HAZ-0972
LL-HAZ-0973
LL-HAZ-0974
LL-HAZ-1652
LL-HAZ-1877
LL-HAZ-1878
LL-LOR-7888
01-218-0858
01-239-6752
01-265-9143
01-265-9151
01-285-2495
LL-HAZ-0876
LL-HAZ-0918
LL-HAZ-0954
LL-HAZ-1044
LL-HAZ-1045
01-218-7354
01-265-9143
01-265-9151
01-329-6752
00-200-6946
00-200-6946
00-409-3810
01-030-6162
01-030-6162
01-285-3035
LL-HAZ-0250
LL-HAZ-1818
LL-LOR-6343
LL-LOR-6343
NOMENCLATURE
Activator
Primer, Clear
Primer, Epoxy
Paint, Stencil Aquadex
Paint, Polyurethane Orlyel
Paint, Polyurethane, Dk Green, 3407'
Paint, Polyurethane Tan,30219
Paint, Polyurethane Gray, 36622
Paint, Polyurethane
High Solid Polyurethane, 35450
High Solid Polyurethane, 35190
PAINT, POLYURETHANE, Teflon
Filled
Primer, W/B
Paint, Polyurethane, Gray
Paint, Polyurethane White
Paint, Polyurethane Gray
Paint, Polyurethane Blue
Paint, Aquadex Gray
Paint, Zinc Chromate Primer
Paint, Stencil, Aquadex Black
Paint, Aquadex Red
Paint, Aquadex Blue
Primer, W/B
Paint, Poly White
Paint, Poly Gray
Paint, Poly Gray
Coating, Resin
Coating, Resin
Paint, Touch Up Alum
Glyptal, Reducer
Glyptal, Reducer
Paint, Polyurethane White
Paint, Enamel Gray
Paint, Epoxy
Glyptal, Clear
Glyptal, Clear
LBS
IN
16
96
983
36
11
313
234
816
58
354
315
159
6
18
24
184
23
40
20
71
17
9
231
568
82
126
75
75
12
40
40
52
8
92
158
158
69,620
LBS
OUT
10
61
629
23
7
200
150
522
37
221
202
102
4
12
15
118
15
26
13
45
11
6
148
364
52
81
48
48
8
26
26
33
5
59
101
101
44,557
LBS
SAVED
6
35
354
13
4
113
84
294
21
127
113
57
2
6
9
66
8
14
7
26
6
3
83
204
30
45
27
27
4
14
14
19
3
33
57
57
25,063
96
-------
PROJECT TITLE:
PROJECT NUMBER
PROJECT ENGINEER:
High Volume Low Pressure Paint Spray Guns
COPAEQ-01
David Brock/Carol Brooks
DETAIL 1
COST BENEFIT ANALYSIS HVLP
Shop
94115
94116
94221
96226
94115
94116
94221
96226
94116
ALL
343
ALL
ALL
ITEM
Maximum Performer V3
Maximum Performer V3
Maximum Performer V3
Maximum Performer V3
Air Hose Upgrade
Air Hose Upgrade
Air Hose Upgrade
Air Hose Upgrade
Upgrade fittings manifold
Training for 100 artisans 1 MH each
Prepare for training
Annaul Red. in Filter disposal cost
Annual Reduction in Paint Purchase
Quantity Unit Costs
30
100
4
20
500
2,400
25
100
20
100
24
2,238
see detail
450
450
450
450
1
1
1
1
300
30
30
1
Subtotal $
(13,500) — r
(45,000)
(1,800)
(9,000)
(500)
(2,400)
(25)
(100)
(6,000)
(3,000) /
(720) '/
2,686 1
103566.94
(82,045)
106,253
ONE TIME COST
ANNUAL AVOIDANCE
PAINT COST
Annual Purchase
paint slop
Amount Sprayed
Convert to gallons
Cost per gallon
Cost last year$
(6,962)
62,658
5,696
50
284,809
COST AFTER HVLP
Annual Purchase
paint slop
Amount Sprayed
Convert to gallons
Cost per gallon
Cost next yearS
45,835
(6,962)
39,873
3,625
50
181,242
97
-------
(Blank)
98
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
PROJECT DESCRIPTION
between 240 and 300 tons of R12.
Refrigerant Replacement
SFOPRF-01
Mike Clark/Adrian Gray/Kate Wood
(904) 772-59977(904) 772-2200
651/003
The NADEP has five air conditioning systems that are each
Preliminary analysis has determined replacement of these
systems with R-22 systems will be preferred to retrofit with R-123. Before a decision is finalized
there will be some investigation into doing one project through Energy Conservation which would
replace one unit with natural gas cooled system. A meeting will be held 27 January 1995 to
discuss.
RDT&E REQUIRED:
SPECIAL FUNDING:
None
Possibly for pilot project
PROJECT COST
If we do it all ourselves without the special project the following estimates are:
1. R12 system for Rubber Shop/Seat Shop/Landing Gear Shop to be replaced by
two systems: R-22 system for Rubber Shop and old Seat Shop and air cool water chiller
system for Landing Gear Shop. Both projects are BCD October 1995 through PAC.
EQUIPMENT
$173,000
INSTALLATION
$150,000
MATERIAL
With equipment
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
One time expense
-0-
From Class 1 ODs to Class 2 (R-22) or non-
ODS
PROJECT COMPLETION PATH
ACTION
Prepare/oversee
contract to PWC to
replace/retrofit
systems
CODE
651
ECD
10/95
MH ESTIMATE
99
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Refrigerant Replacement
SFOPRF-01
Mike Clark/Adrian Gray/Kate Wood
PROJECT COST
The remaining four systems are found in Building 101U and 101J. The projects are in the
preliminary planning stages with the following estimates:
EQUIPMENT
$300,000
INSTALLATION
$300,000
MATERIAL
With equipment
YEARLY CBA: $600,000 one time cost
ANNUAL DISPOSAL COST-^0-
MEDIA SHIFT: From Class 1 CDS to Class 2 (R-22) or non-ODS
PROJECT COMPLETION PATH
ACTION
Prepare/oversee
contract to
replace/retrofit
systems
CODE
651
ECD
12/96
MH ESTIMATE
TARGETED MATERIALS/PROCESSES
SHOP*
TOTALS
P
#
NUN
NOMENCLATURE
LBS
IN
LBS
OUT
LBS
SAVED
100
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Ultra High Pressure Waterjet Stripper
RECOGN-01
Rick Johnston/John Zulich
(904) 772-4521
341/343
PROJECT DESCRIPTION: NADEP JAX currently uses a variety of mechanical
(abrasive blasting, machining) and chemical (nitric acid solution) techniques to remove thermal
spray coatings from engine components. Purely mechanical means (putty knife, wire brush) are
used to remove abradable rubber from J52 strators. Waterjet stripping can remove almost any
thermal spray coating and all abradable rubber coatings in minutes with no loss parent metal.
RDT&E REQUIRED:
SPECIAL FUNDING:
Mature, off-the-shelf technology. Components have
already been stripped as demonstration projects.
PROJECT COST
EQUIPMENT
$800,000
INSTALLATION
Turnkey
MATERIAL
TBD
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
PROJECT COMPLETION PATH
ACTION
Write specification
Let contract
CODE
TBD
NAWC Lakehurst
ECD
03/01/95
MH ESTIMATE
40
101
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Ultra High Pressure Waterjet Stripper
RECOGN-01
Rick Johnston/John Zulich
TARGETED MATERIALS/PROCESSES
(Per year)
SHOP#
96225
96225
96223
TOTALS
P
#
NUN
NOMENCLATURE
Nitric acid
Abrasive blast media
Abrasive blast media
LBS
IN
2400
400
40,000
42,800
LBS
OUT
2400
400
40,000
42,800
LBS
SAVED
2400 gals
400
40,000
42,800
102
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE: Methylene Chloride Elimination/Replacement
PROJECT NUMBER: 1300-READOT-01
PROJECT ENGINEER: Michael Linn
PHONE NUMBER: (904) 772-2469
SHOP: 343
PROJECT DESCRIPTION: Methylene Chloride is used to remove potting materials from
electrical connectors. Since this chemical is a Hazardous Air Pollutant, and one that is going to be
regulated heavily under OSHA requirements, it is advantageous to seek alternatives. Though the
immediate cost payback for limited use at NADEP JAX does not warrant the RDT&E cost, it may
be cost effective if worked on a corporate level.. Though this project is still in the RDT&E phase,
NADEP Jacksonville will implement alternatives as they are developed.
RDT&E REQUIRED:
SPECIAL FUNDING:
Yes
None currently identified
PROJECT COST
EQUIPMENT
Unknown
INSTALLATION
Unknown
MATERIAL
Unknown
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
PROJECT COMPLETION PATH
ACTION
Define RDT&E
Requirement
Fund RDT
Perform R&D
Perform T&E
CODE
343
AIR-8.0Y
NAWC/NADEP
NADEP
ECD
05/95
10/95
10/96
10/97
MH ESTIMATE
20
1500
200
103
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Methylene Chloride Elimination/Replacement
1300-READOT-01
Michael Linn
TARGETED MATERIALS/PROCESSES
SHOP#
94343
94241
TOTALS
P
#
1
1
NUN
6810-00-244-0290
6810-00-244-0250
NOMENCLATURE
Methylene Chloride
Methylene Chloride
LBS
IN
20
6
26
LBS
OUT
20
6
26
LBS
SAVED
TBD
TDB
TBD
104
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Eliminate Freon-113 from Instrument Bearing Cleaning
CLSOCM-01
Joyce Rollen
(904) 772-3444
342
PROJECT DESCRIPTION: Precision cleaning - Instrument bearings are cleaned using
Freon-113.The Freon-113 process will be changed to an aqueous, non-HAPS, non-ODS process.
RDT&E REQUIRED:
SPECIAL FUNDING:
None
PROJECT COST
EQUIPMENT
$30,000
INSTALLATION
$12,000
MATERIAL
$1,000
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
PROJECT COMPLETION PATH
ACTION
ID/specify alternate
process
Acquire equipment
Acquire materials
Install equipment
Validate process
Implement
Issue instructions
CODE
342
46
94221/723
46
342/94221
342
342
ECD
02/95
04/95
04/95
06/95
07/95
09/95
10/95
MH ESTIMATE
160
4
4
80
160
40
40
105
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Eliminate Freon-113 from Instrument Bearing Cleaning
CLSOCM-01
Joyce Rollen
TARGETED MATERIALS/PROCESSES
SHOP*
94221
94221
TOTALS
P
#
NUN
551-0854
983-0282
NOMENCLATURE
Freon-1 13
Freon-1 13
LBS
IN
1000
220
1220
LBS
OUT
1000
220
1220
LBS
SAVED
1000
220
1220
106
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
PROJECT DESCRIPTION:
Elimination of Silver Cyanide Plating
COEPAG-01
Mike Romanelli
(904) 772-3444
342
Silver cyanide plating - Currently, silver is deposited on parts
using a cyanide complex. Research is underway to replace silver cyanide with a less toxic process.
RDT&E REQUIRED:
SPECIAL FUNDING:
$50,000
Not available
PROJECT COST
EQUIPMENT
INSTALLATION
MATERIAL
$10,000
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
PROJECT COMPLETION PATH
ACTION
Industry search
Identify substitutes
Prototype
Refine process
Issue report
CODE
342
342
342/96225
342/96225
342
ECD
03/95
05/95
09/95
11/95
01/96
MH ESTIMATE
80
80
320
80
107
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Elimination of Silver Cyanide Plating
COEPAG-01
Mike Romanelli
TARGETED MATERIALS/PROCESSES
SHOP*
96225
96225
96225
TOTALS
P
#
NUN
00-242-6341
00-237-2910
00-174-6581
NOMENCLATURE
Silver Cyanide
Potassium Cyanide
Sodium Hydroxide
LBS
IN
25
150
3100
3275
LBS
OUT
25
150
3100
3275
LBS
SAVED
25
150
3100
3275
108
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Removal of Plated Metal Coatings
RECOEP-01
Esra McDaniel
(904) 772-3444
342
PROJECT DESCRIPTION: Enstrip is used to remove Cadmium, nickel, and silver from
plated parts prior to rework. Enstrip is a cyanide containing process. Will expand the current non-
cyanide stripping process to include the remaining parts.
RDT&E REQUIRED:
SPECIAL FUNDING:
None
None
PROJECT COST
EQUIPMENT
INSTALLATION
MATERIAL
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
PROJECT COMPLETION PATH
ACTION
Industry search
Identify subs.
Prototype
Refine process
Issue report
CODE
342
342
342/96225
96225/342
340
ECD
03/95
05/95
09/95
11/95
01/96
MH ESTIMATE
80
80
320
80
80
109
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Removal of Plated Metal Coatings
RECOEP-01
Esra McDaniel
TARGETED MATERIALS/PROCESSES
SHOP*
96225
96225
96225
TOTALS
P
#
NUN
00-242-6341
00-237-2910
00-174-6581
NOMENCLATURE
Silver Cyanide
Potassium Cyanide
Sodium Hydroxide
LBS
IN
25
150
3100
3275
LBS
OUT
25
150
3100
3275
LBS
SAVED
25
150
3100
3275
110
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
Eliminating Chromate-type Conversion Coating on
Aluminum
COINCV-01
John Deitzel
(215)441-2033
NAWC Warminster
PROJECT DESCRIPTION: Chemical conversion coating is required on aluminum
surfaces prior to paint for paint adhesion and corrosion treatment. Currently, this process uses a
material containing chromic trioxide. Implementation of a chrome-free process would eliminate
this hazardous material.
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
RDT&E REQUIRED:
SPECIAL FUNDING:
On-going at NAWC Warminster
None
PROJECT COST
EQUIPMENT
-0-
INSTALLATION
-0-
MATERIAL
$1,000
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
PROJECT COMPLETION PATH
ACTION
Identify alternatives
Procure materials
Test & evaluate
Implement
Issue instructions
CODE
NAWC Warminster
720
340/94113
340/94113
340
ECD
08/95
10/95
11/95
11/95
12/95
MH ESTIMATE
300
40
16
40
40
111
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Eliminating Chromate-type Conversion Coating on
Aluminum
COINCV-01
John Deitzel
TARGETED MATERIALS/PROCESSES
SHOP*
94113
TOTALS
P
#
NUN
01-341-8609
NOMENCLATURE
Turcoat Alumigold
LBS
IN
825
825
LBS
OUT
825
825
LBS
SAVED
825
825
112
-------
PROCESS IMPROVEMENT PLAN
NADEPJAX PA2
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
PHONE NUMBER:
SHOP:
Elimination of Chrome Containing Chemical Conversion
Coating on Magnesium
COINCX-01
Jim Dixon
(904)772-4516/3444
342
PROJECT DESCRIPTION: Chemical conversion coating is applied to magnesium
surfaces for corrosion treatment. Current process utilizes sodium dichromate (chrome containing).
Implementation of chrome-free coating would solve problem.
RDT&E REQUIRED: None
SPECIAL FUNDING: None
PROJECT COST
EQUIPMENT
-0-
INSTALLATION
-0-
MATERIAL
$2,000
YEARLY CBA:
ANNUAL DISPOSAL COST:
MEDIA SHIFT:
PROJECT COMPLETION PATH
ACTION
Identify alternatives
Modifying equipment
Procure materials
Prototype process
Optimize
Implement
Issue instructions
CODE
340
46
723
340
340/94113
340
340
ECD
01/96
03/96
03/96
06/96
08/96
10/96
12/96
MH
ESTIMATE
200
100
40
80
100
40
40
113
-------
PROJECT TITLE:
PROJECT NUMBER:
PROJECT ENGINEER:
Elimination of Chrome Containing Chemical Conversion
Coating on Magnesium
COINCX-01
Jim Dixon
TARGETED MATERIALS/PROCESSES
SHOP*
94113
TOTALS
P
#
NUN
00-281-2686
NOMENCLATURE
Sodium Bichromate
LBS
IN
2200
2200
LBS
OUT
2200
2200
LBS
SAVED
2200
2200
114
-------
CHAPTER 7
PRIORITIES
P2 Projects documented in Chapter 6 prioritized, as directed by NAVAIRSYSCOM, in the
following order:
* Class I CDS
* RCRA Hazardous Waste
* HAPS Other Than ERA Top 17
* CLASS II CDS
* EPCRA
AGENCY
PROJECT #
65886-002
65886-003
65886-004
65886-001
65886-005
65886-006
65886-007
65886-008
65886-009
65886-010
65886-011
65886-012
65886-013
65886-014
65886-015
65886-016
65886-017
65886-018
65886-019
65886-020
65886-021
65886-022
65886-023
65886-024
65886-025
65886-026
PROJECT TITLE
Vortex Generator Gun
Elimination of 1,1,1-Trich
Particle Counter
Water Treatment Plant
Eliminate Chromic Acid Anodize
Coating on Aluminum
Aircraft Fuel Cell/Tank Repair
Naphtha Replacement
Post Strip Solvent
Spray Paint Equipment Solvent
Recycling P-D-680
M.E.K. Substitution
Toluene Substitution
Methylene Chloride Replacement
A/C Fuel Systems Pressure/Leak
Testing
Electrocoat Primer Demo
Powder Coat
PMB/Chemical Strip
Cadmium Plating Replacement
Eliminate 1,1,1-Trich/B earing
Cleaning
Eliminate Freon-113/Bearing
Cleaning
Eliminate Meth Chloride/Bearing
Cleaning
Eliminate Meth Chloride/Bearing
Cleaning
Circuit Boards Cleaning
PMB/Chemical Strip
Methylene Chloride Replacement
Low VOC Coating
PROJECT #
1234-TEELCM-01
CLSOGN-02
1236-TEHYEQ-01
1237-FATRTW-01
1238-COANCM-
01
1210-CLENOT-01
1110-CLAEPC-Ol
1110-COPRPT-02
1110-CLEQOT-Ol
1241-RCSOOT-01
1243-CLSOGN-01
1242-CLSOGN-01
1300-READOT-02
1233-TEFULK-01
1110-COPRPT-Ol
1110-COPRPT-03
1110-REPAAE-03
COEPCD-01
CLBEEN-01
CLBEEN-02
CLBEEN-03
CLBEEN-04
1300-CLELCB-01
1110-REPAAE-01
1110-REPAAE-05
1110-COPAAE-02
PROJECT LEAD
Terry Taylor
Jim Dixon
Clara Hagadorn
John Dinkins
Bruce Mobley
Andrew Yang
Caridad Roque
Caridad Roque
Caridad Roque
Caridad Roque
Andrew Yang
Andrew Yant
Andrew Yang
Laura Rossi
Hank Birdsong
Hank Birdsong
Steve Hartle
Mike Romanelli
Joyce Rollen/
Carol Brooks
Joyce Rollen/Bill
Somora
Joyce Rollen/Carol
Brooks
Joyce Rollen/Bill.
Somora/Thad Patin
Mike Linn
Rick Barnes
Rick Barnes
David Brock
PRIORITY
1
1
1
1
1
1
2
1
3
2
3
3
3
1
1
1
1
2
1
1
2
1
1
1
1
3
115
-------
AGENCY
PROJECT #
65886-027
65886-028
65886-029
65886-030
65886-031
65886-032
65886-033
65886-034
65886-035
PROJECT TITLE
HVLP Paint Equipment
Refrigerant Replacement
Ultra-High Pressure Waterjet
Meth-Chl/Potting Removal
Freon-113
Elimination/Instrument Bearings
Eliminate Silver Cyanide Plating
Removal of Plated Metal
Coatings (Enstrip)
Eliminate Chrome Conversion
Coating on Aluminum
Chrome Conversion Coating on
Magnesium
PROJECT #
COPAEQ-01
SFOPRF-01
RECOGN-01
1300-READOT-01
CLSOCM-01
COEPAG-01
RECOEP-01
COINCV-01
COINCX-01
PROJECT LEAD
David Brock/Carol
Brooks
Mike Clark/ Adrian
Gray/Kate Wood
R. Johnson/S. Hartle
Mike Linn
Joyce Rollen
Mike Romanelli
Esra McDaniel
John Deitzel
Jim Dixon
PRIORITY
1
1
2
3
1
2
2
3
3
116
-------
CHAPTER 8
POTENTIAL BARRIERS TO PLAN
Barriers associated with the budget process, R&D, engineering approval, etc., are
covered in the project POA&Ms discussed in Chapter 6.
117
-------
(Blank)
118
-------
CHAPTER 9
OTHER RELEVANT PLAN REQUIREMENTS
SOLID WASTE REDUCTION AND RECYCLING
NADEP Jacksonville, with the assistance of the Environmental Management Office
(code 003), is the DoD leader in finding innovative ways to reduce, reuse, and recycle solid
waste. During FY-94 the Depot recycled over 1,400 tons of solid waste resulting in total
revenues received or saved of more than $2.5 million. This far exceeded the CNO's 10
percent per year reduction for solid waste.
Through the efforts of the Clay County Association for the Retarded (CCAR), the
Defense Reutilization and Marketing Office (DRMO), Naval Air Station, Jacksonvile MWR,
and in-house equipment the Depot has developed outlets for 40 types of solid waste. These
range from easily recycled newspaper, cardboard, and aluminum soda cans to the more
difficult items such as machine tool coolants, tires, and plastic media blast (PMB) materials.
The Revenue generated from solid waste recycling is divided among the participants
that collected and recycled the waste for the Depot. CCAR and NADEP Civilian Emplyee
Welfare and Recreation Committee divided approximately $3,000 a year. NAS MWR
provides a token payment to the NADEP general operating fund for cardboard and plastic,
and all revenue generated through DRMO goes directly into the NADEP general operating
fund. This $2.5 million reduces overhead and helps keep operating cost down.
119
-------
(Blank)
120
-------
SOLID WASTE ANNUAL REPORT FY-94
RECYCLING REVENUE
MATERIAL RECYCLED THROUGH DRMO
MATERIAL
Carbon Steel
Light Steel
Heavy Steel
Aluminum
Titanium
High Temp Steel
Copper
Stainless Steel
Batteries (Lead Acid)
Tires
Brass
Lead
Magnesium
Silver
Nickel
Mercury
Subtotal
MATERIAL
White Ledger Paper
Color Ledger Paper
Computer Paper
Magazines
Filestock
Color Computer Paper
Newspaper
Aluminum Cans
Subtotal
GRAND TOTAL
POUNDS
00
339,456
00
55,013
00
216
9,685
20,100
I) 00
00
00
00
3,320
00
00
40
427,830
MATERIALS
POUNDS
105,910
26,935
21,470
1,800
15,960
ler 2,415
35,829
7,960
218,279
646,109
TONS
.00
169.73
.00
27.51
.00
.11
4.84
10.05
.00
.00
.00
.00
1.66
.00
.00
.00
213.90
RECYCLED
TONS
52.96
13.47
10.74
.90
7.98
1.21
17.91
3.98
109.14
323.04
DOLLARS
RECEIVED
$ .00
143,907.16
.00
10,204.76
.00
9,009.23
1,689.12
4,953.00
.00
.00
.00
.00
76.36
.00
.00
2,651.60
$ 172,491.23
THROUGH CCAR
DOLLARS
RECEIVED
$ .00
.00
.00
.00
.00
.00
.00
.00
$ 5,8878.16
$ 178,378.39
SOURCE
DRMO
DRMO
DRMO
DRMO
DRMO
DRMO
DRMO
DRMO
DRMO
DRMO
DRMO
DRMO
DRMO
DRMO
DRMO
DRMO
DRMO
SOURCE
CCAR
CCAR
CCAR
CCAR
CCAR
CCAR
CCAR
CCAR
CCAR
121
-------
COST AVOIDANCE
(BY REDUCING NEW PRODUCT PROCUREMENT)
MATERIAL
Machine Tool Collant
@ $ 8.59/Gal
Plastic Media Blast
Type V@ $ 1.06/lb
Aluminum Oxide Blast
220 Grit @$ .71/lb
120 Gril @ $ .43/lb
MetcoliteC@ $ 1.02/lb
Metcolite VF @ $ .88/lb
Glass Bead Blast
#13 @ $ .24/lb
#4@$ .56/lb
Subtotal
GRAND TOTAL
GALLONS POUNDS
19,500
COST
AVOIDANCE SOURCE
148,200 $
323,400
172,200
600
43,050
3,600
236,450
500
779,800 $
928,000 $
167,505 65000
342,804 94100
122,262 94100
258 94100
43,911 94100
3,168 94100
56,748 94100
280 94100
569,431 72300
736,936 (2)
122
-------
COST AVOIDANCE
(BY REDUCING LANDFILL DISPOSAL @ $150.00/tTON)
MATERIAL RECYCLED THROUGH DRMO
MATERIAL
Metallic and Non-metallic
COST
TONS AVOIDANCE
213.90 $ 32,085
SOURCE
Duval Co.
MATERIAL RECYCLED THROUGH CCAR
MATERIAL
TONS
COST
AVOIDANCE
SOURCE
Metallic and Non-metallic 109.14 $ 16,371 Duval Co.
MATERIAL RECYCLED THROUGH 72300/NAS MWR
MATERIAL
Cardboard
Paper NADEP
Shredder Paper NADEP
Clear Glass
Brown Glass
Plastic (Pet)
Subtotal
GRAND TOTAL
TONS
COST
AVOIDANCE
SOURCE
122.65 $
.00
1.43
.83
.37
1.24
125.42 $
448.46 $
18,397
214
124
55
21
18,813
67,269 (3)
72300
72300
72300
72300
72300
72300
Duval Co.
123
-------
COST AVOIDANCE
(BY REDUCING HAZARDOUS WASTE DISPOSAL @ $ 1.21/LB)
MATERIAL RECYCLED INTERNALLY BY NADEP
MATERIAL
Blast Media
Machine
MATERIAL
Machine Tool Coolant
Machine Pit Waste
Subtotal
POUNDS
779,800
COST
AVOIDANCE
SOURCE
GALLONS POUNDS
9,100
10,400
19,500
69,160
79,040
148,200
$ 943,558.00 94100
COST
AVOIDANCE SOURCE
$ 83,683 65000
95,638 65000
$ 179,322 00300
MATERIAL RECYCLED FOR NADEP BY OTHER COMMANDS
MATERIAL
Used Oil
GRAND TOTAL
GALLONS POUNDS
COST
AVOIDANCE SOURCE
49,476 336,437 $ 407,088 DRMO
1,264,437 $ 1,529,968 (4)
124
-------
TOTAL REVENUES RECEIVED OR SAVED
THROUGH RECYCLING AND COST AVOIDANCE
(1) Revenues - Recycling Generated (Actual Dollars) $ 178,378
(2) Cost Avoidance - Reduction of New Procurement 736,936
(3) Cost Avoidance - Reduction of Landfill Disposal 67,269
(4) Cost Avoidance Reduction of HW Disposal 1,529,968
GRAND TOTAL $2,512,551
Material Recycled During FY-94 1,403.72 Tons
Material Recycled During CY-93 1,244.27 Tons
Material Recycled During CY-92 712.68 Tons
Material Recycled During CY-91 287.00 Tons
Material Recycled During CY-90 104.97 Tons
12.8% Increase
74.0% Increase
148.0% Increase
63.4% Increase
Started Tracking
125
-------
(Blank)
126
-------
APPENDIX A
TARGETED CHEMICALS REFERENCES
Class I CDS Materials
Class II CDS Materials
RCRA Materials
EPCRA Materials
Hazardous Air Pollutants
40 C.F.R. 82 Subpart A, Appendix A
40 C.F.R. 82 Subpart A, Appendix A
40 C.F.R. Part 261.3 through 261.33
40 C.F.R. Ch 1, Part 372.65 and 40 C.F.R. Part 355
Clean Air Act, Title I, Section 112 and CAA
Amendment, Section 301
127
-------
(Blank)
128
-------
NADEP JACKSONVILLE
SHOP PRODUCTION AND PROCESSES SURVEY
BASELINE 1994
129
-------
(Blank)
130
-------
DEVELOPING A
POLLUTION PREVENTION
(P2) PLAN
\ IlowTa Btwk for Kentucky Generators
ishfd by
Kfintuclty Pollution Prtvriutun Center (APPO
-------
ABOUT THIS HANDBOOK
This handbook will help you prepare a pollution prevention plan for your business
or industry. Prepared to provide businesses with practical information on how to
approach, plan, and implement a hazardous waste reduction program-in-place, the
handbook motivates industry to search for administrative, material, or technology
changes that result in less waste.
With this book, you'll walk through each step of reviewing operations, identifying
and assessing pollution prevention options, and implementing and measuring your
progress. And within this book you can find answers to questions like:
• How do pollution prevention practices enhance regulatory compliance,
reduce risk, and source reduce wastes?
• Does Kentucky law include EPA's requirements for a waste
minimization "program-in-place?"
• How do I conduct a pollution prevention assessment?
• What steps are necessary in implementing various waste reduction
practices?
• What specific pollution prevention practices are businesses
successfully using?
• Where can I go with my questions on pollution prevention?
Because individual industries' needs vary widely, we encourage you to modify
procedures and techniques discussed here to meet your own unique requirements.
This book serves as a point of reference or benchmark, rather than a set of rigid
requirements.
The Kentucky Pollution Prevention Center (KPPC) staff developed this handbook
for use at statewide facility planning workshops. The Center offers these
workshops to help Kentucky industries and businesses comply with new
environmental laws and reduce the cost of waste management. KPPC's ultimate
goal is to promote pollution prevention and waste reduction through industrial
training and on-site technical assistance. The training programs seek to integrate
pollution prevention and toxics use reduction ethics into the industrial planning
and decision-making process.
-------
INTRODUCTION 1
DEFINITIONS 3
KY's GOALS & KEY DATES 4
HOWDOIDOIT? 5
1) MANAGEMENT COMMITMENT 8
2) DEFINING THE SCOPE, OBJECTIVES, AND GOALS 13
3) ORGANIZE A TEAM 15
4) CONDUCT A WASTE ASSESSMENT 17
5) TRACK TRUE COSTS OF WASTES 25
6) EVALUATE POLLUTION PREVENTION (P2) OPTIONS 32
7) IMPLEMENTATION 36
8) MEASURINGP2 RESULTS 38
9) A LONG-TERM COMMITMENT 41
BIBLIOGRAPHY 42
POLLUTION PREVENTION INFORMATION 43
Appendix A: RCRA Personnel Training Checklist 45
Appendix B: Wastestream Data Sheets 48
Appendix C: Contacts 52
Appendix D: Two Sample Pollution Prevention Plans 56
Appendix E: KPPC Fax Request Form 79
-------
INTRODUCTION
Kentucky Legislation and Policy
In the interest of protecting public health and the environment and responding to a
growing concern that solid and hazardous waste problems needed more attention
than they previously had received, the 1994 Kentucky General Assembly passed
legislation establishing a Commonwealth pollution prevention policy to:
"Encourage environmental leadership in pollution prevention by source
reduction when technically feasible and economically practicable, without
shifting risks from one part of a process or environmental medium to another. "
In the Kentucky Revised Statutes Chapter 224 Environmental Protection (KRS
224.46-305 et. seq.), the General Assembly finds that the best means to achieve
environmental leadership through pollution prevention for facilities generating
hazardous waste or releasing toxic chemicals are by:
• Providing technical assistance to reduce the release of toxic chemicals and
the generation of hazardous waste
• Encouraging facilities to adopt policies to prevent pollution, to prepare
comprehensive plans, and to develop measurable performance goals
• Providing economic incentives to reduce the amount of hazardous waste
generated and toxic chemicals released in the Commonwealth
• Using cabinet incentives to acknowledge the environmental leadership of
facilities meeting the pollution prevention goal
The law encourages businesses that generate hazardous waste or release toxic
chemicals regulated under Title HI, Section 313 of the Superfund Amendments
and Reauthorization Act (SARA) to develop a facility pollution prevention plan.
Pollution prevention planning stimulates in-plant changes which avoid, eliminate
or reduce toxic materials use and hazardous wastes. To be effective, the law
encourages facility planning with measurable performance goals which should be
based on production units for ease in comparing reduction efforts from year-to-
year.
-------
Kentucky's voluntary pollution prevention planning efforts are based on the
elements of EPA's voluntary "program-in-place" federal guidelines. The
"program-in-place" will help facilities meet the certification requirements found
on the Hazardous Waste Manifest ? a form which companies must use when
shipping hazardous wastes off-site.
Although Kentucky's pollution prevention policy is based on environmental
concerns, waste reduction also has positive incentives for industry. Pollution
prevention reduces operating costs, waste handling and disposal costs, and
liability risks. Companies that reduce wastestreams also improve their public
image. Whatever the type of waste, it represents the loss of resources and the loss
of money. Waste is an indication of inefficiency and as such, pollution prevention
makes sense in today's competitive marketplace.
-------
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DEFINITIONS
In its broadest sense waste reduction includes all practices that reduce the
amount of unwanted materials entering the environment — air, water or land;
whether hazardous or not. For regulatory purposes in Kentucky, however, the term
applies only to releases of hazardous waste and toxic chemicals. As used in KRS
224.46-315 to 224.46-325, pollution prevention means:
"In-plant practices that reduce, avoid, or eliminate the generation of hazardous
waste or the release of toxic chemicals at their source, rather than controlling,
treating, or managing hazardous waste or toxic chemicals after their generation
or release, to reduce the risks to employees, public health, and the
environment."
More specifically, pollution prevention means in-plant practices, including, but
not limited to:
• Process modifications
• Feedstock substitutions
• Product reformulation
• Management practices or housekeeping alterations
• Recycling within industrial processes
• Equipment replacement or modifications
The changes in management practices or housekeeping alterations would include
maintenance and preventive maintenance, training, inventory control and
improvements in housekeeping.
Pollution prevention and source reduction are used interchangeably throughout the
US and mean the same thing. Methods for achieving waste reduction divide
conveniently into two basic types: pollution prevention or source reduction and
recycling.
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Developing A Pollution Prevention Plan
Recycling is the use, reuse, or reclamation of a waste, either on-site or off-site,
after it is generated. Recycling methods include:
• The effective use or reuse of a waste as a substitute for a commercial
product
• Removing contaminants from a waste to allow its reuse
• Reclaiming useful constituent fractions within a waste material
KENTUCKY'S GOALS & KEY DATES
The Commonwealth's goal is to reduce the amount by weight of hazardous waste
and toxic chemicals generated by each Kentucky facility in 1987 by 25% by
January 1, 1997, and by 50% by January 1, 2002.
Each Kentucky facility which began operating after December 31, 1987, will have
a goal to reduce the amount by weight of hazardous waste and of toxic chemicals
generated by 25% within 10 years and 50% within 15 years after beginning the
operation.
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HOW DO I DO IT?
As you plan for the growth of your business and the changes in your product lines,
include pollution prevention ideas. Unfocused, ill-timed, or poorly managed waste
reduction efforts will lead to low performance and high cost. Don't make your
waste reduction program a fad — make it a culture and the way you do business.
In some form, all of the companies that accept or exceed environmental
regulations have an individual who takes the lead in environmental matters. This
"Environmental Coordinator," by delegation or enthusiasm, is usually the
pollution prevention "Cause Champion." The levels of commitment, creativity,
and consistency demonstrated by this person will strongly influence the success of
the environmental program and the pollution prevention planning effort.
Another influential factor is the allocation of resources — time, money, equipment,
and personnel. This allocation, in large part, is determined by the ability to justify
the need. This may not be strictly financial return on investment; consideration
must be given to the regulatory, liability, and cost avoidance aspects. The fear of
fines, the likelihood of litigation, or the certainty of increasing costs may be
sufficient to justify the expense, or it may be the desire to improve the business's
public image. Regardless of the motivation, the risks accepted by management are
based upon available data, and the long-term vision of the decision-makers.
It is the responsibility of the Champions to insure that the information provided is
factual and in agreement with the company's current environmental policy. But, it
is also their duty to help facilitate the changes in policy and practices necessary to
continually improve the corporate vision of environmental responsibilities.
Presenting these arguments to management, coaching employees in
implementation, and recording the benefits of your efforts are part of changing the
attitudes and perceptions of waste reduction in your company.
You probably have been designated as the Waste Coordinator for your facility or
you would not be reading this manual. You will not be able to perform these
duties by yourself. Pollution prevention requires that all options are considered;
therefore, others in the organization can, and will, be affected by the program. Get
everyone involved from the start.
A comprehensive plan will: determine options for pollution prevention, evaluate
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Developing A Pollution Prevention Plan
the alternatives, and consider the feasibility of implementation. Final
determinations of economic and technical feasibility, performance goals, and
other aspects of the plan are left to you and your organization.
To be effective and incorporate the elements of a program-in-place, your pollution
prevention plan should contain:
1) A written policy of management and corporate support for planning efforts and
a commitment to implementation
2) Written scope and objectives of the plan and establishment of quantitative,
production-related performance goals. (You can include a description of any
hazardous waste or toxics reduction accomplished prior to the planning law.)
3) Options to be evaluated and a schedule for implementation, based on a
pollution prevention assessment. Details of the plan should include:
• A list of all hazardous wastestreams
• Assessment of whether you need to set performance goals (If goal-setting
isn't practical at this point, list actions which will lead to your facility's
establishment of performance goals.)
• Evaluation of processes, operations, and activities that involve toxic
chemicals and create hazardous waste
• Evaluation of reduction options for each waste that you targeted in your
plan's performance goals
4) A cost allocation system for waste management. If feasible, the system should
identify these:
• Purchase price of hazardous and toxic materials in the waste stream;
• Hazardous waste treatment, storage, and disposal costs
• Associated environmental liability costs for use of hazardous materials and
disposal of hazardous wastes
• Oversight costs for maintaining environmental compliance
5) Employee awareness, involvement, and training programs for pollution
prevention efforts
6) A description of your procedures to make pollution prevention an on-going
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effort and evaluation of your program-in-place.
Writing and implementing a pollution prevention plan is similar to writing any
other business plan. This handbook will help you begin writing your plan. Make
sure your plan clearly reflects the reasoning behind the planning, what the plan
requires, and who will implement it.
From our experiences working with industries interested in reducing their waste,
we have found nine elements of a successful plan and program:
1) Obtaining management commitment
2) Defining scope, objectives, and goals
3) Using a team approach
4) Conducting a waste assessment
5) Tracking the wastestreams
6) Evaluating waste reduction options for technical and economic feasibility
7) Implementation
8) Measuring results
9) Long-term commitment
Let's examine these elements in more detail.
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Developing A Pollution Prevention Plan
1) MANAGEMENT COMMITMENT
Since goals and policies are established by management, a successful pollution
prevention program requires sincere corporate commitment. The program must
become a functioning part of a firm's standard operating procedures., including
product development, operational procedures, and training. High-level
management commitment keeps the pollution prevention program active in all
areas of the company by committing time, personnel, and financing. Management
must be willing to give the pollution prevention team the authority and
responsibility to implement the program. Lack of this commitment often becomes
an obstacle to waste reduction.
A formal policy statement best conveys pollution prevention program objectives
to employees. Consider including these points in your environmental policy
statement or operating guidelines:
• Environmental protection ? Make the production line responsible for
environmental protection. Measure employee performance against the
set goal. In addition, make every employee as responsible for
environmental protection as they are for safety or quality
• Reducing or eliminating waste is a main goal in research, process
design, and plant operations and is as important to management as
safety, yield, and loss prevention.
• Consider reusing and recycling materials before classifying and
disposing as a hazardous waste.
In the policy statement for your facility, you may also want to list motivations for
pollution prevention planning, such as regulatory requirements, product quality,
cost and liability control, and worker health, safety, and risk reduction. Make the
exact language appropriate to your facility.
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EXAMPLE POLICY STATEMENTS
1. [Your Company] advocates a clean and safe environment. Its policy is to
minimize the generation of hazardous and nonhazardous solid wastes and,
insofar as possible, to eliminate air and water pollutants. It seeks the help of
all employees in the achievement of these objectives. Further, [Company]
wants its employees to be fully aware of all hazardous and potentially
dangerous chemicals or equipment used in the work place and to use them
in a completely safe manner. Finally, it is [Company]'s desire to operate in
full compliance with all applicable Federal and State environmental
regulations.
2. [Your Company] is committed to excellence and leadership in protecting
the environment. In keeping with this policy, our objective is to reduce
waste and emissions. We strive to minimize adverse impact on the air,
water, and land through excellence in waste reduction. By successfully
reducing waste at its source, we can achieve cost savings, increase
operational efficiencies, improve the quality of our products and services,
and maintain a safe and healthy workplace for our employees. Secondarily,
[Your Company] promotes environmentally sound recycling, reuse, and
reclamation of all wastestreams.
3. At [Your Company], protecting the environment is a high priority. We are
pledged to eliminate or reduce, wherever possible: 1) our use of toxic
substances; 2) our release of toxic pollutants; and 3) our generation of
hazardous and other wastes. When wastes or releases cannot be avoided, we
are committed to recycling, treatment, and disposal in ways that minimize
any undesirable impacts on the air, water, and land.
4. [Your Company] and all its employees are committed to a sound
environmental program directed to bring hazardous and all waste to the
lowest level, using the best available technology.
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Developing A Pollution Prevention Plan
5. [Your Company]'s policy is to reduce all hazardous and non-hazardous
waste to the minimum levels economically and technically practical and to
be in full compliance with all Federal and State waste regulations;
As both a responsible citizen and [Company] employee, each individual is
responsible for reducing waste during working hours, for complying fully
with all waste reduction program goals established by the company, and for
not violating any Federal or State waste regulations;
Employees are urged to come forth with suggestions for further reducing
waste in their own work area and in any other areas about which they may
have ideas.
6. [Your Company] is committed to excellence and leadership in protecting
the environment by striving to minimize adverse impact on the air, land, and
water through pollution prevention and energy conservation. We are
dedicated to identifying and implementing pollution prevention
opportunities through training and awareness building programs for all
associates.
The attached policy outlines [Your Company]'s corporate policy with
respect to environmental and safety issues. We pledge to eliminate or
reduce our use of toxic substances and to minimize our use of energy and
generation of all wastes, whenever possible. Prevention of pollution at the
source is the preferred alternative. When waste cannot be avoided, we are
committed to recycling, treatment, and disposal in ways that minimize
undesirable effects on air, water, and land.
ENVIRONMENTAL PROTECTION IS EVERYONE'S RESPONSIBILITY
, Plant Manager
YOUR TURN - Develop a "draft" written policy statement for your facility.
Can you keep it to 25 words or less?
10
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Management Practices and Procedures
Pollution prevention and environmental programs must provide more than just a
policy statement if there is to be implementation. Management must be willing to
give authority and responsibility to the pollution prevention team to implement
the program much like they have with quality management system teams. The
following paragraph is an example of how one plant set forth new management
practices and procedures that showed the overall commitment to the pollution
prevention plan, team, and program.
"The commitment of management to pollution prevention and waste reduction is
incorporated in the company environmental policy. Economic incentives
associated with this process are sufficient to force management to actively pursue
alternatives to reducing costs associated with current usage and waste generation
levels. In order to ensure on-going efforts in this area, a pollution prevention team
will be implemented, consisting of all departments. This group will set goals and
monitor progress in attaining these goals. Management will demonstrate personal
commitment to the objectives and praise the commitment demonstrated by the
pollution prevention team."
Once management signs and dates the policy statement, display it prominently and
distribute it widely. How you first distribute the written policy to employees
indicates company commitment. Posting it unexpectedly at work stations sends a
negative message. Calling a special meeting to review Kentucky's voluntary
pollution prevention program, explaining and distributing copies of your
company's own policy, and asking for employee ideas sends a positive signal.
YOUR TURN - List some ideas here for promoting the policy statement at
your own company.
11
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Developing A Pollution Prevention Plan
Another example of a positive signal for management commitment of the overall
pollution prevention program at a facility is a certification statement of
understanding and support by the owner or senior management as a cover page for
the plan. The following is an example certification used by one plant.
POLLUTION PREVENTION PLAN
Facility Identification and Information
Company Name:
Mailing Address:
Contact Person: Telephone:
Certification:
I certify that I have personally examined this pollution prevention plan, and that I
am familiar with its contents and all attachments. Based upon my inquiry of those
persons immediately responsible for obtaining the information, I believe the
information presented in the plan is true, accurate, and complete.
Owner or Senior Management Official
Name (Please print or type) Title
Signature
Although a commitment to reducing waste should begin with management,
employees often suggest improvements in day-to-day operations. Employees
generate the waste and they can contribute to the overall success of the pollution
prevention program. Inform and involve employees at each step in developing and
implementing a program and solicit their cooperation. Employee involvement
will be discussed further in section 3.
12
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2) DEFINING THE SCOPE,
OBJECTIVES, AND GOALS
The scope of the pollution prevention plan is to include all managers and
employees in implementing the company's policy. Initially, review historical
waste generation and the current technologies and procedures being used. Then,
outline possible future technologies and procedures that will reduce generation of
wastes. In addition, analyze existing training levels and future training needs.
General project objectives developed by management and the assessment team
can include:
• To comply with all environmental laws and regulations
• To achieve a significant reduction in the generation of hazardous wastes
and toxic chemicals through avoidance and source reduction
• To work towards developing reliable means of measuring reductions
• To improve the health and safety aspects of the workplace
• To advise and train employees in environmental and pollution prevention
matters, actions, and responsibilities
• To increase research and development activities with a focus on finding
substitutes for hazardous raw materials used in production
• To maintain product quality
• To sustain the facility's growth for a five-year period
• To meet the corporation's economic requirements.
YOUR TURN - What are the scope and objectives for your organization?
13
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Developing A Pollution Prevention Plan
Another important aspect to achieving commitment is to set pollution prevention
performance goals for the smallest practical operating entity (a business unit, a
production line, or an individual worker) and to provide incentives to the
employees for achieving or surpassing those goals. The workers should participate
in the setting of the goals and agree to them before they are brought to
management for endorsement.
When you are setting the overall goals for the pollution prevention program, make
them effective goals that are:
• Acceptable to those who will work to achieve them
• Flexible to adapt to changing requirements
• Measurable over time
• Suitable to the overall corporate goals
• Understandable
• Achievable with a practical level of effort
YOUR TURN - What are the goals for your organization?
14
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3) ORGANIZE A TEAM
The keys to reducing waste generation ? commitment, involvement, and teamwork
? are basic to many work place successes. Owners and managers can determine
priorities and set the tone of the company's waste management efforts, but it takes
everyone to make it happen. Once everyone understands how reduction of toxic
substances and hazardous waste fits into company policies and practices,
opportunities for participation are unlimited. Everyone in the facility is involved
in some way in changing how it operates.
A technically competent person with sufficient authority to do the job should
select and lead the team. A company needs to identify a "Cause Champion" with
the following attributes:
• Familiar with the facility, its production processes, and its waste
management operations
• Familiar with the people
• Familiar with quality control requirements
• Good rapport with management
• Familiar with new production and waste management technology
• Familiar with pollution prevention and waste reduction principles and
techniques and environmental regulations
• Aggressive managerial style
When planning for pollution prevention ask yourself these questions:
• Who can help you understand your facility?
• Who can help you change how your facility operates?
• Who can help you maintain your waste reduction plan as old
challenges are met and new opportunities arise?
Although a commitment should begin with management, production operators and
line employees can often suggest improvements in the operations. They possess
first-hand knowledge and experience with production and operation processes.
They can assist especially in assessing operational or procedural changes, or in
equipment modifications affecting the way they work.
The team approach is best since it combines a wide range of experience,
15
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Developing A Pollution Prevention Plan
knowledge, and perception of the issues. Include representatives from:
Management Engineering Production
Environmental Quality Product Design
Operators Purchasing Accounting
Consultants Vendors/ Suppliers Shipping/Receiving
No pollution prevention program is successful without the full cooperation of all
employees. To obtain cooperation, the role of training is very important.
Secure employee commitment to pollution prevention by training them in waste
reduction procedures, encouraging them to come forth with ideas, asking them to
participate in the setting of waste reduction goals and procedures, and by
providing them with incentives to achieve those goals.
Training the staff, especially the supervisors, in the importance of pollution
prevention and the procedures employed allows everyone to understand the goal
of the organization. Your plan should include a description of the:
• Types of awareness activities and training courses provided
• Schedule of awareness activities and training courses offered
• Methods of documenting the training
The pollution prevention training can be a part of the RCRA hazardous waste or
Worker Right-to-Know training programs. In Appendix A, you will find an
excerpt from 40 CFR 265 on required personnel training for RCRA and a handy
RCRA personnel training checklist.
YOUR TURN - How can you incorporate pollution prevention training into
your current RCRA hazardous waste training program?
To reduce waste successfully, management must recognize the value of employee
involvement. If management initiates and encourages employees to develop and
implement a program, pollution prevention changes will occur.
4) CONDUCT A WASTE ASSESSMENT
16
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The likelihood of finding cost-effective options for reducing hazardous wastes is
directly related to understanding the relationships between your operations, the
toxic substances used, and the wastes generated. Enlarge your understanding of
these relationships by reviewing plant operations and conducting a toxics use and
hazardous waste pollution prevention assessment.
Consider a pollution prevention assessment in several stages:
• Preview your plant's operations, chemical usage, business practices,
and wastes generated
• Walk through your facility to verify your findings and identify reasons
for your wastes
• Document your findings
The size and type of your business will determine how much effort you put into an
assessment. The owner of a very small business might conduct an assessment
alone in four to six hours. Larger manufacturing or multiple- process firms benefit
from a team assessment that may take several weeks. You'll need several people
with diverse skills to evaluate complicated wastestreams, analyze multiple kinds
of equipment, and contribute to economic analyses. This is where the team
approach to pollution prevention is crucial.
17
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Developing A Pollution Prevention Plan
To preview your organization, ask the following questions about your current
operations:
• What are this facility's current processes/operations?
• Why do we do each process/operation this way?
• What are the consequences of doing each process/operation this way?
• What are the wastestreams generated from each process, and how
much?
• Which wastes are classified as hazardous and which are not? What
makes them hazardous?
• What input materials do you use that generate wastestreams?
• How much input material from a particular process enters each
wastestream?
• How much of a raw material can you account for through fugitive
losses?
• How efficient is the process?
• Are unnecessary wastes generated by mixing otherwise recyclable
hazardous wastes with other process wastes?
• What types of housekeeping practices do you use to limit wastes?
• What types of process controls do you use to improve process
efficiency?
Before the assessment walk-through, have the pollution prevention team answer
these questions and prepare an agenda of points still needing clarification. The list
can contain objectives, questions, and further concerns.
18
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Pollution prevention assessments identify and profile wastestreams, how they are
generated, and the amount of waste generated by each. A pollution prevention
assessment helps you identify cost-effective approaches to reducing waste volume
and toxicity. You can then better decide how to use resources for source reduction
and recycling programs. A waste assessment alone will not reduce waste, but it's a
good start.
Pollution prevention assessments are not one-time projects. Goals are re-evaluated
as changes occur. Such changes might exist in available technology, raw material
supplies, environmental regulations, and economic climate. Effective facility
pollution prevention planning requires an annual review and update of your
plan and accomplishments.
After the assessment team identifies wastestreams and creates a checklist, it's time
to survey the plant site. Become as familiar with the site as possible. Although the
information you collected is critical to understanding the processes involved,
seeing the site in operation is also important. For example, a process unit may
operate differently from the method originally described in the operating manual.
Employees may have made undocumented changes in flow diagrams or to
equipment. The site inspection resolves questions which might arise during your
review.
The site inspection also provides information that supplements what you learned
earlier. Throughout your tour, team members should use the inspection checklist,
ask questions about the above items, and look for specific opportunities to reduce
waste. They should verify information gathered prior to the site inspection.
Assessors should talk with employees who operate processes and equipment. The
employees' experience and opinions concerning pollution prevention and waste
reduction options can be quite valuable. The assessors should review the data
during or just after the survey. This review can help you identify missing or
inaccurate information. From it, you can make additions and corrections to the
waste flow diagram. Examine each step in the manufacturing process from the
delivery of the material to the storage and shipping of the final product.
Use something similar to the following worksheet for each wastestream at your
facility. Appendix B also has examples of "Wastestream Data Sheets" being used
at a plant.
19
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Developing A Pollution Prevention Plan
WASTE ASSESSMENT
INSTRUCTIONS: Copy this form and use one copy for each process.
Summarize each process selected for detailed review along with its associated
toxic substances and wastes.
Date: Process, Operation, or Activity:
For each wastestream generated, determine:
• Point of origin
• Subsequent handling/treatment/disposal
• Physical and chemical characteristics
• Quantity
• Rate of generation (i.e., Ibs/unit of product)
• Variations in generation rate
• Potential for contamination or upset
• Cost to manage or dispose
List all toxic substances used in this process:
List reduction options for this process:
Which option is economically most feasible? Explain:
20
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21
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Developing A Pollution Prevention Plan
Which option is technically most feasible? Explain:
How much reduction is achieved? Develop a performance standard for this
wastestream based on this information.
List the positive or negative cross-media impacts on the environment or
employee health and safety.
Toxic substances affected:
Other wastestreams affected:
Products affected:
Option proposed on (date):
Option approved for implementation:
YES NO Date:
Reason for acceptance or rejection:
22
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If you have many wastestreams that are generated at your facility, you probably
will want to prioritize them before you start the assessment. Some typical
considerations for prioritizing wastestreams to assess include:
• Compliance with current and future regulations
• Costs of waste management (treatment and disposal)
• Potential environmental and safety liability
• Quantity of waste
• Hazardous properties of the waste (including toxicity, flammability,
corrosivity, and reactivity)
• Other safety hazards to employees
• Potential for (or ease of) reduction
• Potential for removing bottlenecks in production or waste treatment
• Potential recovery of valuable by-products
• Available budget for the pollution prevention assessment program and
projects
Based on the collected information, you can develop a flow diagram and material
balance for each process step. The diagram should clearly identify the source,
type, quantity, and concentration of each wastestream. Use the background
information to identify data gaps, sampling points, problem areas, and data
conflicts.
Example Flow Diagram
23
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Developing A Pollution Prevention Plan
Flash solvent
makeup
Dirty pans
flolaasa flsferasa
to sir 10 ait
r *«
J:
24
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The waste assessment tracks all waste produced at a business to find out where it
was generated. Break it down into these elements:
• Alternative procedure and process decisions for the following:
V Identify housekeeping and operating procedures which will reduce
waste and include a description of these procedures in the plan
V Survey production equipment and facility technologies to ensure no
excessive waste is generated
V Waste separation by compatible groups to enhance reuse
V Preventive Maintenance Programs: Maintaining equipment history
cards on equipment location, characteristics, and maintenance
V Operation of equipment to minimize energy use and material waste
V Review employee training programs to include pollution prevention
goals and to encourage employee participation in the program
• Inventory of raw material supplies and waste sources to include:
V Material and waste balances
V Sources of chemical use and waste generation
V Points of waste discharge
V Chemical profile of wastes (why they are hazardous)
V Waste disposal costs
25
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Developing A Pollution Prevention Plan
• Priority framework to include:
V Analyze and review chemical hazards for acceptance
V Assess risk and require prior approval of all chemicals before being
received on-site
V Estimate cost of pollution prevention and waste reduction
V Estimate liability costs, especially long-term
V Identify management criteria for importance
V Prioritize wastes for the pollution prevention program
Once you identify your wastes, quantify and determine their costs as accurately as
possible. Reports which you've submitted to regulatory authorities can help you
estimate waste quantity and disposal costs. A record of the frequency of waste
pulls and tipping fees is often on file at your facility. Develop further details by
having team members measure individual wastestreams over a period of time to
establish a verified generation rate. The difference between the amount of material
purchased and the quantity shipped as product components is your estimated
waste.
26
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5) TRACK TRUE COSTS OF WASTES
An accounting system should be in place to routinely track the quantity, disposal
method, and disposal costs for every wastestream produced. This information is
very useful in identifying waste reduction opportunities, prioritizing efforts, and
tracking the overall success of the program. The costs of waste management
includes more than just the fee paid to the removal contractor. True costs of waste
management include:
• Calculating costs of wastestream materials, based on the purchase
price of those materials. The value of the waste material is the initial
cost less any scrap credits
• Calculating the cost of managing wastes, including costs for personnel,
recordkeeping, monitoring, training, inspections, manifesting, and
labeling. Also include costs for transportation, laboratory fees,
penalties and fines, liability insurance, pollution control equipment,
treatment and disposal and others.
• Estimating the cost of waste reduction (include initial costs,
amortization, depreciation, tax rebates, pay back potential, labor costs)
• Estimating liability costs, especially long-term
These costs should be charged to the product or the process that generates the
waste. Department managers can be motivated to reduce waste when they realize
the costs. A tool that is gaining a lot of popularity in pollution prevention payback
is Activity-Based Costing or ABC. When a company initially benchmarks its
departments and operations, it is for cost reduction.
The benchmarking process to determine the true cost of waste management forces
us to begin assigning costs to all activities associated with the process including
handling, training, storage, oversight costs and the value of the lost raw material
in the wastestream. The process of assessing pollution prevention projects,
particularly the financial analysis component, fits within the framework of the
standard capital budgeting model yet expands on and broadens the way traditional
capital budgeting is often practiced.
27
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Developing A Pollution Prevention Plan
The ABC financial approach attempts to rectify the tendency in financial analyses
to omit environmentally-related costs, which typically are lumped into overhead
accounts, arbitrarily allocated to products, and overlooked in the cost
identification process. Several limitations of a traditional accounting system are
cost allocations are NOT appropriate or relevant because they are managed by
accounts without process knowledge and the information is static or even after-
the-fact which is too late for strategic planning.
Look at the allocation of costs in a traditional or conventional cost accounting
system in the diagram below. Notice that Process A is non-toxic and generates no
hazardous waste while Process B uses a solvent in cleaning and generates a spent
solvent for disposal. In a traditional cost system, 50% of all overhead costs are
assigned to each process based on labor in dollars.
CONVENTIONAL ACCOtNTFNr, SYSTEM
,., ,,-,. 1 r\(irihutufn br» hf'-flfl1 Viftft Input;
*'5'l /!% S\ ^=*^%^^
Dl RE<
l.ABOF
OVERHEAD
Mwilitiirirrg & Re|«ortiin|
Lain" I tag & .Manifesting mmm
Rit'llf-ki-Krw* Trauaui;
W iixtt? Di3|^>«ijii
L'tiJiiN-'i & ri'fprt"<'k*4J"4>n
,, . r" ; !
Cra^ng Li{tiipmt'iitHfn ha1!fit
on Ijihor Dalian
By
The Northeast Waste Management Officials' Association
The Massachusetts Office of Technical Assistance, 1994
28
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In an ABC system, or full cost system, 100% of the labeling and manifesting
costs, permits and fees, and Right-to-Know training costs are assigned to Process
B because of the spent solvent. Also, Process A has reduced insurance,
monitoring, and reporting costs because it is non-toxic.
The following diagrams visually show you what to think about during an
assessment to assign costs and determine pay back for pollution prevention
opportunities which will help the project compete for funding. These hidden costs
can make the difference in funding market-driven, pollution prevention options.
OVERHEAD AM .QC ATION USIM",
KILL COST SYSTK.M
OVtKHE.AD
Taws S Insurant?
Monitoring & Reporting *.
1 Waste DiijHftai r~"
5 l.'tititits & Di-precmliun
' Labeling >& Mamfnluig
eow Training
Permit* X
OVURJIEAD COSTS FOR PKOCESS B
Mor.JK-rt
L-Sbei'-m?
Ri|Shl-f:V
Waste I)
Uuiiiii!?,
Jgggnyij
Penr-ivS ;
Ta«s &.
Total Ok
CKcrlioa
riiAJ5-cP*; 1:rJ-
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-------
Developing A Pollution Prevention Plan
As your company incorporates pollution prevention approaches in its strategic
planning, capital investment priorities need more management attention and
coordination. Qualitative dimensions of assessing pollution prevention projects
needs better management review. The following list of "Potential Operating
Costs" is adapted from material published by the Tellus Institute. The italicized
items are those most likely not to be included in the financial analysis of a
pollution prevention project either because they are hidden in overhead or because
their allocation is insufficiently specific.
POTENTIAL
dinxt j)-.~odu,". rrctt;in;••
f^lt'H >f-> !-.%'«< A« !'l s-.'i'-'-
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' w.rfrl :•!.:.:"..;::-::•, %K,:r.:eS
fc COSTS
Fulurr Li;"it'iliE;
By
The Northeast Waste Management Officials' Association
The Massachusetts Office of Technical Assistance, 1994
30
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Pollution prevention projects often have impacts on a broad range of issues, such
as market share, materials usage patterns, and process modifications, that are
difficult to quantify but that may be of strategic importance. To provide a
comprehensive and accurate assessment of the potential benefits of a pollution
prevention project, it is crucial that all costs and less tangible items are identified
and evaluated in a project proposal.
The following table provides examples of various environmental cost activities
(Activity), the way those activities might be defined for determining frequency or
volume (Cost Driver), the information needed to calculate the costs of the
activities (Measurement), and the sources of information about the activities
(Source)
ACT! yrry cosji; U_KJ_VEI<
SpIii'Lcak IBCCXT.I Hunter cf'SpilU T.jbor ifem
ScgHUng Nurabe: nl Intafcnls $,"ai'cl;
Sfcislcnnf: ' Nuiribc' nf toxics 1 jtwi \-lf,-,uf
Nunilx-i ^rf Pnx-e^cf- S^'vvL't'k
NumScr of Siiiiiivienis Later Hcur« •
ol Scssion-s Labor Hours
SOURCK
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Pfrmihin| & Fees SJiitrixTc' "I'c^ir.ii Labor i-!oi!rs Engineer ImeiMcu
Lhs . Disirtanns! _|re5(S;rhc-ni"JI ur-'Uii Rpjuljt3T-" -5>-Uin*r.
Mnnf.'.:r,-^'j^rS~ Njiulvi i:f fvU.-hinci I jitxii Ham;, M:irh:nc Mxmlfaurcr
.ijrare ;xic:!Ji'i|-jipincM OnislcU* Repair Shop
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S''d!«uriic.',I:»-ji-|:-i", 'I"J3A R«pnir-g Form
LngiiKflrng Records
LPE i*i«%n up Rcrwdi
By
The Northeast Waste Management Officials' Association
The Massachusetts Office of Technical Assistance, 1994
31
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Developing A Pollution Prevention Plan
Activity-Based Costing (ABC) is a two step process — first, you determine the
costs of significant activities and second, you assign the costs of activities to cost
objects such as products, customers or services. When assigning costs, you have
to remember that some facility-level costs do NOT go away such as the CEO's
pay, environment, health, and safety, research and development and even the cost
of accounting. We have to assign those costs to activities so that quality, delivery,
costs, and time are evaluated simultaneously. The following diagram offers one
example of how issues and costs might be mapped for a particular pollution
prevention project.
EXAMPLE
Conventional
Costs Lcs* Tangible Costs
STRATKfJK?
SlliMFICANCE
* Waste Pi*
* Raw Materia
* MafMgcm
* Training
* Record k
r-.
* Criminal Lib
* Prd Quality/ ,
Market Shan;
* Financial Liability
,, * Shareholder
m KosDurcrs
Re Ifit ions
* Cniptoycc IleaKb & Safety
» Fines |
pping
QUALITATIVE
(Ji'AliTATIl'E
By
The Northeast Waste Management Officials' Association
The Massachusetts Office of Technical Assistance, 1994
32
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Environmental costs are broken out in the following table and you can see that
they are not just based on labor hours to perform tasks but rather, reflect labor,
materials, equipment and other costs such as insurance and regulatory fees. These
are the common cost items often associated with pollution prevention projects.
IvN VIUONMKNTAL COS'I *
I ABOU
c-ivducrx-.n .,vnr:<
man-rial hardline
instJ.-oi.-m
rccorek-cpiiis
manifesting
labclina
stocking
miimrM
psftnirting
MATERIALS
iav,- materials
solvents
process ivalcr
efcamnf water
o'fficc supplies
!rs:nii!ft malenals
saferv inatciu-ili
Tiarrs
EQUiPMtM- OITII:K
product JAn ftt'i'itijidirii! iti'prrf taii«in
cjcinirKi.'CcareiL^nLi Swasn* diS|iftsal
material handlirj; r/ichi-K--. MsHjrarK'e
waste ifC3tn:en! ; iiiitilics
wastcwatcr treatment \ refiuiatory fees
air pcllulion conirol . taxes
j;nin"jriK fijuiprncnt ; niaLitenaact"
j'ro;ecrivf squip'i^Tii lab Ices
storage equip-tieni
By
The Northeast Waste Management Officials' Association
The Massachusetts Office of Technical Assistance, 1994
YOUR TURN - What records and personnel will you need to establish an
activity-based accounting system for multi-media wastes, energy and time?
33
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Developing A Pollution Prevention Plan
6) EVALUATE POLLUTION
PREVENTION (P2) OPTIONS
When the causes of waste are understood, the pollution prevention assessment
process enters the creative phase. Your objective at this step is to generate a
comprehensive set of pollution prevention options. Consider every wastestream as
a reduction opportunity until proven otherwise. Most of the time, an opportunity
exists if a wastestream exists.
Following the collection of data and site inspections, the members of the team
will have begun to identify possible ways to reduce waste in the assessed areas.
Identifying potential options relies both on the expertise and creativity of the team
members. Much of the information you need can come from their education and
on-the-job experience.
Don't forget to utilize available pollution prevention information resources such as
the Kentucky Pollution Prevention Center (KPPC), the Waste Reduction Resource
Center for the Southeast, EPA's telephone hotlines and the Enviro$en$e electronic
bulletin board, or the Kentucky Department of Environmental Protection
(addresses and phone numbers are at the end of this handbook in Appendix C).
Also, associations, vendors/suppliers, and consultants are valuable resources.
These and many other sources contain information on what other companies have
done to source reduce waste generation.
Rank your options using the following waste management hierarchy:
1) Source reduction options:
• Improved operating practices
• Employee training and awareness programs
• Scheduling to eliminate frequent equipment cleaning
• Process improvements
• Input changes
• Changes in the composition or design of a product
• Separation of wastes
34
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2) Reuse/Recycling options:
• Return a waste into the originating process as a substitute for a raw material
• Use a waste as a raw material in another process
• Reclaim a waste for sale or use as a fuel
• Utilize waste exchange services
3) Treatment options:
• Process a waste, hazardous or not, to reduce disposal cost and to minimize
environmental damage. Consider treatment options only after identifying
all acceptable pollution prevention techniques.
Your pollution prevention team should list all the possible opportunities to reduce
waste within the facility. The list may include several options for each
wastestream or process. At this stage in the assessment process, assessors should
not consider in detail the technical or economic usefulness of any particular
option. Develop the list based on a broad range of general opportunities identified
by asking questions about each phase of your process:
• Product design: Does product design require use of hazardous materials in
later stages of production? Could negotiation with the customer produce
desirable changes in product formulation or design?
• Raw material substitutions: Would different materials result in a
less-hazardous or less-toxic product? Do raw materials require use of
hazardous materials in later stages of production?
• Materials handling: Is the form in which raw materials are received
constraining design or processing? Are materials delivered in just-enough,
just-in-time fashion?
• Changes in processes, equipment, or operations: Would upgrading
machinery result in less use or release of hazardous materials? Do
production runs and schedules optimize the use of material?
Housekeeping procedures: What housekeeping or operations procedures
35
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Developing A Pollution Prevention Plan
cause problems later on?
Maintenance procedures: Is maintenance adequate, regularly scheduled,
and implemented?
Training procedures: Are operators trained in (and using) the most efficient
production processes?
In-process recycling/reuse: Are there ways to recycle materials within the
production process for later reuse?
Reclaiming, recycling, and reusing of wastestreams: Are there ways to
recycle materials outside the process, at the facility, in a way that
minimizes the risk of worker exposure or release to the environment?
WHAT HAVE YOU FOUND?
Now you're ready to discuss your results with plant personnel and company
management. The screening activity should promote the best options for technical
and economic feasibility analyses. You need a detailed analysis from both the
technical and economic viewpoints in order to choose the best waste reduction
options.
Technical evaluation
Determine whether a proposed option will work, and whether there are any facility
constraints or product requirements which make it technically unwise to install
and operate. The completed technical evaluation is reviewed by ALL affected
groups. If a project appears impractical, or is found unacceptable through
unsatisfactory answers to any of the questions on the next page, drop it until more
promising options have been investigated.
36
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Economic evaluation
If capital expenditures are necessary, generate as accurate an estimate as possible
of the total cost of implementation. Companies with sizable engineering
departments probably have pre-set methods of estimating capital projects. If you
are a smaller company, be sure that the capital cost estimate includes ALL costs
incurred in getting the new process or equipment to the site, installed and ready to
operate.
There may be increased costs you must consider in operating cost estimates:
energy, material handling, maintenance, training, etc., for the new process or
equipment. Use the capital and operating cost estimates as the basis for arriving at
a final recommendation by whatever method the company normally uses for
profitability analysis (i.e. return on investment, pay back period, net present
value).
During the screening procedure, assessors should consider:
• Does it have a good track record? If not, is there convincing evidence that
the option will work as required?
• What other benefits will occur?
• Does the option have a good chance of success? (A successful start for a P2
program will gain wider acceptance as the program progresses.)
• Can you implement it within a reasonable amount of time without
disrupting production?
• Does the necessary technology exist to develop it?
• What is the main benefit gained by implementing this option (e.g.,
economics, compliance, liability, workplace safety, etc.)?
• How much does it cost? Is it cost effective?
These technical and economic calculations should lead to the final ranking of the
most reasonable options. The waste assessment tracks all wastes produced at a
business to find out where it was generated. When the tasks outlined above are
completed, you can write into the plan a description of options and a schedule for
implementation. You will find some options (such as procedural changes) are
inexpensive and quick to implement. The screening procedure should account for
ease of implementation. If an option is clearly desirable and inexpensive, promote
it.
37
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Developing A Pollution Prevention Plan
7) IMPLEMENTATION
Implement operational, procedural, or materials changes (without changing
equipment) as soon as you determine potential cost savings. In plans that call for
equipment changes, it's essentially no different from any other capital
improvement project. The phases of the project include planning, design,
procurement, and construction or installation.
Once the reduction techniques are identified, develop an implementation plan for
each wastestream. This plan should include the implementation schedule,
equipment needs, conceptual design, implementation requirements, management
requirements, and cost estimates.
The implementation schedule and goals for the plan should include:
• Selecting alternatives for implementation (prioritize and list conditions for
adoption)
• Identifying measurable, performance goals for each hazardous wastestream
• Establishing outcome objectives and ranges of acceptability
• Identifying steps or phases and timing for implementation
• Identifying tasks and personnel assignments
• Training and involving all personnel in the business
• Setting target dates for completion of goals
Several attitudes can prevent successful implementation of pollution prevention
options, which is frustrating to the assessment team. The important factor at this
point is that the pollution prevention task force MUST NOT consider the job
complete until the recommended measures are implemented, or at least until the
project is funded and scheduled.
38
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Some barriers you can expect include:
• Other corporate priorities for use of capital resources
• Skepticism ? "it won't work," or "we've tried that before"
• The Status Quo ? "if it ain't broke, don't fix it."
This pollution prevention program is designed and organized to overcome such
attitudinal barriers early by:
• Obtaining high-level commitment
• Representing all groups in the plant on the task force
• Carefully analyzing and evaluating all options
BUT, the assessment team must keep selling the package until it's a success.
YOUR TURN - What barriers do you expect to implementing your pollution
prevention plan?
39
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Developing A Pollution Prevention Plan
8) MEASURING P2 RESULTS
In order to measure the success of the pollution prevention plan, specific waste
reduction performance goals must be established and expressed in numeric terms.
This does not mean percent reduction, but actual reductions in pounds, tons, or
kilograms of waste generated per standard unit of production, as defined by the
generator. If the establishment of numeric performance goals is not practical,
include a clearly stated list of actions designed to lead to the establishment of
numeric goals as soon as possible in your pollution prevention plan.
Demonstrating that your plan's objectives and goals have been achieved is
essential. The following are some useful measurements:
• Ratio of waste generated to production unit or rate, before and after
implementation of the option
• Savings in raw materials costs and waste disposal costs
• Changes in the composition and/or toxicity of wastes
• Insurance and liability savings for environmental, health and safety
improvements
• Changes in utilities and maintenance costs
• Changes in production capacity and product quality
• Ratio of raw materials consumed to production rate, before and after
implementation (an indirect measure of waste reduction)
• Reduced health and safety exposure of workers and the community
• The program's actual costs and savings compared with the initial program
estimates
40
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In general, waste generation depends directly on the production rate. Measuring
pollution prevention by comparing quantity of waste or input materials to
production rate is generally more useful if applied to a single production unit
rather than to an entire plant. This is especially true of plants where dissimilar
processes and operations are included in one facility. Consider wastes generated
on a periodic basis, such as waste from maintenance or construction, separately
from production wastes, unless the evaluation includes at least one repetition of
the periodic cycle.
One measure of effectiveness for a waste reduction project is the project's effect
on the organization's cash flow. The project should pay for itself through reduced
waste management costs and reduced raw materials costs. However, measuring
the actual reduction of waste is also important. The easiest way to measure waste
reduction is by recording the quantities of waste generated before and after a
waste reduction project was implemented. The difference, divided by the original
rate of waste generation, represents the percentage of waste reduced. However,
this simple measurement ignores other factors also affecting the quantity of waste
generated.
The ratio of waste generation rate to production rate is a convenient way to
measure waste reduction. However, this ratio is not accurate for large quantities of
waste that is generated infrequently. To assure accuracy, distinguish between
production-related wastes, maintenance-related wastes, and clean-up wastes.
Also, a few wastestreams may be inversely proportional to production rate. For
example, waste from old materials will increase if the production rate decreases.
This is because the old materials in inventory are more likely to expire when its
production use decreases.
41
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Developing A Pollution Prevention Plan
In measuring waste reduction, businesses should measure the total quantity of an
individual wastestream as well as the individual waste components. Often, good
housekeeping and concentrating a dilute aqueous waste cause much of the
reduction. Although concentration, as such, does not fall within the definition of
waste reduction, practical benefits result from concentrating water wastestreams,
including decreased disposal costs. Concentrating a wastestream makes it easier to
recycle and may reduce the load on a facility's wastewater treatment system .
Obtaining good quality data for wastestream quantities, flows, and composition
can be costly and time consuming. For this reason, in some instances, expressing
waste reduction indirectly in terms of the ratio of input materials consumption to
production rate may be practical. These data are easier to obtain although the
measure is not direct.
Measuring waste reduction with a ratio of waste quantity to material throughput or
product output is generally more meaningful for specific operations rather than for
an entire facility. Therefore, preserving the focus of the project when measuring
and reporting progress is important. For those operations without chemical
reactions, measuring progress with the ratio of input material quantity to material
throughput or production rate may be helpful.
Schematic of a spf ay booth dealing unit system.
r-t^.^—[—--*
Cwftji-.
:^ai!viort»ri .».lit
%-«i;n>».«:
f^ tst* So^stt.1: ?%9iit t-^
OfiS*« Ipf fr'si c-ls(' J "i
42
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9) A LONG-TERM COMMITMENT
To insure continued reductions, a business must monitor and evaluate techniques
once they are in place. Your plan should address updating procedures as well as
combining the program into the management structure. In addition, the program
should allow for production changes and development of new reduction
techniques.
Pollution prevention planning (and assessing) offers ways to improve
management of a source reduction program and introduce new technologies and
practices.
Much of the planning for a pollution prevention program requires:
• Increased awareness and attention to toxic chemicals
• Increased awareness and training to change old work patterns
• Knowledge of options for change
• Willingness to experiment and to change
• Management's willingness to provide resources for change
• Willingness to follow through, evaluate, and learn from changes
Management's commitment to change makes the difference between simply
preparing a plan, and preparing and implementing a plan. Implementation is the
key. Since changes seldom occur as planned, and facilities change over time, you
need to monitor your pollution prevention plan to ensure its usefulness. This
means long-term management support and, in many cases, a champion within the
organization whose job includes staying abreast of the pollution prevention
program and making needed updates.
By following these nine steps and using the information resources listed in the
back of this handbook, you'll make a great
Pollution Prevention Champion!
43
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Developing A Pollution Prevention Plan
BIBLIOGRAPHY
The University of Tennessee Center for Industrial Services
Writing a Waste Reduction Plan: Charting Your Company's Course Towards
Better Waste Management. Nashville, TN: UT-CIS, First Edition, 1990,
Revised July 1993. 615-532-8657.
Waste Reduction Assessment and Technology Transfer Training Manual
Second Edition. Nashville, TN: UT-CIS, 1989. 615-532-8657.
Georgia Tech Research Institute
Georgia Pollution Prevention Guide. Atlanta, GA: Georgia Tech Research
Institute, 1990. 404-894-3806.
Minnesota Office of Waste Management
Minnesota Guide to Pollution Prevention. Saint Paul, MN: Minnesota Office
of Waste Management, 1991. 612-649-5750.
North Carolina Pollution Prevention Pays Program
Developing and Implementing a Waste Reduction Program. Selected
References on Developing a Waste Reduction Program. Raleigh, NC:
Department of Natural Resources and Community Development, 1988.
800-476-8686.
Oregon Department of Environmental Quality
Benefiting from Toxic Substance and Hazardous Waste Reduction. Portland,
OR: Oregon Department of Environmental Quality, 1990. 503-229-5913
United States Environmental Protection Agency
The EPA Manual for Waste Minimization Opportunity Assessments.
EPA/600/2-88-025. Cincinnati, OH: US EPA ORD Pollution Prevention
Research Branch, 1988. 513-569-7215.
United States Environmental Protection Agency
Waste Minimization: Environmental Quality with Economic Benefits.
EPA/530-SW-87-026. Washington, DC: US EPA Office of Solid Waste and
Emergency Response, 1987. 800-369-5888.
44
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POLLUTION PREVENTION INFORMATION
The Kentucky Pollution Prevention Center (KPPC)
The University of Louisville
Room 420, Academic Building
Louisville, KY 40292
Phone: 502-852-0965 Fax: 502-852-0964
WWW - http://www.louisville.edu/org/kppc
KPPC provides information on techniques designed to reduce all wastes to all
media — land, air, and water. This is accomplished through confidential, non-
regulatory, on-site assessments, an information clearinghouse, and training
seminars and activities.
Cam Metcalf, Executive Director
Keith Ridley, Assistant Director, Assessment
Melinda Latham, Administrative Assistant
Allan Handmaker, Technical Coordinator
Patricia Longfellow, Program Assistant HI
and retired waste reduction engineers throughout Kentucky and EPA Region
IV.
Waste Reduction Resource Center for the Southeast
PO Box 27687
3 824 Barrett Drive
Raleigh, NC 27611-7687
(800) 476-8686
WRRC is staffed by five engineers who provide confidential waste reduction
technical assistance on a variety of industry specific techniques. The Center
houses an extensive collection of information concerned with waste reduction
options.
45
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Developing A Pollution Prevention Plan
US EPA
Pollution Prevention Office
401 M Street, SW
Washington, DC 20460
(202)245-3557
Provides information on reducing industrial pollutants.
US EPA
Pollution Prevention Information Clearinghouse Technical Support
Science Applications International Corporation
7600-A Leesburg Pike
Falls Church, VA 22102
(703)821-4800
Technology transfer of methods to reduce industrial pollution including
information packets and the PIES on-line data base.
US EPA - Office of Research and Development
Pollution Prevention Research Branch
26 West Martin Luther King Drive
Cincinnati, OH 45268
(513)569-7215
Publishes information for industry based on Pollution Prevention research.
US EPA - Region IV
Pollution Prevention Office
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-3555
Regional office that provides Pollution Prevention information.
US EPA Asbestos and Small Business Ombudsman
401M Street, SWA-149C
Washington, DC 20460
(800) 368-5888
Distributes information to businesses on a variety of health and environment
issues.
46
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47
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APPENDIX A:
RCRA PERSONNEL TRAINING
CHECKLIST
-------
EXCERPT FROM 40 CFR 265
§ 265.16 Personnel training.
(a) (1) Facility personnel must successfully complete a program of
classroom instruction or on-the-job training that teaches them to perform
their duties in a way that ensures the facility's compliance with the
requirements of this part. The owner or operator must ensure that this
program includes all the elements described in the document required
under paragraph (d)(3) of this section.
(2) This program must be directed by a person trained in hazardous
waste management procedures, and must include instruction which
teaches facility personnel hazardous waste management procedures
(including contingency plan implementation) relevant to the
positions in which they are employed.
(3) At a minimum, the training program must be designed to ensure
that facility personnel are able to respond effectively to
emergencies by familiarizing them with emergency procedures,
emergency equipment, and emergency systems, including where
applicable:
(i) Procedures for using, inspecting, repairing, and replacing
facility emergency and monitoring equipment,
(ii) Key parameters for automatic waste feed cut-off systems;
(iii) Communications or alarm systems;
(iv) Response to fires or explosions,
(v) Response to ground-water contamination incidents; and
(vi) Shutdown of operations.
(b) Facility personnel must successfully complete the program required in
paragraph (a) of this section within six months after the effective date of
these regulations or six months after the date of their employment or
49
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Developing A Pollution Prevention Plan
assignment to a facility, or to a new position at a facility, whichever is
later. Employees hired after the effective date of these regulations must
not work in unsupervised positions until they have completed the training
requirements of paragraph (a) of this section.
(c) Facility personnel must take part in an annual review of the initial training
required in paragraph (a) of this section.
(d) The owner or operator must maintain the following documents and records
at the facility:
(1) The job title for each position at the facility related to hazardous
waste management, and the name of the employee filling each job,
(2) A written job description for each position listed under paragraph
(d)(l) of this Section. This description may be consistent in its
degree of specificity with descriptions for other similar positions in
the same company location or bargaining unit, but must include the
requisite skill, education, or other qualifications, and duties of
facility personnel assigned to each position;
(3) A written description of the type and amount of both introductory
and continuing training that will be given to each person filling a
position listed under paragraph (d)(l) of this section;
(4) Records that document that the training or j ob experience required
under paragraphs (a), (b), and (c) of this section has been given to,
and completed by, facility personnel
(e) Training records on current personnel must be kept until closure of the
facility. Training records on former employees must be kept for at least
three years from the date the employee last worked at the facility.
Personnel training records may accompany personnel transferred within
the same company.
RCRA Personnel Training Checklist
1 Do you generate RCRA hazardous waste?
50
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If "NO," no training is required or needed
2. Are you a "CESQG" (never as much as 100kg of hazardous waste in any
one month)?
If "YES," no training is required by law. It may, however, be advisable.
If "NO", continue to next question.
3. Are you an "SQG" (never as much 1000 kg of hazardous waste in any one
month)?
If "NO," skip to Question 6.
4. If "YES," do you accumulate hazardous waste on site before shipping to a
TSDF?
If "NO," no training is required by law. It may, however, be advisable.
5. If "YES," have you made sure that "all employees are thoroughly familiar
with the proper waste handling and emergency procedures relevant to their
responsibilities during normal operations and emergencies?"
6. If you are a "LQG" (1000 kg or more of hazardous waste in any one
month), do you accumulate hazardous waste on site before shipping to a
TSDF?
If "NO," no training is required by law. It may, however, be advisable.
If "YES," continue with the remaining questions.
7. Have you trained facility personnel in:
» Procedures for proper use, repair and maintenance of emergency and
monitoring equipment?
» How to stop flow of waste in case of an emergency?
» Communications and alarm systems in the facility?
» Emergency response to fires and/or explosions?
» Emergency response to spills which threaten surface or ground water?
» How to shut down operations in those emergencies?
51
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Developing A Pollution Prevention Plan
8. Have you ensured that new employees, or those newly assigned to this
position, have completed this training within their first six months on the
job?
9. Do all affected personnel take part in an annual review of this training?
10. Do you maintain the following records and have documentation readily
available at the facility:
» The job title for each hazardous waste-related position, and the name of
the person who fills that position? A written job description for each of
those positions?
» A written record of the types, amounts, and dates of training given to each
of the hazardous waste workers?
» Do you maintain detailed records of the content of this training to
demonstrate that it conforms to 40 CFR Part 265.16?
11. Do you retain training records on current personnel permanently, and on
former employees for at least three years?
52
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Developing A Pollution Prevention Plan
APPENDIX B:
WASTESTREAM DATA SHEETS
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Developing A Pollution Prevention Plan
WASTE STOEUM DA FA SHEET
Pepsiffeisen! Ail ___ ^_ __ Waste CoajifmattM
W«st« Name .LgsWS.utbs
Process Generating The Waste
Waste Generation Rate (Galons or Pounds Per Month) Varies
Lmrfini i^is|X*s
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WASTE STREAM DATA SHEET #4
Department Waste Caoitimator
Waste Name Oily Rags
Pn>wss Gert8«i)ing Tha Waste Maintenance
wasi» r»Rneralion Rale (Gallons or Pounds Per Month; SS gaiior. atom every 3 months I
Currant Disposal Procedures Oily nags are packaged and shipped to Ririaco,
OneTirro
Have YOU Classified Your Wasse?
Hazardous | | (fr so llsl (he EPA Waste Cotfcs) Non Hazardous !
How Have Your Made Utis Octefgiinaliort?
Tesiing | X j(lf so attach resulls) Piocess Knowlecfflc:
(Consult CES)
jjR nf?rppos}liQri PerpBnl
1 , jMtecetjancous Used Ojls _________ _ 20
2. Cloth Rags ^_ ^^ 80
3. ^
4
General Parameters: Flashpoint __Degn»BsF pH Specific Gravity
Physical State it TO OegieesF Solid[_XjL*uuid |_Jasint Sow {~H| Gas [ }
(dentify Waste Packaowo T^pe and SUe 55 Gallon Drum DOT 1?R
Waste Caordinatof Si(jnalure (3a(e
55
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Developing A Pollution Prevention Plan
ANALYSIS OF WASTE STREAMS
Ptentwide
Pta Wnae
Pmducng Activity
Wisle Material
ftodisoed
Eslirnittd Anwunt
of Wute Produced
Her Yw
Cunutt W»te
Disposal MejkxJ
Gc»b
56
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APPENDIX C:
CONTACTS FOR:
KY DEPARTMENT OF
ENVIRONMENTAL PROTECTION
FIELD OFFICES
NATURAL RESOURCES AND
ENVIRONMENTAL PROTECTION
CABINET
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Developing A Pollution Prevention Plan
KENTUCKY DEPARTMENT OF ENVIRONMENTAL PROTECTION FIELD
OFFICES
Ashland Office
3700 13th Street
Ashland, Kentucky 41105-1507
606/920-2071
Bowling Green Office
108 Westen Avenue
Bowling Green, Kentucky 42104-3356
502/843-5475
Columbia Office
PO Box 335
102 Burkesville Street
Columbia, Kentucky 42728-1408
502/384-4734
Florence Office
Suite #8
7964 Kentucky Drive
Florence, Kentucky 41042-2915
606/292-6411
Hazard Office
PO Box 2
233 Birch Street
Hazard, Kentucky 41701-2115
502/435-6022
London Office
238ARegional State Office Building
Room 345
85 State Police Road
London, Kentucky 40742-9008
606/878-0157
Louisville Office
312 Whittington Parkway, Suite 201
Louisville, Kentucky 40222-4925
502/595-4254
Madisonville Office
State Office Building
625 Hospital Drive
Madisonville, Kentucky 42431-1698
502/824-7529
Morehead Office
Mabry Building
200 Kentucky Highway 32 South
Morehead, Kentucky 40351-1346
606/784-6635
Owensboro Office
Suite #700
Alvery Park Drive West
Owensboro, Kentucky 42303
502/686-3304
Paducah Office
4500 Clarks River Road
Paducah, Kentucky 42003-0823
Maxey Flats
Highway 1895, Route 2, Box
Hillsboro, Kentucky 41049-9608
606/784-6612
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NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
CABINET
OFFICE OF THE SECRETARY Work*
5th Floor, Capital Plaza Tower
Cabinet Secretary Phillip J. Shepherd 4-3350
Deputy Secretary Karen Armstrong-Cummings 4-3350
Principal Assistant Mark York 4-3350
Ombudsman Judith Petersen 4-3350
Ombudsman PamiaWood 4-3350
Ombudsman, Air Rose Marie Wilmoth 4-3350
Budget Officer Melanie Bailey 4-3368
Office of Adm. Hearings Barbara Foster 4-7312
Office of Communications Faun Fishback 4-5525
Director, OAS Boyce Wells 4-7320
Assistant Director, OAS Roger McCann 4-7320
Personnel Branch Trinta Cox 4-7320
Finance Branch Jim Reynolds 4-7364
Data Processing Branch Belenda Holland 4-5174
OFFICE OF LEGAL SERVICES
5th Floor, Capital Plaza Tower
General Counsel Jody Curry 4-5576
Surface Mining Division Iris Skidmore 4-5576
Natural Resources Kathy Hargraves 4-5576
DEPARTMENT FOR ENVIRONMENTAL PROTECTION
14ReillvRoad
Commissioner Robert Logan 4-3035
Deputy Commissioner Russ Barnett 4-2150
Division of Water Jack Wilson 4-3410
Division of Waste Management PatHaight 4-6716
59
59
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Developing A Pollution Prevention Plan
100 Sower Blvd.. Ste. 104
Div. of Environmental Services William Davis 4-6120
803 Schenkel Lane
Division for Air Quality/Director John Hornback 3-3382
DEPARTMENT FOR NATURAL RESOURCES
107Mero Street
Commissioner William Martin 4-2184
Executive Staff Advisor JoeDietz 4-2184
691 Teton Trail
Division of Conservation Steve Coleman 4-3080
Division of Energy John Stapleton 4-7192
627 Comanche Trail
Division of Forestry Mark Matuszewski 4-4496
DEPARTMENT FOR SURFACE MINING RECLAMATION AND
ENFORCEMENT
#2 Hudson Hollow
Commissioner Carl Campbell 4-6940
Division of Permits Fred Kirchhoff 4-2320
Division of Field Services Dave Nance (Acting) 4-2340
618 Teton Trail
Division of Abandoned Lands Steve Hohmann 4-2141
ENVIRONMENTAL QUALITY COMMISSION
14ReillvRoad
Director Leslie Cole 4-2150
Chair Wm. Horace Brown 4-2150
NATURE PRESERVES COMMISSION
801 Schenkel Lane
Director Bob McCance 3-2886
Chair Hugh Archer
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PETROLEUM STORAGE TANK ENVIRONMENTAL ASSURANCE FUND
COMMISSION
911 Leawood Drive
Acting Director Laurance McCabe 4-5981
Bob Ware 839-4696
Bill Berger-Emergency Response 4-341 0 or 4-2380
*Area Code/Prefix: 502-56
61
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Developing A Pollution Prevention Plan
APPENDIX D:
TWO SAMPLE POLLUTION
PREVENTION (P2) PLANS
62
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XYZ WIDGETS CORPORATION
2200 Widget Road
Anytown, Kentucky 40000
POLLUTION PREVENTION PLAN
September 1, 19
63
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Developing A Pollution Prevention Plan
POLLUTION PREVENTION PLAN
Facility Identification and Information
Company Name:
Mailing Address:
Contact Person: Telephone:
Certification:
I certify that I have personally examined this pollution prevention plan, and that I am familiar
with its contents and all attachments. Based upon my inquiry of those persons immediately
responsible for obtaining the information, I believe the information presented in the plan is true,
accurate, and complete.
Owner or Senior Management Official
Name (Please print or type) Title
Signature
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PREFACE
XYZ Widgets Corporation has always been concerned with protecting the environment and
keenly aware of its role as a good neighbor in the community. It has long been a policy that we
go well beyond what is legally required and strive for zero discharge of pollutants into the
environment, whether on-site or off-site.
We recognized long ago that reduction of wastes has definite economic benefits as well as
environmental ones. Consequently, a program called SWAP (Stop Waste, Add Profits) was
begun in 1990 under which teams were formed to reduce our wastes to the lowest cost-effective
level, beginning with the most "environmentally unfriendly." Under this team approach, the
wastes were identified and arranged in order of environmental impact. The processes which
caused them to be generated were analyzed to determine what source reduction measures were
available for each. The analysis resulted in reduction priority being given to the two of the three
largest hazardous waste streams generated at that time. As a result of our waste reduction
measures, those two streams were reduced as follows between 1989 and the date of writing this
Waste Reduction Plan:
WASTE STREAM 1989 LBS.
1991 LBS.
REDUCTION (1989-91)
LBS. %
"TCA"
Varsol
"MEK"
"PERC"
15,000
39,000
1,050
15,000
0
12,130
1,200
18,500
15,000
26,870
-150
-3,500
100
69
(14) gain
(23) gain
The PERC waste stream was not reduced because of rigid contractual rules. Attempts to obtain
contract revisions to remove this barrier have been under way for months, but have been
unsuccessful so far. Although we would like to project reduction goals for the PERC waste
stream, it is generated making a product under U.S. Department of Defense contracts specifying
procedures which preclude source reduction of hazardous materials.
In both cases where our efforts have been successful, reductions have been accomplished by
process changes and by training which increased employee awareness of how their actions can be
directly responsible for generating unnecessary waste.
Our teams are currently working on all waste streams generated in the plant, hazardous or not.
Cost estimates on which to base capital funding to implement further reduction are being made.
The goals and schedule for accomplishing further hazardous waste reduction from the present to
the end of 1995 are detailed later.
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Developing A Pollution Prevention Plan
We are confident we can meet the goals set forth in this plan, especially with strong support from
corporate management as stated in the Pollution Prevention Policy Statement, a key element of
the plan.
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POLLUTION PREVENTION POLICY STATEMENT
XYZ Widgets Corporation
September 1, 199 _
This corporation is committed to excellence and leadership in protecting the environment from
being adversely affected by any material emitted from our manufacturing operations.
It is further committed to the concept that wastes of any kind to any medium represent costs
which must be reduced to the economically and technically achievable minimums.
We reaffirm here our Corporate goals to provide a safe and healthy environment for employees
and to be a good neighbor to the community in which we reside.
Therefore, our policy is, and shall be, to constantly seek opportunities to:
+ Reduce wastes at the source, through employee training in waste awareness, through
substitution of environmentally friendly raw materials wherever possible, and by ongoing
analysis of processes and operations to identify causes of waste,
+ Replace existing waste-generating processes with those which generate fewer or less-
hazardous wastes,
+ Revise processes so that wastes can be re-used or recycled within them,
+ Market new or re-designed products whose manufacture results in reduced wastes, or for
which existing wastes become raw materials, and
+ Urge suppliers to develop products and procedures which will assist us to reduce wastes
generated.
In order to ensure that this policy is carried out, we pledge that we will make available the
necessary resources to our employees so that opportunities determined to be feasible will be
implemented. To encourage such implementation, economic justification of projects resulting in
waste reduction at the source will require a return on investment which is no more than three-
fourths of that required for conventional projects.
Chairman & Chief Executive Officer President & Chief Operating Officer
Vice President, Manufacturing Vice President, Financial
Vice President, Marketing Vice President, Procurement
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Developing A Pollution Prevention Plan
68
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XYZ WIDGETS CORPORATION
POLLUTION PREVENTION PLAN
STATEMENT OF SCOPE AND OBJECTIVES
SCOPE OF THE PLAN:
Although this plan is written to meet the voluntary planning responsibilities of
the Kentucky Revised Statues 224.46-305etseq., the XYZ Widgets Corporation 's
Stop Waste, Add Profits (SWAP) program applies to all hazardous and non-
hazardous wastes generated by operations conducted at the Anytown, Kentucky
facility. The plan, in future updates, will be amended to include all the following
in addition to RCRA hazardous wastes and Section 313 toxic chemicals, which
are being given first priority:
+ Point source and fugitive emissions to the air;
+ Liquid waste discharges to the municipal sewer;
+ Raw material and finished goods scrap; and
+ Non-hazardous solid wastes such as general plant trash, office and
lunchroom waste,
The plan calls for positive commitment to its objectives by Corporate
management, and for involvement of every person employed at the facility.
OBJECTIVES OF THE PLAN:
The plan has two objectives:
1. To reduce all waste streams (as defined in the statement of the Plan's
scope) to the minimum quantity which is technically feasible and
economically practical.
2. To continue in perpetual effect as an instrument which will:
+ Maintain Corporate waste awareness;
+ Ensure on-going analysis of factors influencing waste generation;
and
+ Provide continuing employee training.
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Developing A Pollution Prevention Plan
ESSENTIAL ELEMENTS OF THE PLAN:
1. A facility-wide waste assessment will be conducted to less frequently than
annually. The assessment will be conducted by the Plan's administrative
team. The plant-wide assessment will be scheduled so that its results will
be available to Process Teams when they establish their annual goals.
2. All new processes and all major process changes will require a waste
stream impact study.
3. Employee training on waste reduction will be embedded in the existing
and on-going Safety and OSHA Employee Right-to-Know training
program. For those employees who are required to have special hazardous
materials training, a waste-reduction component will be incorporated in
that training as well.
4. Each Process Team will be required to measure and track all wastes
generated by the team's activities. A process team will be responsible for
and bear the expense of its waste streams, which will be a part of the
team's cost-budgeting structure. Tracking of wastes will be accomplished
by a mass-balance technique which will ensure that all materials are truly
accounted for.
5. Financial tools will be utilized so that the full cost impact of each waste
stream generated is tracked.
6. Each Process Team will establish a pollution prevention goal and an
implementation schedule at the beginning of each year. A progress report
and the next year's goals and implementation schedule will be submitted
by January 5 of each year.
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DESCRIPTION of the PLAN
1. Administration
The Pollution Prevention Plan will be administered by a SWAP Team to
be headed by the Vice President, Manufacturing.. The team will
composed of the following:
+ Technical Coordinator;
+ Environmental & Safety Director;
+ Maintenance Superintendent;
+ Purchasing Agent;
+ Staff Accountant; and
+ One representative from each Process Team
The duties of the team will include:
+ Administer the plan;
+ Schedule and conduct the annual facility-wide assessment;
+ Appoint sub-teams to analyze assessment results, consider options
and make recommendations for the entire team's consideration;
+ Meet regularly to review waste data, project progress and make
new assignments;
+ Report findings, make final recommendations, and initiate project
requests for implementation and corrective action; and
+ Prepare the annual progress report and update the Plan and the
goals and implementation schedule as and if necessary.
2. Training and Worker Involvement
Pollution Prevention will be incorporated into the existing training
curriculum wherein employees are trained on the general nature of
chemical hazards, safe operating procedures and use of MSDS's.
Employees in a process area will be required to evaluate their own area's
waste streams and be provided with resource material which describes the
technology available and currently used for reduction of waste streams of
similar nature or in similar processes. Major emphasis will be on
preventing waste generation by improved procedures, material substitution
and process changes.
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Developing A Pollution Prevention Plan
3. New Processes, New Products and Maj or Changes
New processes and products or major changes will be installed only after
an analysis of the waste stream impact. New start-ups and major changes
will require an estimate of the type and volume of the waste generated, its
environmental impact and related costs. Product development groups will
be required to assess waste impact early in their design considerations.
Any significant additional waste generated will require a challenge to the
design before work proceeds. Manufacturing teams will need to be
apprised early in the development as to the nature of the required
manufacturing process and asked for input on the anticipated waste
streams' impact. Production teams will have a strong incentive to
challenge changes and new products because they are ultimately
responsible for managing and must budget the cost of their waste streams.
4. Waste Management Cost Accounting
A mass balance analysis technique (total pounds of all materials in = total
pounds of all materials out) will be used to identify all input and output
streams to each individual process. Once waste streams have been
identified and quantified by this analysis, waste will be reported in weight
per unit of production. For example, the process manufacturing Type A
Widgets will report all waste streams in pounds per 1000 Type A Widgets
made.
This information will be logged by operating personnel on a shift-by-shift
basis and turned over to accounting for cost calculation, because of the
differing nature and processing involved in the various wastes, waste costs
will be established in dollars per pound on a case-by-case basis. In the
case of product rejects, the process team will classify rejects in five
categories, according to the value added by manufacturing at the point of
rejection.
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A. Waste Streams No. 1: Perchloroethylene (PERC); EPA Waste Code FOO1
SOURCE
Type X Widget Department
OPERATION GENERATING WASTE
Vapor degreasing to remove machine coolant prior to in-process
inspection
BARRIERS TO REDUCTION
Type X Widgets are produced under a DOD contract which specifies the
process in great detail. PERC is used in this department in a vapor
degreaser to remove chips and oils resulting from first-stage machining so
that the parts can be individually inspected. Because of potential corrosion
by hydrochloric acid resulting from solvent degradation, the DOD contract
specifies replacement of the solvent charge every 100,000 widgets. The
waste is generated when the degreaser is drained and solvent replaced.
Given this lack of control, potential for reducing this waste is very poor.
POLLUTION PREVENTION MEASURES PREVIOUSLY IMPLEMENTED
Considerable reduction has been accomplished in the quantity of PERC
lost at this location as drag-out and fugitive emissions by modifying
operating procedures. However, no reduction in RCRA hazardous waste
has been accomplished because of the requirement that the solvent be
replaced on a regular schedule.
GENERATION HISTORY
1989: Produced 6,000,000 Widgets, Generated 15,000 pounds waste
Waste Generation Rate = 2.50 pounds per 1000 Type X
widgets.
1990: Produced 6,500,000 Widgets, Generated 16,250 pounds waste
Waste Generation Rate = 2.52 pounds per 1000 Type X
widgets.
1991: Produced 7,400,000 Widgets, Generated 18,500, pounds waste
Waste Generation Rate = 2.50 pounds per 1000 Type X
widgets
POLLUTION PREVENTION MEASURES PLANNED
Technical liaison has been established with DOD with the objective of
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Developing A Pollution Prevention Plan
eliminating use of this solvent. Because of our success in totally
eliminating solvent-cleaning in manufacturing Type Z Widgets, we expect
to eventually negotiate contract revisions with DOD which will allow us to
change to an aqueous cleaner. This technique is now in successful use
making Type Z widgets. All plans to reduce hazardous waste in this
operation are held in abeyance, pending definite action by DOD.. We
would be able to implement the change about ten weeks after the contract
revision.
POLLUTION PREVENTION GOAL
Technology already in use in this facility could eliminate this waste
stream. XYZ Widgets has no control over when the decision to allow its
use may come. Therefore, no reduction goal or implementation date has
been set.
74
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B: Waste Stream No.2: 1,1,1 Trichloroethane (TCA); EPA Waste Code F001
SOURCE
Type Z Widget Department
OPERATION GENERATING WASTE
Vapor degreasing of widgets prior to deburring and buffing.
POLLUTION PREVENTION MEASURES ALREADY IMPLEMENTED
Whereas this department used a vapor degreaser and TCA until late 1989,
the process no longer uses vapor degreasing, but relies on a rinse of the
parts in clear, ambient-temperature water to accomplish the same end.
This was made possible by replacing oil-based cooling medium in the
preceding machining operation with a water-based synthetic coolant.
GENERATION HISTORY
1989: Produced 6,120,000 widgets, generated 15,000 pounds waste
Waste Generation Rate = 2.50 pounds/1000 Type Z
Widgets
1990: Produced 7,050,000 widgets, generated 800 pounds waste
Waste Generation Rate = 0.11 pounds/1000 Type Z
Widgets
1991 and Future - No RCRA waste to be generated in this operation
Waste Generation Rate = 0.00 pounds/1000 Type Z
Widgets
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Developing A Pollution Prevention Plan
C. Waste Stream No. 3: Waste Varsol (Mineral Spirits); EPA Waste Code D001
SOURCES
Maintenance Shop; Tool and Die Shop
OPERATIONS GENERATING WASTE
Maintenance mechanics use Varsol-charged Safety-Sink cleaning stations
to wash parts or anything they may have to clean up. A service removed
dirty solvent and replaced it with clean on a regular three-week schedule.
There were three sinks in the maintenance shop in 1989. In that year, these
sinks were responsible for 7,500 pounds of waste manifested for off-site
recovery.
The tool and die shop has two 250-gallon vats of Varsol into which
stamping dies are immersed for cleaning. The solvent was replaced every
nine weeks by the same company that serviced the parts sinks. They were
responsible for generating 31,500 pounds of waste solvent in 1989.
POLLUTION PREVENTION MEASURES ALREADY IMPLEMENTED
During 1990 and 1991, the use of Varsol for cleaning was extensively
studied, including study of work practices and evaluation of how well the
existing operations were utilizing the solvent's oil-removal capacity. As a
result of that study, the following measures were taken:
+ The replacement cycles for the sinks in maintenance were
increased from three weeks to six weeks.
+ One of the die-cleaning vats was taken out of service.
+ The replacement cycle for the remaining die-cleaning vat was
increased from nine weeks to twelve.
+ Drainboards were added to the die-cleaning vats to allow recovery
of solvent dragged out on dies.
As a result of these measures, the total waste Varsol shipped off-site was
reduced as indicated below:
GENERATION HISTORY
1. Maintenance Department:
1989: Processed 11,240 Maintenance Workorders, generated 7,500
pounds of waste.
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Waste Generation Rate = 0.67 pounds per workorder
1990: Processed 12,100 Maintenance Workorders, generated 4,250
pounds of waste.
Waste Generation Rate = 0.35 pounds per workorder
1991: Processed 11,300 Maintenance Workorders, generated 3,800
pounds of waste.
Waste Generation Rate = 0.34 pounds per workorder.
2. Tool and Die Shop
1989: Produced 23,000,000 widgets, generated 31,500 pounds of waste.
Waste Generation Rate = 1.37 pounds per 1000 widgets.
1990: Produced 23,500,000 widgets, generated 21,900 pounds of waste.
Waste Generation Rate = 0.93 pounds per 1000 widgets.
1991: Produced 22,950,000 widgets, generated 8,330 pounds of waste.
Waste Generation Rate = 0.36 pounds per 1000 widgets.
POLLUTION PREVENTION MEASURES PLANNED
The following options are being evaluated from a technical and economic
standpoint:
+ Replace all but one of the solvent type parts sinks in maintenance
with a heated, agitated cleaning tank using a water/detergent
solution as cleaning medium. This should allow us to reduce this
department's solvent waste by another 50%.
+ Purchase and install a spray cleaner with air-drying capability for
die cleaning. This should eliminate use of solvent cleaners in tool
and die shop except for small hand-wipe operations.
POLLUTION PREVENTION
1. Maintenance Department
Evaluation Date
06/30/93
06/30/94
06/30/95
Target Waste Quantity, Ibs.
2500
2500
1250
Lbs. Waste/Workorder
0.21
0.21
0.12
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Developing A Pollution Prevention Plan
2. Tool and Die Shop
Evaluation Date
06/30/93
06/30/94
06/30/95
Target Quantity, Ibs.
8300
8500
115
Pounds/1000 Widgets
0.32
0.32
0.05
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D. Waste Stream No. 4: Methyl Ethyl Ketone (MEK): EPA Waste Code F005
SOURCE
Final Packaging and Inspection
OPERATION GENERATING WASTE
Type Y Widgets have a component made of highly polished stainless steel.
To prevent marring of the polished surface, the stainless steel sheet is
purchased with a protective paper attached by pressure-sensitive adhesive.
Removal of traces of adhesive and bits of paper from the finished product
is accomplished by wiping with a rag wet with MEK. The operator's
supply of MEK is discarded when it becomes dirty enough to leave a dull
film on the surface after it evaporates.
POLLUTION PREVENTION MEASURES ALREADY IMPLEMENTED
None - All alternative methods of cleaning tried thus far have failed.
GENERATION HISTORY
1989: Produced 10,400,00 Type Y widgets, generated 1, 050 pounds of
waste.
Waste Generation Rate = 0.10 pounds/1000 Type Y
widgets.
1990: Produced 9,950,000 Type Y widgets, generated 1,000 pounds of
waste.
Waste Generation Rate = 0.10 pounds/1000 Type Y
widgets.
1991: Produced 11,785,000 Type Y widgets, generated 1,200 pounds of
waste.
Waste Generation Rate = 0.10 pounds/1000 Type Y
widgets.
POLLUTION PREVENTION MEASURES PLANNED
At present there are no proven alternatives known to us. We will continue
an intensive program of training and waste awareness, but reduction of any
significant magnitude will be difficult to accomplish, given the present
state of training.
It is planned to investigate the following potential source-reduction
options. If one should be come available, it will be thoroughly evaluated
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Developing A Pollution Prevention Plan
from an economic standpoint, and implemented if it is not cost-
prohibitive. It should be noted that the market for Type Y widgets is
extremely competitive, and the profit margin is one of the lowest in our
product line.
+ Obtain polished sheet from supplier with water-removable
protective film; and
+ Continue search for suitable substitute cleaning material.
POLLUTION PREVENTION
It is our intention to eliminate this waste stream entirely, if an alternative
method which is both effective and economically feasible can be found.
Our goal is that the Waste Generation Rate for this waste stream will be
reduced 10% or to 0.09 pounds per 1000 Type Y widgets by September 30
1995.
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Company ABC
Pollution Prevention Plan
September 1993
Revision: New
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Developing A Pollution Prevention Plan
POLLUTION PREVENTION PLAN
Facility Identification and Information
Company Name:
Mailing Address:
Contact Person: Telephone:
Certification:
I certify that I have personally examined this pollution prevention plan, and that I am familiar
with its contents and all attachments. Based upon my inquiry of those persons immediately
responsible for obtaining the information, I believe the information presented in the plan is true,
accurate, and complete.
Owner or Senior Management Official
Name (Please print or type) Title
Signature
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PREFACE
Company ABC is committed to protecting the environment. Prior to enactment of the
Kentucky Revised Statutes, Chapter 224 Environmental Protection Section 46.305 et seq.,
Company ABC implemented the following processes and procedures to reduce waste.
PARTS CLEANING
In 1993, Company ABC installed a Hotsy aqueous washer to replace a large solvent dip
tank. The dip tank was used to clean parts that were too large for the parts cleaning tanks. The
dip tank was removed a few years ago. The new Hotsy washer uses a non-hazardous detergent
and hot water. No hazardous waste is anticipated to be generated from the new process.
The Hotsy cleans parts effectively and timely. Most parts can be cleaned within a 10-
minute cycle. We have successfully cleaned engine blocks, engine parts, transmissions, and
many other parts.
The Hotsy runs on a timer so that the washer is turned off on nights and weekends and
automatically starts heating up prior to opening.
The washer also has an oil skimmer to remove oil from the water. We expect the water to
last for approximately 6 months, at which time we will determine if it can be discharged to the
sanitary sewer. The washer is topped off with fresh water and soap as needed.
PAINTING
In 1992, Company ABC switched from purchasing pre-mixed paints to a paint mixing
process. Due to the many color and batch variations among autobody paints, we bought a large
amount of paint. Paint was often wasted when we did small jobs that required little paint.
We now have a system that mixes any color or batch of paint to match the automobile
paint. We mix paint in various amounts, thereby reducing excess waste.
In 1992, we also installed a gun cleaner that recirculates the solvent. Prior to installing
this cleaner, our painters used a bucket of solvent and manually cleaned guns.
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Developing A Pollution Prevention Plan
Company ABC
POLLUTION PREVENTION
POLICY STATEMENT
Company ABC is committed to a leadership role in protecting the environment.
Whenever feasible, we will eliminate, reduce, or recycle our waste in full compliance with all
Federal and State Regulations. Our employees are urged to participate in all types of pollution
prevention.
President, Company
ABC Date
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SCOPE AND OBJECTIVES
To comply with the voluntary planning responsibilities of KRS 224.46-305 et seq. and
improve the environment, all employees of Company ABC will be involved in pollution
prevention. RCRA hazardous waste and Section 313 toxic chemicals will be our first priority for
waste reduction.
Our goal is to reduce hazardous waste streams to the technically feasible and
economically practicable minimum by the timetable noted in the contents of the plan. We will
achieve these reductions through waste reduction assessments, procedure improvements,
equipment changes, material substitution, employee training and other reduction methods.
POLLUTION PREVENTION PLAN ADMINISTRATION
John Smith Foreman will act as the Pollution Prevention Coordinator for Company ABC.
The Pollution Prevention Coordinator will administer the plan, prepare the annual progress
report and update the plan as needed.
Pollution prevention options will be evaluated by the foreman, Service Director,
Manager, and applicable employees.
Pollution prevention can only be achieved with the cooperation of employees generating
the waste. Therefore, all employees will be made aware of the need for waste reduction.
Training will be incorporated into the Hazard Communication training. Employees will also be
trained on operator dependent pollution prevention techniques.
Waste costs are computed from the following costs:
* Cost of raw material lost to waste (if applicable)
* Labor;
* Waste transportation/treatment/disposal; and
* Laboratory fees (if applicable).
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Developing A Pollution Prevention Plan
WASTE STREAM # 1: WASTE PAINT RELATED MATERIAL
Company ABC has an automated, enclosed paint booth for autobody repairs. The spray
guns are manual High Volume Low Pressure (HVLP) guns. Waste is generated from leftover
paint and gun cleaning. Waste is collected in 55-gallon drums and shipped off-site for fuels
blending.
Waste Generation:
1989
1990
1991
1992
1993*
WASTE
GENERATED
1505
1441
1161
1764
1199
BODYSHOP
REPAIR
ORDERS
1342
840
1000
1432
952
WASTE (LB)
PER REP AIR
ORDER
1.12
1.72
1.16
1.23
1.26
COST
OF WASTE
N/A
N/A
N/A
$5200
$3850
* As of July 31, 1993
N/A = Not available
Cost of waste includes transportation, disposal, and raw material loss.
Disposal/transp. $500/year
Average paint cost $35/gallon
Average thinner cost $20/gallon
In 1992, Company ABC implemented two waste reduction measures for waste
contributing to the paint waste stream. A paint mixing station was installed which allowed us to
mix our own paint colors. With the new paint system, we are able to mix the quantity of paint
needed for the job. This reduced the excess paint, thereby reducing the waste. Weighing
accuracy becomes critical. If operators do have leftover paint, it is saved in small paint
containers for the next job of the same color.
We also installed a recirculating gun cleaning tank to replace manual dipping and
cleaning. The gun cleaning tank holds 5 gallons of solvent. Guns and paint pots are rinsed with
a small amount of solvent and then placed in the tank. The gun cleaning tank takes about 45
seconds to clean the parts. The solvent is changed monthly. Reclaimed solvent is purchased for
86
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refilling the tank.
87
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Developing A Pollution Prevention Plan
BARRIERS TO REDUCTION
* SUB STITUTE PAINT:
We are currently unable to substitute a non-hazardous paint due to car
manufacturers' paint types. Since we have to match GM and other car
manufacturers' paint, we must use the same type. GM is currently
evaluating substitute paint. If water-based paint is approved by GM, we
will adopt this waste reduction strategy. Our waste generation would
decrease, however the phase-out time of the solvent-based paint would be
significant.
* REUSE GUN CLEANING SOLVENT TO THIN PAINT:
This option is not feasible due to the various paint colors and types and
the exact measurements of mixing. Contaminants in the thinner would
ruin the paint.
* SOLVENT DISTILLING ON-SITE:
Solvent distillation is economically unfeasible for our low generation
rate.
POLLUTION PREVENTION OPTIONS
The following options are being assessed as possible pollution prevention:
* Substitute paint. This would follow auto manufacturers'lead. If implemented,
we would be required to keep two systems for many years for older cars.
* Scrape paint cup with a spatula prior to placing in gun cleaner.
* Train operators to reduce overspray.
Ensure spray gun nozzles are clean and not damaged.
Maintain a gun distance of 6-8 inches from the workpiece.
Trigger gun at the end and the beginning of each stroke.
Ensure proper pressure is on gun stroke.
* Settle solids out of paint gun cleaning tank, remove and reuse the solvent.
Except for the substitute paint, the above pollution prevention measures can be
implemented without a significant cost. The waste reduction would result in decreased
disposal costs. Operators will be trained on above practices during 1993 and
improvements will be ongoing.
Installing a water-based system will be very expensive but cost will not be a
prohibiting factor. Costs at this time are unknown.
-------
GOALS
1993
1994
1995
WASTE (LB)TREPAIR ORDER
.55
.50
.45
WASTE STREAM #2: MINERAL SPIRITS PARTS CLEANING SOLVENT
Company ABC generates a mineral spirits parts cleaning solvent when parts
cleaners are changed. We have seven parts cleaning tanks throughout the maintenance
shop. Parts cleaning tank are changed as needed on a contract. The contract price
includes solvent replacement, transportation, and permitted recycling.
Waste Generation:
1989
1990
1991
1992
1993*
WASTE
GENERATED
(LB)
3868
2398
3555
4173
2112
MECHANICAL
REPAIR
ORDERS
11643
9469
10765
11095
6592
WASTE (LB)
PER REP AIR
ORDER
0.33
0.32
0.30
0.30
0.28
COST
OF WASTE
N/A
N/A
N/A
$1922
$863
* As of July 31, 1993
N/A = Not available
In 1992, Company ABC installed an aqueous parts cleaner to replace a solvent
dip tank removed a few years ago. This aqueous washer is used to clean large parts such
as engine blocks, transmissions, etc. The Hotsy washer uses a detergent and hot water.
We have successfully cleaned all types of parts. We anticipate changing the wash water
every 6 to 12 months. We believe the wash water will be non-hazardous. The cost to
purchase this size Hotsy was $6000.
89
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Developing A Pollution Prevention Plan
POLLUTION PREVENTION
Solvent is used until its cleaning capacity is exhausted. All tanks are used regularly. At
this time we will not consider on-site distillation because our intention is replacement of
hazardous solvent with aqueous cleaners.
* Replace all solvent parts washers with aqueous washers. We estimate that 2 or 3
additional Hotsy's will be needed to replace our 7 solvent parts cleaners. These
washers will be smaller than the one we have already installed. The cost will be
approximately $3000 each. The estimated payback is 3.2 years for two washers.
* Inform operators to drain parts into tank rather than blow off with compressed
air.
* Turn off parts washers when not in use. Currently, washers are turned off only
during non-business hours.
The Hotsy parts washers will be purchased one per year starting in 1994. Other
measures will be communicated in 1993.
GOALS
1993
1994
1995
1996
1997
WASTE (LB)TREPAIR ORDER
.27
.27
.20
.10
0
90
-------
If we are unable to purchase aqueous cleaners, we will consider solvent distillation.
Estimated Cost:
Investment of Still $5000
Annual maintenance of waste streams:
Replenishing solvent $ 200
Utilities, Labor UNKNOWN
Still bottom disposal $ 500
Estimated Savings:
Cost of waste
paint/thinner and parts cleaners $1900
Estimated Payback: 3 years
The still may also be used to distill gun cleaning solvent. The estimated payback period
would not change significantly due to the low volume.
91
-------
APPENDIX E:
KPPC Fax Request Form
FREE, FAST, CONFIDENTIAL
INFORMATION
-------
the RequestLine: Fax Us to Ask Us
FAX to 502-852-0964 or call (800) 334-8635 xt. 0965
[1 Please send me a listing form fcr ihe Kentucky Industrial Materials
Exchange.
Add me to your mailing Its' to receive the S'Msm Linenewslatter and
i'Wkces o! environ mania! workshops
1 f wcui'irt like infarmalion alioiil an on-sslo polluton prevanlion assessment
| t have 3 difficult waste stream. I would sike ta work vrth you to re«rtuee
fliirnitiale it The wastBslcea.'iVprccess is (totefSy describe):
( woaM liXe for KFFC ta nnaNe a p.resen"aiion at my company about
pcriluikm nreveraicn.
Your name and tillu-
Company fs'ame
Address __
City State, Zip
Dale
93
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U.S. AIR FORCE
INSTALLATION POLLUTION PREVENTION
PROGRAM GUIDE
and
Sample Pollution Prevention
Management Action Plan
July 1996
Compiled by
HQ AFCEE/EP
3207 North Road, Bldg 532
Brooks AFB TX 78235-5363
with the invaluable assistance of
a team from various MAJCOMs,
Installations, HQ AFCESA and
HQ USAF/CEVQ/SGPA
-------
-------
INSTALLATION POLLUTION PREVENTION
PROGRAM GUIDE
TABLE OF CONTENTS
Chapter 1: POLLUTION PREVENTION PROGRAM 1
1.1 Overview of Policy 1
1.2 Program Goals 2
1.3 Purpose and Organization of Guide 4
Chapter!: POLLUTION PREVENTION AS A PROCESS 5
2.1 Overview 5
2.1.1 Pollution Prevention Conceptual Model 5
2.1.2 Pollution Prevention Hierarchy 6
2.2 Pollution Prevention Process 6
2.2.1 Policy 7
2.2.2 Baselines 7
2.2.3 Requirement 7
2.2.4 Options and Solutions 7
2.2.5 Program Execution 8
2.2.6 Metrics and Reporting 8
2.3 Maintaining the Management Action Plan (MAP) 10
2.3.1 Revi ewing the Current PI an 10
2.3.2 Updating the Opportunity Assessment (OA) and MAP 11
2.4 Hazardous Material Inventory Control as a Pollution Prevention Tool 12
Chapters: PROGRAM COMPONENTS 14
3.1 Overview 14
3.2 Ozone Depleting Substances (ODS) 14
3.2.1 Goals 14
3.2.2 Overview 14
3.2.3 Directives 14
-------
Pag
3.2.4 Refrigerants 15
3.2.5 Halons 16
3.2.6 Solvents 16
3.2.7 Procurement Contracts 16
3.2.8 Waivers 16
3.2.9 Tracking and Reporting 17
3.2.10 Alternative Chemicals 17
3.2.11 Additional Resources 17
3.3 EPA-17 Target Chemicals 18
3.3.1 Goal 18
3.3.2 Background 18
3.3.3 EPA-17 Target Chemicals and Typical Uses 18
3.3.4 Typical Opportunities 18
3.3.5 Tracking and Reporting 18
3.4 Hazardous Waste/Industrial Waste 19
3.4.1 Goal 19
3.4.2 Tracking and Reporting 19
3.4.3 Processes Generating Hazardous Waste 19
3.4.4 Typical Hazardous Waste Reduction Opportunities 19
3.4.5 On-Site Recycling/Reuse of Hazardous Waste 20
3.4.6 Additional Resources 21
3.5 Municipal Solid Waste 21
3.5.1 Goals and Objectives 21
3.5.2 Program 22
3.5.3 Program Measurement 22
3.6 Affirmative Procurement 23
3.6.1 Goals 23
3.6.2 Tracking and Reporting 24
3.6.3 Typical Processes/Opportunities 25
3.6.4 Product Sources 25
3.6.5 References 25
3.7 Energy Conservation 25
3.7.1 Goals 25
3.7.2 Background 26
3.7.3 Energy Program 26
3.7.4 Typical Opportunities 27
3.7.5 References 27
-------
3.8 Water Conservation 27
3.8.1 Goals 27
3.8.2 Background 28
3.8.3 Execution 28
3.8.4 Typical Opportunities 28
3.8.5 References 29
3.9 EPCRA and the Toxic Release Inventory (TRI) 29
3.9.1 Background 29
3.9.2 Reporting 30
3.9.3 Goals 31
3.9.4 Tracking 32
3.9.5 References 32
3.10 Pesticide Management 32
3.10.1 Goal s and Measures of Merit 3 2
3.10.2 Integrated Pest Management (IPM) 32
3.10.3 References 33
Chapter 4: TEAM BUILDING AND IMPLEMENTATION 34
4.1 Introduction 34
4.2 The Pollution Prevention Team 34
4.2.1 Pollution Prevention Subcommittee (Working Group) 35
4.2.2 Pollution Prevention Teams 35
4.3 Training 36
4.3.1 AFIT Env 220, Pollution Prevention Course 36
4.3.2 USAFSAM Pollution Prevention Technologies Course 36
4.3.3 AFCEE Opportunity Assessment Training Workshops 36
4.3.4 Other Training Opportunities 36
4.4 Recognition of Personnel 37
Chapters: PROGRAMMING AND BUDGETING 38
5.1 Overview 38
5.1.1 Appropriations 38
5.1.2 Program Element Code (PEC) 3 8
5.1.3 Pollution Prevention Requirements 3 8
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5.2 Pollution Prevention Program Budget and Priorities 39
5.2.1 Recurring Requirements - Operations and Services (O&S) 39
5.2.2 Non-recurring Requirements - Levels I, II, III 39
5.3 Pollution Prevention Program Exclusions 39
5.4 Eligible Projects 40
5.5 Validating the P2 Program Submittal 41
5.6 WIMS-ES 42
Chapter 6: TECHNOLOGY NEEDS 43
6.1 Overview 43
6.2 Technology Needs Survey (TNS) 43
6.3 Technology Assessment 44
6.4 ESOH RD&A Strategic Planning 44
6.5 Base-Level Responsibilities 44
Chapter?: SUPPORTING ORGANIZATIONS 46
APPENDICES
Appendix A - Glossary and Reference Tables
Appendix B - Opportunity Assessment Process, Data Collection Worksheets and
Typical Opportunities
Appendix C - Air Force Pollution Prevention Management Action Plan Prototype
(includes three Sections and three Appendices)
-------
LIST OF FIGURES
Title of Figure Page
Table 1-1, Air Force Pollution Prevention Goals 3
Figure 2-1. Pollution Prevention Conceptual Model 5
Figure 2-2, The Pollution Prevention Process 6
Table 4-1, Responsibilities of the Pollution Prevention Subcommittee 34
Table 4-2, Responsibilities of the Pollution Prevention Teams 35
Table 7-1, Supporting Organizations 46
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CHAPTER 1
POLLUTION PREVENTION PROGRAM
1.1 Overview of Policy
The Air Force (AF) is committed to environmental leadership and preventing pollution by
reducing usage of hazardous materials and releases of pollutants into the environment to as near
zero as feasible. The pollution prevention concept is designed to prevent pollution by reducing
or eliminating harmful discharges to the air, land, and water at the source. Pollution prevention
provides every installation with the opportunity to become good stewards of the environment and
to act on the 13 Mar 95 SEC AF/CS AF Environment, Safety and Occupational Health Initiatives
memorandum:
• Sustain Readiness: Pollution prevention is essential to maintaining and improving
environmental quality. This strongly supports the initiative of "preserving the long-term
environmental vitality of our training ranges and airspace."
• Be a Good Neighbor: Although the SECAF/CSAF memo emphasizes cooperation
with local communities on restoration issues, the Emergency Planning and Community Right-to-
Know Act (EPCRA - see Section 3.9) also offers pollution prevention program managers the
opportunity to cooperate with local agencies. Reductions in pollutant discharges will certainly be
welcomed by all communities which have AF installations as neighbors.
• Leverage our Resources: We "must do more today than ever before, and do it with
increased cost-effectiveness." Pollution prevention reduces the costs associated with hazardous
material purchases and management, hazardous waste management and disposal, compliance
efforts, personal protective equipment and the health impacts resulting from exposure to
hazardous substances. Pollution prevention is an opportunity to change our work processes for
greater safety and efficiency, using the latest environmental technologies.
The AF pollution prevention policy is solidly in step with the national policy of the United States
as stated in the Pollution Prevention Act of 1990:
"...pollution should be prevented or reduced at the source whenever feasible;
pollution that cannot be prevented should be recycled in an environmentally safe
manner, whenever feasible; pollution that cannot be prevented or recycled should
be treated in an environmentally safe manner whenever feasible; and disposal or
other release into the environment should be employed only as a last resort and
should be conducted in an environmentally safe manner."
The AF pollution prevention program involves efforts to reduce the use of wastes through a
hierarchy of actions. The actions range from the most preferred choice of source reduction, to
recycling, treatment, and finally disposal as a last resort. This hierarchy of actions must be fully
integrated into day to day AF operations. By considering how all operations - not just those
Pollution Prevention Program Guide Page 1
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producing hazardous wastes - contribute to the pollution of air, land, and water resources, the Air
Force can better identify and control pollution sources.
In keeping with the requirement for full integration, the Air Force pollution prevention program
applies to all AF installations within the United States, its territories, and foreign countries.
Additionally, it applies to the Air Force Reserves, the Air National Guard, and Air Force
Government Owned Contractor Operated (GOCO) facilities. Each installation, including those
outside the U.S., will develop and execute a Pollution Prevention Management Action Plan (PP
MAP) that addresses source reduction, recycling, treatment opportunities and disposal for major
pollutant sources.
For more details on Air Force pollution prevention policy, consult Air Force Policy Directive
(AFPD) 32-70, Environmental Quality, and Air Force Instruction (API) 32-7080, Pollution
Prevention Programs.
1.2 Program Goals
The Air Force Pollution Prevention Strategy, released by the Air Force Chief of Staff and the
Secretary of the Air Force on 24 July 1995, provides the vision, objectives and goals for
execution of the Air Force's Pollution Prevention program. The Vision Statement reads:
"Effectively promote pollution prevention by minimizing or eliminating the use
of hazardous materials and the release of pollution into the environment. Meet or
exceed regulatory requirements through the use of education, training and
awareness programs, health-based risk assessments, acquisition practices,
contract management, facilities management, energy conservation, and
innovative pollution prevention technologies."
This is to be accomplished through four primary objectives:
• Permeate all mission areas with the pollution prevention ethic through comprehensive
education, training and awareness.
• Institutionalize pollution prevention into all phases of the weapon system life cycle.
• Incorporate pollution prevention in all aspects of installation operations.
• Develop and transition innovative pollution prevention technologies to the field.
Reduction efforts apply equally to all aspects of the AF mission: from concept through
production, deployment, and ultimate disposal of new weapon systems; to finding less hazardous
materials and processes and integrating them into technical orders, military specifications, and
military standards for existing (deployed) systems; to reducing hazardous materials use and waste
generation of installation activities. This Installation Pollution Prevention Program Guide will
focus mainly on the third objective, achieving pollution prevention in installation operations.
Pollution Prevention Program Guide Page 2
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In the AF Strategy, specific goals have been established for selected pollution prevention
program components: Environmental Protection Agency 17 Industrial Toxic Pollutants
(EPA-17), Hazardous Waste, Municipal Solid Waste, Affirmative Procurement, Energy /Water
Conservation, Toxic Release Inventory (TRI) Chemicals, and Pesticide Management. These
program components will be continuously monitored and measured against their respective
baselines to ensure goals are achieved.
TABLE 1-1
AIR FORCE POLLUTION PREVENTION GOALS
PROGRAM COMPONENT:
BASELINE
YEAR:
Environmental Protection Agency 1992
17 Industrial Toxic Pollutants (EPA-17)
Hazardous Waste Minimization
Municipal Solid Waste
1992
1992
Environmentally Preferable None
Products (Affirmative Procurement)
Energy Conservation
TRI Chemical Releases
Pesticide Management
1985
1994
1993
GOAL:
50% Reduction of purchases
by 31 Dec 96
25% reduction in disposal by 31 Dec 96
50% reduction in disposal by 31 Dec 99
10% reduction in disposal by 31 Dec 93
30% reduction in disposal by 31 Dec 96
50% reduction in disposal by 31 Dec 97
100% of all products purchased each
year in each of EPA's "Guideline Item"
categories shall contain recycled
materials meeting EPA's Guideline
Criteria
10% reduction in BTU/sq ft by 1995
20% reduction in BTU/sq ft by 2000
30% reduction in BTU/sq ft by 2005
50% reduction of total releases and
off-site transfers by 1999
50% reduction in pounds of active
ingredient by 2000
Another component of the AF Strategy is the reduction or elimination of the use of Ozone
Depleting Substances (ODS). Although there is no numeric reduction goal currently associated
with purchases of ODS, their purchase requires SAF/AQ approval through the waiver process.
This will be discussed further in Chapter 3.
Pollution Prevention Program Guide
Page 3
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1.3 Purpose and Organization of Guide
The purpose of this guide is to give AF personnel a comprehensive document describing how to
implement AF pollution prevention policy and maintain effective programs at their installations.
Pollution prevention is an evolving program; this edition of the guide is the second update to the
initial edition published in July 94, and additional revisions will follow in future years.
Personnel are encouraged to expand this document as required and to send suggested changes to
HQ AFCEE/EP.
Chapter 1 provides the policy background, mandate, and context for the pollution prevention
program. Chapter 2 describes the pollution prevention process and the MAP as an execution
tool. Chapter 3 details the program components including ozone depleting substances;
EPA-17 target chemicals; hazardous materials/waste; municipal solid waste; affirmative
procurement; energy and water conservation; EPCRA, including the Toxic Release Inventory;
and pesticide management. Chapters 4 through 7 focus on other aspects of an effective program,
to include team building, programming and budgeting, technology needs, and sources of
information.
Pollution Prevention Program Guide Page 4
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CHAPTER 2
POLLUTION PREVENTION AS A PROCESS
2.1 Overview
This chapter reviews the pollution prevention process and the methodology for developing a
Management Action Plan (MAP), and then explains how to reevaluate the MAP to keep the
program on target. It does not address organizational structure or the detailed goals of specific
pollution prevention program components, which are covered in other chapters.
A well prepared MAP is the key to a successful pollution prevention program. All AF
installations were required to have MAPs completed by December 1995. The program's focus
now switches from developing a plan, to maintaining the plan and measuring the program's
success.
2.1.1 Pollution Prevention Conceptual Model. AF activities may be modeled as processes
(e.g. base industrial activities, administrative activities, support activities and family housing),
each relying on a steady stream of material and energy. Waste is generated as a by-product of
these processes. Specific goals and objectives for pollution prevention program components
target subsets of these input (material) and output (waste) streams. The relationships in these
processes are shown in Figure 2-1.
FIGURE 2-1
POLLUTION PREVENTION CONCEPTUAL MODEL
Energy and Materials
(incl HAZMATs and ODCs)
Product or Service
Air Force
Processes
By-Products
Energy and Materials
(incl municipal and
hazardous wastes)
Affirmative
Procurement
Recycling
Outside AF
AF processes are fueled by energy and materials. Some of the materials purchased are hazardous
to human health or to the environment. Hazardous wastes are by-products that can pose a
Pollution Prevention Program Guide
Page 5
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substantial or potential hazard to human health or the environment when improperly managed.
They possess at least one of four characteristics (ignitability, corrosivity, reactivity, or toxicity),
or are listed in 40 CFR 261.30 or applicable state or local waste management regulations.
Municipal solid waste (trash) is non-hazardous waste generated by domestic and industrial
processes. Hazardous material use often produces hazardous emissions into the air or water,
increasing environmental and occupational safety and health requirements for these media.
Hazardous material can even become hazardous waste through non-use (i.e., through expiration
of shelf-life).
2.1.2 Pollution Prevention Hierarchy. Changing processes to eliminate purchases of
undesirable "targeted" materials and generation of wastes is known as "source reduction." Where
source reduction is not feasible or cannot eliminate waste, materials may be reused or recycled to
reduce waste and purchase requirements. Goals to purchase environmentally preferable products
through affirmative procurement programs help "close the recycling loop" by creating demand
for recycled products. Treatment of wastes and emissions control to reduce environmental
impacts prior to disposal is a last resort.
2.2 Pollution Prevention Process
Figure 2-2 represents the process of developing and executing a pollution prevention program.
The following subparagraphs describe each portion of the process.
FIGURE 2-2
THE POLLUTION PREVENTION PROCESS
BASELINES
METRICS
AND
REPORTING
Pollution Prevention MAPs are the documentation of this process. They are based on recurring
opportunity assessments designed to continually evaluate an installation's success in achieving
Pollution Prevention Program Guide
Page 6
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pollution prevention at the highest level in the hierarchy of actions. A sample MAP is included
as Appendix C to this guide.
2.2.1 Policy. Refer to Chapter 1 for a discussion of policy.
2.2.2 Baselines. A baseline is a measurement of the amount of targeted substance purchased or
generated during a specified time period. The baseline is the beginning status relative to a goal,
and is the basis for calculating future progress toward the goal. Your installation has established
baselines for all program components except affirmative procurement (see Table 1-1). They are
individually listed in the installation MAP in Section 1.2, and summarized in the Program
Summary table in Section 2.
2.2.3 Requirement. The requirement for minimization for each program component equals the
difference between the goal and the baseline. For affirmative procurement, the requirement will
equal the difference between the goal and the current measurement. The requirement identifies
what the program needs to do. For example, the first Energy goal is to reduce energy use 10% by
the end of CY 1994 from a 1985 baseline. If the 1985 consumption was 0.149 MBTU, a 10%
reduction amounts to 0.0149 MBTU; this is the requirement. If energy consumption efforts after
1985 have already yielded a reduction of 0.004 MBTU, this can be subtracted, and the remaining
requirement is 0.0109 MBTU, or the amount of reduction still needed to attain the goal. This
process is repeated to obtain the requirements for the second and third phase energy reduction
goals (20% by 2000 and 30% by 2005 respectively). Requirements are individually listed in the
MAP in Section 1.3, and summarized in the Program Summary table in Section 2.
2.2.4 Options and Solutions. Options include all possible ways to achieve the goals. They may
involve procedural changes, material substitutions, equipment purchases, facility modifications
or construction, technology needs, or any combination of these. A list of options is generated for
each program component, they are evaluated against criteria established by the base (cost,
feasibility, environmental benefit, mission effectiveness, etc.) and then ranked in priority order.
Solutions are chosen from the prioritized lists of options, developing a cumulative total of
expected reductions for each component (pounds of hazardous waste, tons of MSW, etc.) until
the total reductions meet the previously identified requirements. Finally, the selected solutions
for each program component are listed and described in Chapter 2 of the MAP.
For program components with phased requirements (sequential goals in various fiscal years),
plan to meet the requirements with groups of actions which will provide sufficient reductions to
meet each phase. Once the initial requirement is met, determine the next solution set by
continuing down the list until the benefits exceed the next phase's requirement, and so on.
Projects selected to satisfy a second phase requirement should generally be programmed after the
deadline imposed by the first requirement. For example, projects supporting between 25% and
50% hazardous waste reduction by the end of 1999 should be programmed after the end of 1997,
when hazardous waste is to be reduced by 25%.
Pollution Prevention Program Guide Page 7
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Some solutions may require MAJCOM approval or assistance, while others may require Air
Force Materiel Command (AFMC) assistance for technology solutions. MAJCOMs are
responsible for identifying technology needs (see Chapter 6).
The base should choose criteria to decide what shops, processes or activities to evaluate for
pollution prevention reductions. These criteria may include:
• Waste generation rates - largest or most toxic waste streams
• Hazardous material usage rates
• Possibility of using pollution prevention to eliminate current industrial health concerns,
environmental compliance problems, or reporting requirements
To fully exploit all pollution prevention options, consider all activities. Don't overlook the base
exchange, commissary, snackbars, hobby shops, service stations, golf course, and hospitals.
Construction projects are a large source of solid waste; a pollution prevention review during
project design may yield huge benefits.
2.2.5 Program Execution. The MAP is the installation's single reference to manage the
development and execution of the pollution prevention program. A well prepared plan will
document an installation's previous, current and future pollution prevention actions. It will also
support Toxic Release Inventory (TRI) reporting by including reduction efforts associated with
the installation's releases as reported on the Form R.
The MAP has three sections: process, program, and execution. Each section lists required
management actions, who is responsible for doing them, and when they will be completed.
The execution plan for the program is contained in the MAP in Chapter 3, including the chosen
solutions satisfying the goals of each program component; required actions; schedules; and
OPRs. The level of detail is up to each environmental manager. Subdivisions in this section will
generally be each program component, then each chosen option. For example, in the municipal
solid waste area, there may be a project to purchase two cardboard baling machines. Examples
of actions associated with executing this project might be identifying where the machines will be
located, who will operate them, how operators will receive training, how procedures will be
modified to use the machines (e.g., asking customers to segregate cardboard waste, how
cardboard bales will be transported, etc.), and other details determined by the installation to be
important enough to formally manage.
To get necessary funding, the cost of these solutions needs to be included in budget and Program
Objective Memorandum (POM) submittals as appropriate. See Chapter 5 of this guide and API
32-7001, Environmental Budgeting, for programming and budgeting information. Execute
pollution prevention projects as soon as they are funded. Early execution of pollution prevention
projects will result in early return on investment.
2.2.6 Metrics and Reporting. Installations must measure the actual benefit of implemented
ideas and compare them with the projected benefits. The program should then be adjusted
accordingly, adding or deleting ideas to the program if benefits are disappointing. This will
Pollution Prevention Program Guide Page 8
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"close the feedback loop" to ensure the pollution prevention program will ultimately meet its
goals. Progress toward goals will be measured and reported to MAJCOMs, where it is
summarized and reported using metrics provided in HQ USAF/CEV's 16 Oct 95 letter, Quarterly
Reporting of Pollution Prevention Metric Data. Although Civil Engineering is tasked with
reporting, the data will come from many functional organizations including Supply and
Bioenvironmental Engineering.
The numerous changes taking place on AF installations have caused confusion in establishing
baselines and reporting metric data. HQ USAF/CEV's 16 Oct 95 memo transmitted the latest
Metric Reporting Guidance, summarized below .
As installations transfer between MAJCOMs, coordinated baseline data adjustments will be
made such that the Air Force totals will remain constant. No adjustments will be allowed to
compensate for mission changes, personnel increases or decreases, or Base Realignment and
Closure Commission actions. When an installation closes, the MAJCOM does not remove their
data from the baseline and previously reported numbers. The rationale for this guidance is that
when an installation closes, the missions on that installation typically transfer to other
installations within the same MAJCOM.
The adjusted baseline data will be used to measure all progress toward the AF pollution
prevention goals. MAJCOMs report data to HQ USAF/CEV for the following target areas:
Hazardous Waste Disposal (reported quarterly): Report quantity of pounds disposed, regardless
of disposal avenue (on-site in permitted facilities, or off-site through DRMO or installation
contracts). Include small spills and normal installation operation wastes, but exclude wastes
from major spills such as train derailments; wastes from contaminated fuel or oil removed as part
of the Underground Storage Tank Program; or any wastes resulting from Installation Restoration
Program cleanup.
Municipal Solid Waste (MSW) (reported quarterly): Report the number of tons generated for
each of four categories: disposed, recycled, composted, and waste-to-energy consumption.
Exclude construction and demolition debris. Note this metric data is separate from the annual
HQ AFCESA/CESM solid waste survey, which requires a response from all MAJCOMs on their
solid waste stream in order to identify reduction opportunities.
Number of Units Utilizing Class I OPS (reported quarterly): Each occurrence of the following is
a "unit". Report the total number of units using Class I ODS at the installations.
• Refrigeration system greater than 5 tons
• Facility halon flooding system
• Facility portable extinguisher
• Flight line extinguisher
• Any other miscellaneous halon system that has been identified in the equipment inventory for
the installation's halon management plan.
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Quantity of Class I OPS (reported quarterly): Report the number of pounds of ODS installed in
the units above and in bench stock. Data will be reported by type of ODS (Halon 1301, R-12,
etc.)
EPA-17 Chemicals Usage (reported annually): Report the quantity used, in pounds.
Affirmative procurement metrics are still being defined. They will be structured differently from
the program components previously discussed. Instead of developing a baseline and reducing
our totals to some percentage of that baseline, we work to maximize the purchase of EPA-
designated products ("Guideline Items") containing recycled materials. Affirmative procurement
is discussed further in section 3.6 of this Guide. The base MAP should include listings of all
Guideline Items the base purchases (MAP Chapter 2) and the actions required to ensure all of
these purchases contain sufficient recycled materials to meet EPA recommendations (MAP
Chapter 3).
2.3 Maintaining the MAP
The Management Action Plan should be viewed as a living document reflecting changes in
missions, pollution prevention technology and regulatory requirements. Progress toward
pollution prevention goals needs to be measured and tracked. If small corrective actions are not
taken when they are needed, large ones will be needed later.
As the MAP is reviewed and revised, be sure to pay equal attention to new operations and
activities. New facility construction, new industrial processes, and even projects to repair
buildings and equipment, all offer opportunities to plan pollution prevention into the project.
Remember to consider pollution prevention as a part of the environmental impact analysis
process for all new projects and activities coming to the installation.
2.3.1 Reviewing the Current Plan. Depending on how complete and recent the MAP is, the
base team will need to decide whether it is adequate, needs only updates and minor additions, or
needs to be completely redone starting with a basewide OA. The following audit questions can
be used to determine the health of the current OA and MAP:
1. How recently were the OA and MAP published? Are all AF pollution prevention program
components addressed?
2. Are the schedules in the current MAP being met? Which actions were implemented?
Which were not?
3. What missions have changed since the OA was performed?
4. Did the OA cover all base activities that create health, safety, or environmental issues?
5. Did the OA and MAP address the biggest waste generators and the biggest users of
hazardous materials?
6. How have base shops changed: processes, equipment, people, missions?
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7. Is a cultural change evident? Has training and awareness brought positive attitude changes
towards Pollution Prevention?
8. Are waivers or authorized substitutes for hazardous chemicals in use?
9. Did the actions implemented so far significantly reduce waste disposal and hazardous
material usage rates?
10. How much further to meet reduction goals?
11. Are base personnel adequately trained to perform OAs?
12. Are the above changes significant enough to warrant a new basewide OA?
To answer these questions, it's absolutely necessary to know the program status. If the current
OA and MAP are inadequate - grossly outdated or incomplete, or (at the other extreme) if all
actions have been completed - redo the OA and MAP following the steps outlined in Appendix
B. If the plan is basically sound and is yielding results, but needs a little tinkering to bring it up
to date, consider "spot" OAs and improvements to the MAP.
2.3.2 Updating the OA and MAP. The basewide OA will be easier to update if it consists of
individual process OAs on loose-leaf paper in a binder. New assessments can be added as
missions, processes and goals change.
The first step is to define targets. Where do you want or need new OAs? Know your strengths
and weaknesses. Look at the current plan to see what worked and what didn't. Focus on lacking
areas. The 1995 AF Pollution Prevention Strategy added new reduction goals; ensure there are
OAs and MAP actions to support all of the latest goals.
Next, consider all possible types of reduction opportunities. Here are some ideas:
• Conduct an education campaign to create cultural changes
• Reward suggestions to foster individual involvement
• Look beyond shop walls
• Improve housekeeping and segregation of wastes and materials
• Conserve - Turn off the tap and the lights
• Reexamine processes: improve handling, storage, timing, materials usage
• Research more equipment, newer technologies
• Include more on-base organizations and activities, expand targets
• Research pesticide and herbicide use
• Review Model Shop Reports
• Consider how the MAP actions interact with Base Comprehensive Plans, Stormwater Plans,
Natural Resources, Water/Energy Conservation, Spill Prevention, Pest & Grounds
Management, Toxics Management Plans, HW and SW Plans, etc.
The third step is to define your capabilities. Can the effort be handled in-house; will there be
internal team support? Consider taking on "easy" areas and focusing a contractor on more
complicated issues that require more research. Form a team including the BEE, CEV or EM, LG,
the Pharmacy, process owners and shop personnel. Borrowing personnel from other shops for
OAs often helps to crossfeed ideas and solutions.
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Fourth, do the OAs. Familiarize the team with any previous OAs for the shop, then use the
checklists in Appendix B to conduct new or supplemental OAs. When visiting the shop think
about all aspects of pollution prevention, trying to stay as high on the hierarchy as possible
(source reduction first, then recycle or reuse). Remember to look for affirmative procurement
opportunities. Look at other shops having similar problems, processes, or materials for ideas.
Develop a list of new opportunities; evaluate them and select the most promising. Remember, at
this stage not all the options will be easy. Break the "Convenience Paradigm"; don't just say it
"takes too much time", measure the time and effort that's required and do a cost benefit analysis.
Look beyond territorial boundaries; if three shops use the same solvent, consider buying one
solvent still for all three to use to recycle their waste. Or better yet, consider consolidating the
workload into one area.
Next, supplement the old basewide OA with the new opportunities. Document the shops visited,
the options identified, and the options selected. Consider keeping a "shop by shop list" so that
the next team updating the OA will see what has already been considered, accepted and rejected.
Develop one-sheet descriptions for the selected options, including cost-benefit analysis, and add
them to the basewide OA binder.
The final step is to revise the MAP and request any necessary funding. Quantify expected
pollution prevention gains; prioritize the new actions along with the other opportunities in the
MAP that have not yet been accomplished; and define and assign action items. Update Chapter 1
of the MAP to show new management actions, or to add completion dates for previously defined
actions. In Chapter 2, revise the Program Summary and all of the individual sections (ODS, FEW,
EPA-17, etc.) for which new options were added. Add all new projects to the execution plan in
Chapter 3. Add requirements to the A-106 and budget submittals as needed to obtain funding.
2.4 Hazardous Material Inventory Control as a Pollution Prevention Tool
The Hazardous Material Pharmacy (or HazMart) and the Air Force - Environmental Management
Information System (AF-EMIS) software are powerful tools for reducing hazardous material use
and collecting data for MAPs and metrics.
HQ USAF/LG's 31 May 1995 Hazardous Material Pharmacy (HMP) Organizational Change
Package formally establishes the HMP as a part of the Air Force's Objective Wing structure.
The pharmacy offers single-point accountability over the requisitioning, receipt, repackaging, and
issue of hazardous material and is analogous to the control over prescription drugs. Control of
hazardous material can eliminate unnecessary purchases, diminish handling hazards, and reduce
hazardous waste disposal costs for unused, expired material. A pharmacy is composed of three
activities:
• Authorizing the request: Each request for hazardous material should be given a health and
environmental impact review. Each request should also be reviewed by logistics for quantity,
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unit of issue, alternative sources of supply (currently available on installation, smaller
quantity vendor) and current supply position.
• Distributing or dispensing the material: Each receipt of material should be provided to the
pharmacy user organization in a reasonable quantity and within a reasonable time.
("Reasonable" shall be defined in a memorandum or agreement/understanding between the
pharmacy and the using organization). This activity may require a new facility.
• Tracking and reporting: All material requested, received, issued, used, returned, and stocked
on the installation needs to be recorded. To comply with EO 12856, toxic chemical data
must be gathered, processed and reported on the Form R (when required).
The Commander's Guide to the Implementation of the Hazardous Materials Pharmacy and the
PRO-ACT Information Packet - HAZMAT Pharmacy are useful references for installations
establishing a pharmacy. These documents are available from PRO-ACT; see Chapter 7 for
contact information.
The AF-EMIS is a Windows-based environmental, occupational health and safety focused
hazardous material management tool. It is entirely Air Force owned and developed. The primary
environmental objective of the AF-EMIS is pollution prevention. Prior to ordering hazardous
materials, the user must submit a request that provides detailed material, industrial process,
workplace training and waste disposal information. The request must pass a rigorous review by
environmental, bioenvironmental, supply and hazardous material pharmacy personnel. Once
approved, the AF-EMIS maintains an authorized users list for each material, material safety data
sheet information, including constituent data, waste profile information, as well as all the
information from the original request. As the day-to-day hazardous material supply transactions
are completed, the AF-EMIS builds quantity and usage data for material compounds and for the
individual constituents. The AF-EMIS can supply data for many reports. Among them are
EPCRA, bioenvironmental engineering workplace inventory, ozone depleting substance (ODS)
information, waste manifests, DD Forms 1348, complete usage data by authorized user, by
chemical constituent and by hazardous material.
The AF-EMIS features barricading, an automated link to the standard base supply system
(SBSS), to the quality shelf-life listing (QSL) and to the Hazardous Material Information System
(HMIS). The system is available to all Air Force installations. The AF-EMIS is a key source of
hazardous materials data.
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CHAPTER 3
PROGRAM COMPONENTS
3.1 Overview
Pollution prevention addresses the reduction and recycling of ozone depleting substances,
hazardous waste/industrial waste and municipal solid waste; reduction of EPA-17 target
chemicals, Toxic Release Inventory (TRI) chemicals and pesticides; and programs for affirmative
procurement, energy conservation, and water conservation. The purpose of this chapter is to
discuss in detail each of these program components.
MAJCOMs are to establish a pollution prevention program that crosses functional areas to meet
these AF goals and objectives. The following discussion addresses, as appropriate, the unique
aspects of each of these program areas, typical uses, and typical opportunities for reduction in use
or recycling.
3.2 Ozone Depleting Substances (ODS)
3.2.1 Goals. Air Force Pollution Prevent!on Goals concerning ODS:
• Cease purchases of halon (Class I ODS) by 1 Jun 93
• Cease purchasing air conditioners, Aerospace Ground Equipment (AGE) and other
refrigeration and support equipment containing Class I chlorofluorocarbons (CFCs) after 1
Jan 93
• Cease purchasing commercial vehicles with ODS air conditioning equipment after
1 Jun 93
• Cease purchasing newly produced Class I CFC refrigerants by 1 Jun 93
• Cease awarding contracts requiring use of ODS by 1 Jun 93
• Reclaim and recycle ODS in accordance with current AF procedures
3.2.2 Overview. ODS are substances that deplete the earth's stratospheric ozone layer, and
contribute significantly to greenhouse warming. Some examples include CFCs and
hydrochlorofluorocarbons (HCFCs) which are used in ground air conditioning and refrigerant
systems, automobile air conditioning systems, cleaning solvents and aerosol sprays. Another
category of ODS is halon. Halons are primarily used in fire suppression systems and for vector
control in some missile systems. Other controlled substances include carbon tetrachloride and
methyl chloroform, which are used primarily as cleaning solvents and methyl bromide, which is
used as a pesticide and fumigant. Table A-l (Appendix A) identifies the Class I and Class II
ODS.
3.2.3 Directives. The Department of Defense (DoD) has established policies for CFCs and
halons in DoD Directive (DoDD) 6050.9. It outlines steps required to comply with the Montreal
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Protocol (Sep 87), the Copenhagen-amended Montreal Protocol (1992), the Clean Air Act (CAA)
of 1990, and the National Defense Authorization Act for FY 1993. These laws/acts restrict the
production, purchase and use of Class I ODS listed in Appendix A, Table A-l. See Section
3.2.11 for suggested reading materials for these specific acts and regulations.
Additionally, the AF Pollution Prevention Strategy calls for SAF/AQ and HQ USAF/LG (with
the assistance of SAF/MI and all MAJCOMs) to establish an aggressive program to identify, and
reduce or eliminate, the use of ODS. Technical Orders and MILSPECS are being changed. This
effort is proceeding separately from the PP MAP effort, and will be essential to the AF's ability
to reduce or eliminate the use of ODS.
3.2.4 Refrigerants. The purchase of facility air conditioning systems, aerospace ground
equipment (AGE), other refrigeration and support equipment, and commercial vehicles that use
Class I ODS, without an approved waiver, is prohibited as of 1 Jan 93. Existing equipment
presently being used will be phased out through normal attrition or conversion at scheduled
overhaul. The determination of conversion or replacement is one of economics and should be
based on life cycle costs. There is no requirement for change out or conversion for the sake of
becoming "CFC free". All weapons systems (pre Acquisition Milestone III as of 1 Jan 93) shall
be designed to use non-Class I ODS refrigerants. The purchase of newly produced ODS
refrigerants without an approved waiver is prohibited as of 1 Jun 93.
The pollution prevention program will support the following projects with funding:
• ODS recycling/reclaiming equipment
• Chiller modifications for leak detection
• Efficient purge hardware
The base Refrigerant Manager, located in the Base Civil Engineering organization, manages
facility air conditioning/refrigerant (AC/R) equipment and regulated refrigerants through the use
of a Refrigerant Management Plan (RMP). The AF Strategy set a goal for all installations to
have this plan in place by December 1995.
AFCES A/EN's Refrigerant Management Handbook focuses on conservation measures and the
development of the RMP. Conservation measures include improved servicing techniques,
training and certifying technicians, and recording equipment maintenance and refrigerant usage.
The RMP provides a plan to ensure adequate refrigerant supplies will be available to meet
mission needs until the last of the units using CFC refrigerants have achieved their full economic
life. The RMP provides a refrigerant inventory timeline that shows refrigerant consumption
rates, equipment retirements, and other activities which affect the inventory of refrigerant. An
implementation schedule is part of the RMP. A simple comparison of a plan's projected
refrigerant inventory quantity versus what is actually on-hand will determine whether the base is
in danger of a negative mission impact.
EPA's final rules for facility AC/R technician training and motor vehicle air conditioning
(MVAC) equipment have five main elements:
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• Established required practices for technicians servicing and disposing of air conditioning and
refrigeration equipment;
• Established a certification program for technicians servicing air conditioning and
refrigeration equipment;
• Established a certification program for recovery and recycling equipment;
• Established a requirement to repair equipment with substantial leaks;
• Established requirements for removing ozone-depleting refrigerants from appliances,
machines, and other goods prior to disposal.
There were two effective dates and regulatory references for technician training and certification.
40 CFR 82.40 addresses the MVAC service requirements which became effective on 1 January
1993. 40 CFR 82.161 covers facility AC/R equipment, and became effective 14 November
1994.
3.2.5 Halons. The purchase of newly produced halons or obtaining halon through the Defense
Reserve (Defense Logistics Agency [DLA] Bank), without an approved waiver, is prohibited
(see Section 3.2.8 on waivers). MAJCOMs may request waivers for mission critical halon
applications. "Mission critical" is defined as those halons used on board aircraft to meet flight
safety, flight survivability, or flight certification requirements.
Like the refrigerant management program described in Section 3.2.4, the halon management
program has a requirement for preparation of a management plan. The AF Strategy calls for each
installation to have this plan in place by December 1995. Engineering Technical Letter (ETL)
95-1, Halon 1301 Management Planning Guidance, describes Air Force goals and requirements
for managing Halon 1301 to ensure its availability for mission critical requirements while
minimizing halon dependency and releases into the environment. A sample management plan
outline is included in the ETL.
3.2.6 Solvents. The purchase of ODS solvents and equipment/systems/products requiring ODS
solvents for maintenance or operation must be approved by SAF/AQ. Some solvent use has been
identified as mission critical for which an acceptable substitute has not been found. Such
solvents are now being purchased for the DLA bank.
3.2.7 Procurement Contracts. Contracts awarded on or after 1 Jun 93 must not include
specifications or standards that require the use or that only can be met by the use of Class I ODS,
unless an exception is approved. SAF/AQ, HQ USAF/LG and HQ USAF/CE are the approval
authorities for their respective areas.
3.2.8 Waivers. In the National Defense Authorization Act for FY 1993 (P. L. 102-484) waivers
are permitted for the purpose of extending time to develop and implement ODS alternatives. The
new waiver procedures require a "use" waiver for all uses of ODS, whether purchasing new
ODS, obtaining ODS from the DLA bank, or using recycled materials. "Use" is defined as
dispensing and employing Class I ODS in the operation of any system or in support of any
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system. For refrigerants and halons, this refers to the amount required to recharge a system
during maintenance, not the quantities already in the system. Waiver approvals are required:
• prior to award of any contract that requires the use of a Class I ODS;
• prior to purchase of any Class I ODS;
• prior to obtaining Class I ODS from the Defense Reserve DLA ODS bank for mission critical
applications;
• for the use of Class I ODS, including recycled materials.
3.2.9 Tracking and Reporting. ODS are tracked in quantities of pounds used/quarter or
pounds purchased/quarter. Installations report ODS quantities to their MAJCOMs in accordance
with HQ USAF/CEV s Metric Reporting Guidance. See section 2.2.6 of this Guide for details.
3.2.10 Alternative Chemicals. Substitute chemicals to replace ODS must be chosen with care.
Consult with the Bioenvironmental Engineering (BEE) flight to identify potential hazards
associated with alternative chemicals. Alternatives which are hazardous or are Class II ODS may
be used only as a last resort after all other environmentally preferable alternatives have been
evaluated and rejected for technical or economic reasons. EPA has the authority to identify and
restrict the use of substitutes for Class I and II ODS where other alternatives exist that reduce
overall risk to human health and the environment. The program that provides these
determinations is the Significant New Alternatives Policy (SNAP) Program.
Final rules for the SNAP Program were issued in the March 18, 1994 Federal Register. Under
SNAP, EPA can approve or disapprove the use of chemicals, product substitutes, or alternative
manufacturing processes, whether existing or new. The rule includes listings of acceptable
substitutes, unacceptable substitutes, and pending decisions for ODS "use sectors". EPA
publishes quarterly updates to the SNAP lists in the Federal Register. Contact PRO-ACT (see
Chapter 7) for the latest SNAP program information and other EPA rulings.
3.2.11 Additional Resources. Additional information and details concerning ODS may be
obtained by consulting the following documents:
• API 32-7080
• Air Force Ban on Purchases ofODCs - ACTION MEMORANDUM, 1 Jan 93
• Air Force ODC Interim Waiver Application, Approval Procedures, and Reporting
Requirements., 14 Jul 93
• Air Force Pollution Prevention Strategy., 24 July 1995
• EO 12843, Procurement Requirements and Policies for Federal Agencies for Ozone
Depleting Substances, 21 Apr 93, Office of the Press Secretary
• Guidance for Eliminating the Use of Class I ODS in Military Procurement Contracts, 20 May
93, Department of Defense
• Final Air Force Contracting Policy for Elimination of Class I ODS, SAF/AQC,
14 Oct 94
• Refrigerant Management Handbook., AFCESA Systems Engineering
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40 CFR 82.40, technician training and certification requirements for motor vehicle air
conditioning (last updated 2 May 1995)
40 CFR 82.161, technician certification requirements for facility air conditioning and
refrigeration equipment (last updated 9 Nov 1994)
Procedures for Turning In Ozone Depleting Substances (ODS) to the Defense Reserve, DLA,
8 July 94
Engineering Technical Letter (ETL) 95-1, Halon 1301 Management Planning Guidance, 12
May 95 (note: this ETL also includes attachments detailing AF procedures for requisition
and turn-in of ODS to/from the Defense Reserve)
Significant New Alternatives Policy (SNAP), EPA (59 FR 13044, originally published March
18, 1994 and updated quarterly in the Federal Register)
PRO-ACT Information Packet - Refrigerant Recovery Equipment
3.3 EPA-17 Target Chemicals
3.3.1 Goal. By the end of 1996, the AF goal is to reduce purchase of EPA-17 Industrial Toxic
Pollutants by 50% from a 1992 baseline. Progress will be assessed by measuring the weight in
pounds of substance purchased compared to the CY92 baseline. The new AF Pollution
Prevention Strategy calls for SAF/AQ and HQ USAF/LG (with the assistance of SAF/MI and all
MAJCOMs) to establish an aggressive program to identify, and reduce or eliminate, the use of
EPA-17 toxics. Technical Orders and MILSPECS will be changed. This effort is proceeding
separately from the PP MAP effort, and will be essential to the AF's ability to meet its EPA-17
reduction goals.
3.3.2 Background. EPA has selected seventeen target chemicals for reduction or elimination of
their use based on the volume of use, toxicity, persistence, and mobility. These chemicals were
drawn from the Toxic Release Inventory (TRI) List in the Superfund Amendments and
Reauthorization Act (SARA) Title III.
3.3.3 EPA-17 Target Chemicals and Typical Uses. Appendix A, Table A-2 identifies the
EPA-17 chemicals and typical processes and/or uses for these chemicals at AF installations.
3.3.4 Typical Opportunities. Potential reduction/recycle methods are described briefly in
Appendix B. This discussion provides some of the more common methods available to reduce
the use of EPA-17 chemicals or recycle those that are being used. Additional suggestions may be
found in Air Force Model Shop Reports, available from PRO-ACT (see Chapter 7 for contact
information). Remember that prior to making any substitution for chemicals used in a process,
you must obtain concurrence of the engineering authority with management responsibility for any
applicable Technical Orders (TOs).
3.3.5 Tracking and Reporting. The EPA-17 chemicals are tracked in quantities of pounds
used, as described in HQ US AF/CEV s Metric Reporting Guidance. See section 2.2.6 of this
Guide for details.
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3.4 Hazardous Waste/Industrial Waste
3.4.1 Goal. The objective is to reduce hazardous waste disposal 25% by the end of 1996 and
50% by the end of 1999 from the CY 92 baseline.
3.4.2 Tracking and Reporting. API 32-7042, Solid and Hazardous Waste Compliance,
requires automated reporting of hazardous waste from accumulation to disposal through the
WIMS-ES Hazardous Waste Module. Reporting requirements are given in HQ USAF/CEV's
Metric Reporting Guidance. See section 2.2.6 of this Guide for details.
Hazardous waste disposal quantities are reported in pounds and include all hazardous waste
disposal through the installation (via contract, Defense Reutilization and Marketing Office
(DRMO), etc.). Hazardous waste accepted from offsite facilities should not be included in the
installation's figures. If an installation's state regulates used oil as a hazardous waste, disposal
figures should be considered a reportable quantity. Wastes removed or treated under the Defense
Environmental Restoration Account (DERA) program do not count toward total hazardous waste
quantities included in baselines.
Disposal information can be obtained from the documents listed below. Currently there is no
standardized automated tracking program for compiling the HW disposal quantities.
• Hazardous Waste Disposal Manifests - include all disposal contracts, e.g., Safety Kleen,
DRMO, installation contracts. (Note: if certificate of destruction or treatment codes on HW
manifest indicate recycling or fuels reblending, the item should not be reported as disposed.)
• Annual Federal and state hazardous waste disposal summaries generated at the installation.
3.4.3 Processes Generating Hazardous Waste. Hazardous waste is generated through many
processes typical to most Air Force installations. However, identification of new hazardous
waste streams is ongoing and requires constant attention. The WIMS-ES Waste Stream Program
is a tool developed to record individual waste stream data and allows for electronic transfer of the
information to MAJCOM and Air Staff. This provides a crossfeed mechanism, as the waste
stream may not have been identified at other bases.
Processes with associated hazardous waste streams typical to all installations are listed in
Appendix B. Installations should also cross check these processes with their opportunity
assessments to ensure all waste streams have been identified.
3.4.4 Typical Hazardous Waste Reduction Opportunities. Opportunities exist in almost all
processes to reduce and/or eliminate hazardous waste generation. Each installation should
conduct opportunity assessments to define current waste management practices, characterize
existing waste streams and assess actions needed to reduce and/or eliminate waste. Assessments
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should be done at all facilities on base as appropriate toward reaching the pollution prevention
goals.
Waste Segregation is a simple opportunity that should be practiced at all installations. Physical
segregation of hazardous and non-hazardous waste streams increases waste minimization effort
capabilities, such as recycling, and it also decreases the costs associated with waste disposal. It is
easily achieved by recurring hazardous waste management and awareness training and the use of
good waste handling techniques. Waste streams must be properly classified in order for them to
be properly segregated. Consult your installation hazardous waste management plan and
hazardous waste program manager for more information.
Waste minimization opportunities focus on source reduction or recycling activities that reduce
either (or both) the volume or the toxicity of hazardous waste generated. Waste treatment is
another option that may be considered, however, it is the least favored alternative. Treatment is
typically performed downstream of the source on a waste stream generated by various facilities.
Additionally, it normally requires regulatory notification and/or permitting.
A list of some hazardous waste minimization opportunities is presented in Appendix B.
Additional opportunities may be found in Air Force Model Shop Reports, available from PRO-
ACT (see Chapter 7 for contact information). Recycling refers to the use or reuse of a waste as
an effective substitute for a commercial product, or as an ingredient or feed stock in an industrial
process. Federal and local regulatory requirements dictate how reuse of waste materials must be
used in order to qualify as recycling; see section 3.4.5. Source reduction refers to the reduction
or elimination of waste generation at the source, usually within a process. The Hazardous
Material Pharmacy concept, discussed in more detail in section 2.4, provides a mechanism for
hazardous material source reduction through purchasing controls and inventory management of
hazardous materials. This in turn results in less hazardous material becoming hazardous waste.
3.4.5 On-Site Recycling/Reuse of Hazardous Waste The regulatory requirements of
recycling hazardous waste onsite must be considered. Recycling decreases the volume of waste
that may be considered hazardous and it may exempt the waste from consideration under RCRA.
However, institution of onsite recycling activities involves many site-specific and waste-specific
factors including the type, rate, and frequency of waste generation; the concentration of
contaminants in the waste; and the value of the recycled material. There are also many off-site
factors that may affect the implementation of an onsite recycling program. Off-site factors
include: regulatory limitations; base location; markets for recycled materials; and waste
acceptance criteria by recycling facility (where recycled products are segregated on base and
shipped to off-base recycling facility).
Several recycling practices may be implemented at a base to reduce the volumes of hazardous
waste generated. These methods include:
• Establishing an internal clearinghouse for excess inventory, expired or near expired shelf life
hazardous materials, and recoverable wastes (through the Hazardous Material Pharmacy or
other means)
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• Identifying recoverable used materials
• Installing closed loop systems where hazardous wastes generated in a given process are
reused in that same process
3.4.6 Additional Resources. Each AF base is faced with the need to develop a list of specific
HW minimization techniques to achieve the HW disposal reduction goal. The first source is in-
house input from personnel including operations and maintenance workers, supervisors,
engineers, and others with first hand knowledge of the base operations. Other references that
document source reduction methods are listed below.
• PRO-ACT Environmental Information Clearinghouse (DSN 240-4214)
• "Commander's Guide to the Implementation of the Hazardous Materials Pharmacy", 1994
(available from PRO-ACT)
• Opportunity Assessments
• The "Pollution Prevention Technical Library", a database found in the DENIX environmental
information system (see Chapter 7 for DENIX information)
• EPA publications and databases ("Enviro$ense" - see Chapter 7)
• State and local environmental agency publications
• Published literature, journals, technical papers
• Consultants, equipment vendors and suppliers
• AF Waste Minimization Program Reports
• Other installations with existing waste minimization programs
• MAJCOM Crossfeeds
• Technology Transfer publications
Other references providing guidance and execution for the overall hazardous waste program are
listed below.
• API 32-7042, Solid and Hazardous Waste Compliance
• Base Hazardous Waste Management Plan
3.5 Municipal Solid Waste
3.5.1 Goals and Objectives. Solid waste reduction, pollution prevention and conservation of
natural resources are the goals of the Air Force Resource Recovery and Recycling Program
(RRRP).
Established goals for this program component call for reducing solid waste disposal 50% by
1997 based on a 1992 baseline. Interim objectives call for a 10% reduction by 1993 and a 30%
reduction by 1996. In keeping with the Air Force RRRP, the following objectives are outlined as
a means of accomplishing these goals:
• Minimize the amount of waste discarded in landfills
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• Increase the percentage of waste that is recycled
• Stimulate market demand for environmentally preferable products by increasing the type and
amount of products purchased
• Expand education to increase public awareness and support of recycling and composting
programs
• Maximize proceeds both now and in the future
• Comply with Federal, State and local mandates
3.5.2 Program. Elements of the RRRP include recycling, composting, and advocacy. Each
installation should select a RRRP Manager (or Qualified Recycling Program Manager) to
establish and run the recycling and composting programs, and to advocate for the resources
needed for a successful program. Supporting the RRRP Manager is a RRRP Subcommittee
which reports to the installation Environmental Protection Committee. At a minimum, the
following organizations should participate in the RRRP Subcommittee:
• Aircraft Maintenance
• Army and Air Force Exchange Service (AAFES)
• Comptroller
• Civil Engineering Operations
• Contracting
• Defense Commissary Agency (DeCA)
• Defense Reutilization and Marketing Office (DRMO)
• Environmental Management
• Legal
• Public Affairs
• Services
• Supply
• Vehicle Maintenance
Specific detailed guidance for implementing recycling and composting programs that will
successfully reduce the amount of solid waste generated on Air Force installations, and meet the
legal requirements of Federal, DoD, and Air Force can be found in the Air Force Resource
Recovery and Recycling Program (RRRP) Guide., dated May 95, available through PRO-ACT or
HQ AFCEE/EP.
3.5.3 Program Measurement. Measuring program effectiveness is an important part of the
overall process. The following three metrics, in combination, provide the best complete picture
of program operations.
• Solid Waste Disposal: This metric measures solid wastes disposed of in landfills and through
incineration (not waste-to-energy) in tons. The annual numbers are compared to previous
years and the baseline year (calendar year 1992 for the Air Force) to measure progress toward
meeting the Air Force reduction goals.
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• Solid Waste Generation: This metric measures the total waste generated on the installation in
tons. The total waste is the sum of the disposed amount and the recycled/reused amount
(sum of recycled, composted, and waste-to-energy amounts). This metric allows an
installation to determine the effect of their source reduction efforts, the first level in the
pollution prevention hierarchy.
• Recycling Percentage: This performance indicator measures recycled/reused amounts as a
percentage of total waste generation. The recycled/reused amount is divided by the total
waste generated. This indicator judges the effectiveness of the recycling efforts, the second
level of the pollution prevention hierarchy.
3.6 Affirmative Procurement
3.6.1 Goals. "Environmentally preferable" is a broad term for products or services having a
lesser or reduced effect on human health and the environment, when compared with competing
products or services serving the same purpose. Non-hazardous substitutes for products
containing ODS, EPA-17 and TRI chemicals would be considered environmentally preferable.
Another "environmentally preferable" approach is to buy products which are manufactured using
recycled and reclaimed materials. Affirmative Procurement is the program focusing specifically
on recycled-content product purchases.
One of the problems facing recycling is creating a market for products made from recycled
materials. Today, these products rival virgin products in quality and cost, yet their market
remains largely untapped. The stimulus of government procurement can help close the recycling
loop by encouraging market demand for recovered materials.
Air Force policy as expressed in API 32-7080 requires MAJCOMs to establish affirmative
procurement programs. The AF Pollution Prevention Strategy calls for emphasis on purchase of
recycled materials to the maximum extent practical; and for encouraging purchasing activities to
use environmental preference of vendors and products as selection criteria for awarding
contracts. More detailed implementation guidance will be presented in A Guide to Buying
Recycled: The Air Force Affirmative Procurement Program, still in development but anticipated
complete in Fall 1996. Contact PRO-ACT (see Chapter 7) to receive a copy when available.
The U.S. EPA designates specific "guideline items" that shall contain recycled materials for
Federal procurement. EPA's original list of guideline items included paper and paper products,
lubricating oil, retread tires, building insulation products, and cement and concrete containing fly
ash.
On 1 May 1995, EPA issued a Final Rule adding 21 new guideline items in six product
categories. The rule became effective on 1 May 1996. The new guideline items and their
product categories are listed in Appendix A, Table A-3. All EPA Guideline requirements
formerly found in 40 CFR 247-253 are now consolidated in 40 CFR 247.
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When purchasing items in any of these categories, installations are required to buy products
containing recycled materials unless a written determination is made that such items meet one of
the following exceptions:
• Are not available within a reasonable period of time
• Fail to meet the performance standards set forth in applicable specifications or fail to meet
reasonable performance standards of the procuring agency
• Are not available from a sufficient number of sources to maintain a satisfactory level of
competition (i.e., available from two or more sources)
• Are only available at an unreasonable price. If the cost of the recycled content product
exceeds comparable product costs by 10% or more, the cost is considered unreasonable.
The recommended recycled material content for each product is established in EPA's Guidelines.
Executive Order (EO) 12873 made these recommended content levels mandatory for Executive
agencies, including DoD, unless an exception is met. The Guide to Buying Recycledwill provide
more detailed information on content requirements.
The Pollution Prevention Strategy also calls for the Air Force to "promote the use of
environmentally friendly materials in the construction and maintenance of facilities", and to
"promote efficient material/energy use practices in the construction and maintenance of
facilities." Pollution prevention program managers should remember to consider the construction
and maintenance of facilities as potential processes for opportunity assessment, and work with
project designers to identify and specify building products containing recycled/recovered
material. Many such products are now available and Engineering Technical Letter (ETL) 94-7
requires their use in AF construction projects. HQ ACC has undertaken a demonstration project
in their FY 97 MTLCON program; the project is currently in design. Information from this and
other sources will be developed into a separate Guide for Environmentally Responsible Facilities,
due to be completed in December 1996.
3.6.2 Tracking and Reporting. Metric development for the Affirmative Procurement program
has been very difficult. Federal agencies are required to have procedures for monitoring and
annually reviewing the effectiveness of their affirmative procurement program by tracking
purchases and maintaining records of products containing recycled materials. The difficulty lies
in balancing the effort of data collection with the potential management benefits. A healthy
program will include metrics that yield useful information to help the program grow.
DoD policy requires reporting to the Federal Environmental Executive for large purchases (over
$100,000). Installations will not have to report on stock-listed purchases because these are
reported directly by GSA and DLA. Separate guidance on metrics and reporting will be issued at
a later date. Reporting is expected to be required on an annual basis.
Monitoring Guideline Item purchases (whether from GSA or local purchase) and sharing the
results through a cross-functional team or EPC subcommittee will enable the base to measure and
crossfeed its affirmative procurement successes. Even though GSA item purchases do not need
to be reported to headquarters, the base needs to gather enough information to complete its MAP
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and evaluate its overall success in meeting the goal of 100% recycled-content purchases for each
Guideline Item.
Typical Processes/Opportunities. Installations must establish an aggressive program to meet
Air Force goals for purchase of environmentally preferable products. A list of actions intended
to help installations establish an effective procurement program consistent with the goals is
included in Appendix B.
Many issues such as recycled products tracking, reviewing performance standards of recycled
products, and revising procurement procedures require a coordinated effort among personnel
outside the typical pollution prevention arena. Close coordination with procurement personnel is
essential to successful implementation. As a result, installations should consider establishing a
team through the Pollution Prevention Subcommittee or Working Group to address these unique
issues.
3.6.4 Product Sources. For help in locating products meeting EPA's requirements, refer to the
General Services Administration (GSA) Environmental Products Guide. All Guideline products
listed in this catalog have been researched and purchased to meet EPA's recycled content
recommendations. Contact the GSA Centralized Mailing List Service in Fort Worth, TX,
commercial (817) 334-5215 or DSN 739-7369.
Additional sources for recycled product information will be listed in the Guide to Buying
Recycled.
3.6.5 References
• Air Force Pollution Prevention Strategy., 24 July 1995
• A Guide to Buying Recycled: The Air Force Affirmative Procurement Program,
still in development (estimated completion Fall 1996)
• Resource Conservation and Recovery Act, Section 6002
• 40 CFR Part 247
• Engineering Technical Letter (ETL) 94-7, EPA Guideline Items in
Construction and Other Civil Engineering Specifications
• Comptroller General Decision No. B-238290
• Office of Federal Procurement Policy Ltr 92-4
• HQ USAF/CC and SAF letter, 25 Sep 92
• DASD (Production and Logistics) Memorandum, 3 Feb 93
• EO 12873, Federal Acquisition, Recycling, and Waste Prevention, 20 Oct 93.
3.7 Energy Conservation
3.7.1 Goals. The AF goal to reduce facility energy (natural gas, coal, electricity, fuel oil, etc.) is
10% by 1995, 20% by 2000, and 30% by 2005 on a BTU/sq ft basis, with 1985 consumption as
the baseline; and a 20% increase in industrial facilities energy use efficiency from a 1990
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baseline. It also requires the Air Force to identify and accomplish all energy conservation actions
which pay back in ten years or less, by the year 2005.
Data input by MAJCOMs and bases into the Defense Utility Energy Reporting System (DUERS)
is used to track progress toward the goals. These goals apply to the energy consumed within the
facility (computers, appliances, equipment, etc.) not just the energy used to operate the facility
(heating, air conditioning, lights, hot water, etc.) These goals mirror EO 12902, Energy
Efficiency and Water Conservation at Federal Facilities, and the Energy Policy Act of 1992
(EPACT), which extends the energy conservation goals of the Federal Energy Management
Improvement Act (FEMIA) of 1988. Reduced energy consumption equates directly to pollution
avoidance.
3.7.2 Background. Energy conservation reduces pollution through the reduction of greenhouse
gas emissions, protection of the stratospheric ozone, and prevention of acid precipitation. As
electricity is generated by burning fossil fuel or operating nuclear reactors, it produces emissions
of trace metals such as beryllium, cadmium, chromium, copper, manganese, mercury, nickel, and
silver. Reducing energy generation decreases boiler ash, and scrubber and spent nuclear waste.
It also lessens the need to mine and transport virgin fuels, and dispose of powerplant wastes.
3.7.3 Energy Program. Each base should have a designated Facility Energy Program Manager.
This person is typically located in the Maintenance Engineering Flight of the Base Civil Engineer
organization. The Air Force has provided information to help this person develop and manage an
Energy Conservation Program. The DoD Energy Management Handbook was provided to all
MAJCOMs and base Energy Managers. An Energy Management Training course has also been
offered to all base and MAJCOM Energy Managers. The Air Force Institute of Technology
(AFIT) is also offering an Energy Management course.
The Construction Criteria Base (CCB) is provided on CD-ROM disks, and is sent to each AF
installation every quarter. Current energy information including policy and guidance from OSD,
DOE and AF are on this system.
The Energy program should have two main thrusts - Energy Awareness and Energy Project
Investment. Energy Awareness simply means not using energy when it is not needed (i.e. turn
off lights/equipment when not needed; buy energy efficient equipment when buying new or
replacement products; don't leave windows and doors propped open when heating or cooling is
needed). This thrust should not cause discomfort or inconvenience to the occupants of the
facility, just use common sense on how and when energy is used. Be good stewards of energy
and use it like you were paying the bill.
Energy Project Investment is divided into three areas: government funds, utility company funds
and private sector funds. Two special DoD programs, Energy Conservation Investment Program
(ECIP) and Federal Energy Management Program (FEMP), have been provided by Congress to
fund energy projects. Also, utility companies are offering rebates for installing energy efficient
equipment and have Demand Side Management (DSM) programs to fund energy efficient
equipment installation on their customers' facilities. Within the private sector many companies
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offer Energy Savings Performance Contracting (ESPC), that pays for installation of energy
efficient equipment on a customer's facilities up front and they get paid out of the savings
realized by the customer. Congress has provided special legislation to encourage government
participation in these private sector programs.
3.7.4 Typical Opportunities. Conserving energy can be as easy as turning off a light or turning
down the heat. Examples of conservation measures (from simple to more technical in nature) are
included in Appendix B.
Lighting accounts for over 20 % of the total U.S. electricity consumption. Available technology
can reduce the electricity used for lighting by 50 to 70 percent. These efficient technologies also
provide excellent investment opportunities. A typical lighting upgrade yields an internal rate of
return of 20 to 30 percent, a payback of about 3 to 4 years. The U.S. EPA's Green Lights
Program and DOE's Federal Relighting Program encourage investment in energy-efficient
lighting. Information on energy efficient fixtures, lamps, and bulbs which are stock-listed is
available from the Defense Supply Center Richmond (DSCR), (800) DLA-BULB.
Office equipment and creature comfort are the fastest-growing electricity load. Computer
systems account for 5% of total commercial electricity consumption. The Energy Policy Act and
EO 12902 require the purchase of energy efficient equipment, such as EPA's Energy Star
computers. Computer energy efficiency is addressed in EO 12845.
3.7.5 References
• Energy Policy Act of 1992 (EPACT)
• EO 12902, Energy Efficiency and Water Conservation at Federal Facilities
• EO 12845, Requiring Agencies to Purchase Energy-Efficient Computer Equipment
• DoD Energy Management Handbook, new version anticipated Sept 96
• Defense Energy Program Procedural Memorandum (DEPPM) 94-1
• AFPD 23-3, Energy Management, Sept. 1993
• DoDI 4170.10, Energy Management Policy
• API 32-1023, Design and Construction Standards and Execution of Facility Construction
Projects
3.8 Water Conservation
3.8.1 Goals. The Air Force Pollution Prevention Strategy does not include a numeric goal for
water conservation. Instead, it requires Air Force installations to identify and accomplish all
water conservation actions which pay back in ten years or less. This is to be accomplished by
2005. Energy and water conservation are both mandated by Executive Order 12902 and the
Energy Policy Act. The Defense Energy Program Procedural Memorandum (DEPPM) 94-1
incorporates water conservation into the Energy program. Air Force Energy Program Procedural
Memorandum (AFEPPM) 96-2 addresses the Air Force Water Management Program.
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3.8.2 Background. Water conservation is related to energy conservation and pollution
prevention in two ways. First, approximately 80% of the cost of water production (on a
nationwide basis) results from the energy required to provide water. Second, reductions in water
use will create corresponding reductions in wastewater treatment - which in turn reduces energy
requirements, chemical usage, and the potential for environmental compliance issues associated
with effluent discharge.
3.8.3 Execution. Water conservation should be executed as part of the Energy program.
Specific requirements and responsibilities are detailed in AFEPPM 96-2. Efforts are focused on
three main areas:
• Performing Prioritization Surveys: In 1995, computer models were run to determine the
order in which Air Force bases should receive their comprehensive energy and water
conservation audits. MAJCOMs will be required to accomplish audits on 10% of their bases
each year.
• Performing Comprehensive Facility Audits: The main purpose of an audit is to detect
inefficient water systems, determine how much water and money is lost through leakage or
waste, and determine a feasible method to implement conservation recommendations.
Installations are encouraged to seek out suppliers that will provide free audits. GSA will
provide a list of all utilities that offer no-cost water conservation audits and demand-side
management services and incentives. AF facility managers can contact GSA at (202) 501-
1763. Audits can be accomplished through Energy Savings Performance Contracting
(ESPC) and Demand Side Management (DSM). The DoD Energy Manager's Handbook and
the FEMP handbook Financing Federal Energy Efficiency Projects are both in the process of
being updated to include water conservation.
• Promoting Effective Project Management: The success of a water conservation plan depends
largely on personnel commitment. Before a conservation program is implemented, notify
facility occupants of the program and new procedures. Consider posting notices near water
equipment with information about correct usage; setting up a hotline for questions or leak
reporting; distributing flyers with program information; or setting up a system to recognize
exceptional efforts by individuals.
Including water conservation projects in the installation PP MAP along with the energy
conservation projects will provide visibility for these projects, help ensure their funding, and
provide a mechanism to track their implementation. Projects should be prioritized according to
their cost-effectiveness. Economic evaluation of water projects will include the direct cost of
water; the cost of heating hot water saved; O&M costs of wells, pumps, treatment facilities, etc.;
reduced wastewater disposal costs; O&M savings realized by process changes, new equipment,
etc.; and the availability of grant money for the project. Funding to execute water conservation
projects comes from the same sources used to fund Energy projects (see Section 3.7.3).
3.8.4 Typical Opportunities. Typically, water conservation projects with the most economical
paybacks include the following:
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• Plumbing retrofit (shower heads, toilets, etc.)
• Leak detection and repair
• Xeriscaping, wastewater reuse, and other cost-effective landscaping techniques
• Modifications to cooling towers, boilers and process equipment
• Projects funded in whole or in part with grant money
3.8.5 References
• Energy Policy Act (EPACT) of 1992
• Executive Order 12902, Energy Efficiency and Water Conservation at Federal Facilities
• Air Force Pollution Prevention Strategy, 24 July 1995
• AFEPPM 96-2, Air Force Water Management Program
• GSA list of utilities offering no-cost audits (call 202-501-1763)
• American Water Works Association (AWWA) "M36" manual, a reference for audit
implementation (call DOE Pacific Northwest Laboratory at 509-372-4368 or AWWA at 303-
794-7711)
• Enviro-Management & Research, Inc. (EMR) document, Water Management: A
Comprehensive Approach for Facility Managers (call 703-875-2800)
• Rocky Mountain Institute's Water-Efficient Technologies manual for evaluating appropriate
uses of water-efficient equipment (call 303-927-3851)
• Installation Water Resources Analysis and Planning System (IWRAPS) computer software;
models the winter and summer water requirements for military installations, prepares water
sustainability plans, compares water reduction measures for implemented programs, and
assesses cost effectiveness. Contact HQ AFCESA/CESC at DSN 523-6338
• Passive Solar Handbook, HQ AFCESA
• DoD Energy Manager's Handbook, currently being revised to include water conservation
information
• FEMP handbook, Financing Federal Energy Efficiency Projects, currently being revised to
include water conservation information
3.9 EPCRA and the Toxic Release Inventory (TRI)
3.9.1 Background. On 3 August 1993, President Clinton signed Executive Order 12856
requiring all Federal agencies to comply with the Emergency Planning and Community Right-
To-Know Act (EPCRA) and to commit Federal agency planning, management, and acquisition
resources to fulfill the intentions of the Pollution Prevention Act. Among its provisions, this act
requires industry to notify state and local emergency planning entities of the presence and
quantities of hazardous materials at their facilities and to notify Federal, state, and local
authorities of inventories and releases of those substances. The EPCRA is a stand alone
amendment to the Superfund Amendments and Reauthorization Act (SARA).
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Section 313 of EPCRA is of significant importance to Air Force installations. This section
requires Federal facilities to submit annual U.S. EPA Toxic Release Inventory (TRI) reports by 1
July each year for the previous calendar year's data. The first report covered calendar year 1994,
the baseline year. Progress toward the Air Force goal of 50% reduction in TRI chemical releases
will be measured against the 1994 baseline.
The EO is not applicable to Federal agency facilities outside the customs territory of the United
States. The EO applies to GOCOs, whether or not they are within Standard Industrial
Classification (SIC) codes 20-39. However, the EO cannot create new legal obligations for
private parties, although overall agency reports shall take into account such activities. Future
contract revisions will require GOCOs to provide their agencies with the information necessary
for TRI reporting.
3.9.2 Reporting. EPCRA is composed of 5 basic parts: Emergency Notification and Planning
(Sections 301 to 303), Emergency Release Notification (Section 304), Community Right-to-
Know or List of Material Safety Data Sheets (Section 311), Annual Chemical Inventory (Section
312) and Annual Toxic Chemical Release (Section 313). Sections 301 through 312 are intended
to provide neighboring communities with all the information they need about hazardous
chemicals on the Federal facility for proper emergency response and planning. Section 313
requires the only report that is submitted to the EPA.
EPCRA Sections 301 to 303 require Federal facilities to notify Local Emergency Planning
Committees (LEPCs) and State Emergency Response Commissions (SERCs) of any extremely
hazardous substances (EHSs) produced, used or stored on-site in amounts above the threshold
planning quantities (TPQs). Basically, this is to assist LEPCs in developing emergency response
plans.
EPCRA Section 304 requires Federal facilities to immediately notify SERCs and LEPCs of any
release (above the reportable quantity - RQ) of an EHS or CERCLA section 102(a) hazardous
substance. Immediate notification is by a phone call, followed by written details of the release.
The intent is to notify surrounding communities of any potential hazards.
EPCRA Section 311 requires Federal facilities to provide copies of all Material Safety Data
Sheets (MSDSs), or a list of MSDSs, to the SERCs, LEPCs and fire departments with
jurisdiction over the facility. (If the facility has its own fire department, then providing the
MSDSs to community fire departments is not necessary, but could be considered part of good
community relations.) The MSDSs are for all "hazardous chemicals" over a certain threshold:
any chemical considered as physical or health hazards under OSHA hazard communication
standards. This Section of EPCRA does not have a definitive list of chemicals, but this
definition is very broad. Updated lists, or MSDSs, are required within 3 months of new materials
exceeding thresholds or if new MSDS information is received from the manufacturer. The first
Federal facility reports were due in Aug 94, but can - and should - be continually updated.
EPCRA Section 312 requires a formal Tier I or Tier II report to be submitted to the LEPCs,
SERCs and fire departments with jurisdiction for the same chemicals covered in Section 311.
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This report contains all the local and state agencies need to know about the amounts, locations
and storage conditions of hazardous chemicals and mixtures present at the Federal facility during
the reporting period. This report is due on 1 Mar, to cover the chemicals present on-site during
the previous year. Like Section 311, certain exemptions apply to reduce the burden of reporting.
The EPCRA Section 313 report provides a nationwide view of total annual releases to the
environment, and off-site transfers, of certain toxic chemicals. The TRI report or Form R was
initially intended to inform the public and government officials of routine releases to the
environment of toxic chemicals. With passage of the Pollution Prevention Act of 1990, the Form
R was expanded to include pollution prevention and waste minimization progress as well.
Completion of a Form R will require detailed transaction records, utilization and release data.
The chemicals eligible for inclusion in the 1994 reports are those listed on the TRI List (40 CFR
372.65 - only 313 chemicals) current as of 1 Dec 93. For 1995 and beyond, an additional 286
chemicals are reportable. This list is subject to change; the latest information can be obtained
from PRO-ACT (see Chapter 7).
Air Force Guidance for TRI reporting was released on 10 Apr 95. This guidance is intended to
implement EO 12856/EPCRA Section 313 AF-wide with consistency in interpretation. A
significant number of exemptions are available under EPCRA, but the intent is to provide
baseline data indicating pollution prevention success. All TRI reports must be the best-effort of
each facility and must be defensible.
The chemical monitoring required under EO 12856 tracks substance use (as calculated above
threshold quantities) throughout all departments at a facility (including what is vented,
evaporated, and spilled). This provides a "blueprint" of the aggregate chemical handling at the
site. For EPCRA 313, all Federal facilities exceeding toxic chemical thresholds for:
manufacture or import - 25,000 Ibs/yr; process - 25,000 Ibs/yr; otherwise use - 10,000 Ibs/yr;
must report on the Form R, as amended by the Pollution Prevention Act. Reporting applies even
if facilities do not fall within SIC codes 20-39.
Most AF installations will not break the thresholds required to submit a Form R to EPA.
However, the process of inventorying toxic chemicals, hazardous substances and extremely
hazardous substances is very important to maintain safe and economical operations at each base.
Form R data is published annually by the EPA in the Annual Toxics Release Inventory Public
Data Release. Totals of releases are given by state, facility and chemical. This public knowledge
can help or hinder the installation mission, depending on how well the installation has worked
with local communities prior to the annual publication release.
3.9.3 Goals. The EO mandates agencies set voluntary goals to achieve a 50% reduction in total
releases and off-site transfers of TRI toxic chemicals by 1999, based on a calendar year 1994 TRI
baseline. In addition, the EO directs each agency to establish voluntary goals for the reduction in
use of toxic chemicals at facilities and in products purchased or manufactured by Federal
agencies. Each facility is expected to identify its own reduction goals and prepare a written plan
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outlining how it will contribute to the 50% DoD-wide reduction goal. The PP MAP meets this
requirement.
3.9.4 Tracking. The Hazardous Materials Pharmacy and the AF-EMIS tracking system provide
excellent sources of information for compiling the installation TRI report (see Sections 2.3.5 and
2.3.6 respectively).
3.9.5 References.
• Executive Order 12856, Federal Compliance with Right-to-Know Laws and Pollution
Prevention Requirements
• 40CFR372.65, Toxic Release Inventory list
• Air Force Guidance for TRI Reporting, 10 Apr 95
3.10 Pesticide Management
3.10.1 Goals and Measures of Merit. DoD Instruction 4150.7 dated 22 Apr 96,
DoD Pest Management Program., establishes three goals and metrics for DoD pest management
operations. The DUSD(ES) Measures of Merit include:
• Measure of Merit 1, Installation Pest Management Plan: By the end of FY 97, 100% of all
DoD installations will have pest management plans prepared, reviewed, and updated annually
by pest management professionals. DoDI 4150.7 specifies requirements for installation pest
management plans.
• Measure of Merit 2, Annual Amount of Pesticide Applied: By the end of FY 2000, the
amount of pesticide applied annually on DoD installations will be reduced by 50% from the
FY 93 baseline in pounds of active ingredient. This requirement is reflected as an Air Force
pollution prevention goal in the Pollution Prevention Strategy.
• Measure of Merit 3, Installation Pesticide Applicator Certification: By the end of FY 98,
100% of all DoD installation pesticide applicators will be properly certified within two years
of employment. Also, all contractor employees performing pest management work on DoD
installations shall be certified under an EPA or State Plan accepted in the state in which the
work is conducted.
3.10.2 Integrated Pest Management (IPM). IPM is an approach to pest control that utilizes
regular monitoring to determine if and when treatments are needed, and employs physical,
mechanical, cultural, biological, and educational tactics to keep pest numbers low enough to
prevent intolerable damage or annoyance. Least-toxic chemical controls are used as a last resort.
Treatments are not made according to a predetermined schedule, but rather are chosen and timed
to be the most effective and least disruptive to natural pest controls. Program execution includes
seven steps that are routine procedures for each pest problem:
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1. Identify pest;
2. Develop plan/strategy;
3. Establish action thresholds;
4. Monitor pest population;
5. Control pest (optional);
6. Document results;
7. Evaluate/redesign plan.
In contrast to the past practice of widespread pesticide application, IPM focuses on trapping,
sanitation and exclusion for rodent control; exclusion for bird control; and
good fertilizer, mowing, aeration practices and use of native plants for weed control.
Least-toxic pesticides are to be used only when these measures are inadequate.
3.10.3 References.
• DoD Instruction (DoDI) 4150.7, 22 Apr 96.
• HQ AFCESA/CC letter, 15 May 95, subject: Integrated Pest Management Pollution
Prevention Initiative (with attachments providing a sample IPM Plan outline and explaining
IPM implementation strategy)
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CHAPTER 4
TEAM BUILDING AND IMPLEMENTATION
4.1 Introduction
Assembling and organizing installation resources is a critical aspect of building a successful
pollution prevention program. The following sections provide guidance for developing and
maintaining your pollution prevention team, including information on key organizational
responsibilities, training, and recognition programs.
4.2 The Pollution Prevention Team
Effective pollution prevention program implementation at AF installations requires a coordinated
and focused effort on the part of all AF personnel involved in the generation or handling of solid
wastes and hazardous materials/wastes. While pollution prevention is everyone's responsibility,
key players and organizations must plan, organize, initiate, and evaluate pollution prevention
actions at each base. Well run programs are led by an active Environmental Protection
Committee (EPC) with a strong Pollution Prevention Subcommittee.
TABLE 4-1
RESPONSIBILITIES OF THE POLLUTION PREVENTION SUBCOMMITTEE
Recommend overall installation program goals (supplement to AF goals)
Implement hazardous material identification and tracking system
Recommend/implement a waste tracking system
Prioritize the waste streams, processes, or facility areas for assessment
Select pollution prevention and opportunity assessment teams
Provide training for assessment teams
Establish criteria for selecting options for implementation
Conduct (or supervise) assessments
Conduct (or monitor) technical/economic feasibility analyses of favorable options
Select options for implementation
Consolidate "Program" data for MAP (Project Narrative, Cost, ROI, Benefit, OPRs)
Consolidate "Execution" data for MAP (Implementation steps, Schedule, OPRs)
Advocate funding
Monitor (and/or direct) implementation progress
Monitor performance of new options, once operational
Monitor overall progress toward achieving installation pollution prevention goals and
objectives
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4.2.1 Pollution Prevention Subcommittee (Working Group). The Pollution Prevention
Subcommittee of the EPC typically proposes policy and recommends action to the EPC. This
group may undertake some of the actions normally executed by the Assessment Team, outlined
below, but in most cases will direct and review the Assessment Team's activity. Subcommittee
membership should include those groups or departments that have significant operational or
administrative interest in development of the program. Typical functions represented on the
subcommittee include civil engineering, maintenance, supply, bioenvironmental engineering,
operational contracting, public affairs, and legal. Table 4-1 summarizes the responsibilities of
the Pollution Prevention Subcommittee.
TABLE 4-2
RESPONSIBILITIES OF THE POLLUTION PREVENTION TEAMS
Recommend implementation of policy
Ensure accurate baseline calculations
Identify pollution prevention goal requirements
Generate recommended solutions
Classify options generated by assessments
Select options for implementation
Establish "Program" data for MAP (Project Narrative, Cost, ROI, Benefit, OPR) for
each requirement
Establish "Execution" data for MAP (Identify Implementation Steps, Schedule, OPRs)
for each requirement
Identify funding mechanisms
Document (and/or direct) implementation progress
Document performance of new options, once operational
Document overall performance toward achieving the program area's pollution
prevention goals and objectives
4.2.2 Pollution Prevention Teams. Pollution Prevention Teams are typically components of
the Pollution Prevention Subcommittee which focus on achieving a specific goal, such as the
hazardous waste reduction or affirmative procurement goal. Teams should be made up of five to
seven shop chiefs and mid-level managers normally representing the CE/SG/LG communities.
Team responsibilities are outlined in Table 4-2. They report to the Pollution Prevention
Subcommittee on progress, initiatives, problems encountered, and other requirements. This step
is crucial to the program's success as the overall working group cannot efficiently discuss, track
and implement initiatives to meet all of the Air Force pollution prevention goals. Subcommittee
personnel should stress the need for base personnel to be constantly looking for opportunities to
reduce waste in their areas of expertise.
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4.3 Training
As with most environmental programs, training must be conducted routinely. Every individual at
an installation requires some level of environmental awareness and pollution prevention training
on a frequency needed to maintain proficiency. Information on training and funding of training
can be obtained by contacting the education office personnel. The following are recommended
courses and materials for base personnel.
4.3.1 AF Institute of Technology (AFIT) ENV 220, Pollution Prevention Course. This five
day in-residence course provides an introduction to pollution prevention for key personnel
involved in program management. The course focuses on management and roles and
responsibilities. Attendees are typically program managers from the CE/SG/LG communities.
AFIT funds attendance at courses through course allocations to MAJCOMs.
4.3.2 TJSAF School of Aerospace Medicine Pollution Prevention Technologies Course. This
five day in-residence course provides an introduction to pollution prevention for key personnel
involved in program management. It places more emphasis on computer aided instruction and
software resources than the AFIT course. Attendees are typically program managers and team
members from the CE/SG/LG communities. Attendance at the USAFSAM course is funded
through course allocations to MAJCOMs.
4.3.3 AFCEE Opportunity Assessment Training Workshops. The Air Force Center for
Environmental Excellence conducts three-day opportunity assessment training courses at Air
Force installations throughout the world. These workshops are designed for installation shop
personnel and are typically attended by mid-level and senior NCOs, LG/SG/CE program
managers, and installation leadership, such as EPC members. The course includes actual shop
assessments done by the trainees. Workshops are typically funded through MAJCOMs with
installations paying individual TDY costs. Individual installations have also funded the full
course in order to provide training to base personnel.
4.3.4 Other Training Opportunities. Additional environmental training is available through a
variety of sources:
• AFIT offers courses in Environmental Compliance Assessment and Management Program
(ECAMP), Installation Restoration Program (IRP), AF/EPA Team Approach to
Environmental Cleanup, Introduction to Environmental Management, Environmental
Management Applications, Environmental Contracting, and Hazardous Waste Management.
Call the Environmental Education Center at DSN 785-0381/2.
• EPA training opportunities for Federal personnel are listed on the Enviro$en$e electronic
information system; see Chapter 7 for Enviro$en$e information.
• The Army offers a broad range of courses which AF employees may attend. Contact the
Army's Center for Environmental Initiatives and Hands-On Training (CEIHOT), Fort Sill
OK, at DSN 639-2111 or (405) 442-2111.
• MAJCOMs provide many training courses via contractors. See Chapter 7 for a list of
MAJCOM P2 contacts.
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• The DENIX environmental electronic information system contains a listing of training
resources, in addition to information on pollution prevention and all other aspects of
environmental management; see Chapter 7 for DENIX information.
• Training videos are available from city, state and Federal agencies on many topics.
4.4 Recognition of Personnel
Good daily operating practices include paying attention to the human resources that are involved
in program management and program execution. This includes recognizing individual and
command achievements by implementing a recognition or reward program. On a monthly and an
annual basis, awards may be given for ideas or suggestions that result in pollution prevention
successes. Publicizing these awards by including them in the base paper will increase awareness.
Contact your installation awards point of contact to establish program criteria.
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CHAPTER 5
PROGRAMMING AND BUDGETING
5.1 Overview
Now that the MAP is developed and actions have been identified to meet the base's pollution
prevention (P2) goals, it is critical to ensure all requirements are included in the base and
MAJCOM program and budget. Installation level personnel initiate the programming and
budgeting process for these requirements, and support them during reviews by higher
headquarters. This chapter describes the process and criteria for programming and budgeting for
P2 requirements.
5.1.1 Appropriations. Several different Congressional appropriations may be used to fund P2
needs, depending on the type of requirement and the activity being supported. These
appropriations include Military Construction (3300); Operations and Maintenance (O&M)
(3400); Research, Development, Test & Evaluation (RDT&E) (3600), Aircraft Procurement
(3010), Weapons Procurement (3020), Other Procurement (3080), AF Reserve O&M (3740), and
Air National Guard O&M (3840). Military Construction funds are used for new construction
projects over $300,000; for example, a Hazardous Materials Pharmacy. O&M funds are used for
many of the smaller projects and operational activities. See your resource advisor for details.
5.1.2 Program Element Code (PEC). Within the appropriations, funds are further broken
down into different program elements which identify the mission areas being supported. PECs
are five digit numbers representing specific missions and activity groups. The first three
numbers vary, but for P2 the PEC will always end with "54F", where the letter F represents the
Air Force. For example: PEC 11854F describes Air Force P2 projects for Operating Forces in
the Air Operations activity group. All funding requirements must be identified in the appropriate
PEC. Refer to AFI 32-7001, Environmental Budgeting; API 32-7080, Pollution Prevention
Program; and your resource advisor for further information.
5.1.3 Pollution Prevention Requirements. Because P2 requirements span all functional areas
in the Air Force, it is the responsibility of each functional area to identify pollution prevention
opportunities. However, each functional area does not program and budget separately for
pollution prevention funding. The installation environmental management function (CEV or
EM) typically takes the lead in consolidating P2 requirements, and works with programmers and
resource advisors (usually in CE) to develop the P2 program and budget. The P2 requirements
identified in the installation programs are consolidated at the MAJCOM level and included in the
MAJCOM budget submittal to Air Staff.
Remember, it all begins at installation level. Only a program which covers all requirements and
is thoroughly documented and justified, will result in the installation getting the funds it needs to
meet its P2 goals.
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5.2 Pollution Prevention Program Budget and Priorities
Pollution prevention projects are divided into annually recurring (Operations and Services) and
non-recurring (Level I, II, or III) requirements. The MAP needs to identify all requirements
necessary to support the installation's P2 program and meet AF goals. The plan should include
the program funding requirements for each year (see Appendix C, Sample MAP, Tables 2-2
through 2-8). All requirements for pollution prevention funding must be entered into the Work
Information Management System - Environmental Subsystem (WIMS-ES) A-106 module in
order to be eligible for funding. Projects not entered into the A-106 module, validated by the
MAJCOM, and released to the Air Staff can not be supported during budget exercises. See
Sections 5.5 and 5.6 for further discussion.
5.2.1 Recurring Requirements - Operations and Services (O&S). Annual recurring "must
do" projects associated with "keeping the gates open" include manpower (only authorized
positions on the unit manning document [UMD] coded against a PP PEC); periodic updates of
plans; opportunity assessments; baseline survey updates, recurring operating costs associated
with composting and municipal solid waste recycling programs, training; and travel.
5.2.2 Non-recurring Requirements. Non-recurring requirements are categorized into three
funding levels as follows:
• Level I - ODS and Legal Requirements: This category includes projects required to reduce or
eliminate the use of ODS and projects to comply with a current state, Federal or local law or
meet an Executive Order or AF mandate.
• Level II - Meet Future Goals/Policies and Legal Requirements: Includes items required to
meet goals, policies, and legal requirements at a date beyond the program fiscal year. These
projects represent situations in which existing operations, programs, and facilities meet
current standards, but require action to meet future legal requirements and P2 goals,
objectives, and sub-objectives. Items essential to meeting a goal become Level I in the fiscal
year prior to the fiscal year for goal attainment. For example, essential efforts to meet a 1999
reduction goal become Level I in fiscal year (FY) 98. Efforts not essential to goal attainment
fall into the Level III category.
• Level III - Beyond Goals and Legal Requirements: Level III projects augment the base's P2
activities, but go beyond AF goals and legal requirements. Current AF policy is not to fund
or program for Level III requirements.
5.3 Pollution Prevention Program Exclusions
When determining whether or not an item is eligible for P2 funding, evaluate how the project
specifically supports AF goals. While a project may contribute to reduced "pollution," if it is not
essential for meeting an AF goal, eliminating/reducing the use of ODS, or meeting a legal
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requirement, it cannot be supported as a valid P2 requirement. API 32-7080 describes
requirements which are not eligible for pollution prevention funds.
5.4 Eligible Projects
Installations must evaluate each potential pollution prevention requirement when determining the
project's eligibility for P2 funding. For example, installing a jet washer to replace a solvent
cleaning process as a hazardous waste minimization project toward meeting the hazardous waste
minimization goal would only be a valid Level II project if essential to AF goal attainment. If
installing the jet washer reduces hazardous waste disposal beyond the goal, it would be a Level
III item.
When evaluating items for funding, give priority to the items with low initial costs, high dollar
savings, and significant P2 contributions. Items with a high cost but minimal contribution to the
program should only be supported if absolutely essential to program accomplishment or goal
attainment. While there is no set list of items that will "automatically be funded," following are
some examples of projects that previously have been supported. Installations must still evaluate
each item to determine its validity and category (O&S, Level I, Level II, or Level III) for funding.
• Operating/Managing the PP Program: TDY, travel, training, manpower (only for
authorized positions on the Unit Manning Document). Only reasonable amounts for these
items, based on installation size and number of P2 personnel, will be supported.
• Pollution Prevention Plans and Opportunity Assessments: Initial accomplishment and
updates. Periodic reviews and updates to these plans should be accomplished "in-house"
unless there have been significant changes that warrant the cost to accomplish this work via
contract.
• Recycling Programs to Reduce Municipal Solid Waste: Facilities, supplies, equipment,
contracts. P2 funding should only be used to the extent necessary to cover any shortfall
between program revenues and expenses. Revenues from these programs must first be used
to cover actual or anticipated program expenses before declaring a "profit" and using the
revenues for other approved purposes.
• Composting Programs: Facilities, supplies, equipment, contracts. When evaluating
projects for these programs, pay particular attention to the cost of the project and the
associated reduction in solid waste disposal.
• Jet Washers, Aqueous Parts Washers, Ultrasonic Cleaners, and Alternative Media
Blasting Systems to Replace Solvent Processes: Initial purchase only, not operating,
maintenance/repair, or replacement costs.
• Solvent Recycling/Filtration Units: Initial purchase only, not operating, maintenance and
repair, or replacement costs. Valid only if a viable source reduction alternative is not
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available. Recurring expenses associated with a solvent recycling contract are not eligible for
P2 funding. The P2 program funds efforts to move higher on the pollution prevention
hierarchy, but not to just transfer the waste stream from the installation to a contractor.
• Antifreeze Recyclers: Equipment initial purchase only, not operating, maintenance and
repair, or replacement costs.
• Refrigerant Recycling/Recovery/Reclamation Units: Initial purchase only, not operating,
maintenance and repair, or replacement costs.
• Reviewing/Revising Standardization Documents (Mil Specs/Standards, Technical
Orders, etc.) to eliminate/reduce the use of hazardous materials: For specific weapon
systems, P2 only funds the document review; the Single Manager for the weapon system is
responsible for revising the documents.
• Hazardous Material Pharmacy Startup Costs: Only the initial costs (equipment, facilities,
etc.) to establish the hazardous material pharmacy are valid for P2 funding. Recurring
operating costs for the pharmacy are not valid for P2 funding.
• Alternative Fueled Vehicle (AFV) Conversions and Infrastructure: Initial purchase only,
not operating, maintenance/repair, or replacement costs. Projects to convert petroleum fueled
vehicles to operate on an alternative fuel and infrastructure to support AFVs (for example
compressed natural gas fueling stations) are only valid for P2 funding if the special
DOE/DoD funding for these efforts is insufficient to meet the Energy Policy Act (EPACT)
and Executive Order requirements as determined by the LG community.
• Oil Filter and Fluorescent Bulb Crushers To Reduce Hazardous Waste Disposal: Initial
purchase only; recurring contract efforts to accomplish these actions are not valid for P2
funding.
• Polychlorinated Biphenyl (PCB) Elimination: Removal and replacement of PCB
equipment not otherwise eligible for real property maintenance or environmental compliance
funds, in accordance with HQ USAF/CEV s PCB Elimination Technical Guidance, dated 27
Feb 1996.
5.5 Validating the P2 Program Submittal
All line items included in the installation P2 budget are validated by MAJCOM/CEVs, who must
submit a line item listing to HQ US AF/CEV to support all funding submittals. HQ US AF/CEV
in turn selects a percentage of these items to review for data accuracy. Items on the list, but not
in the A-106 will not be supported. Information contained in the A-106 is used for validation.
Therefore, it is very important for the A-106 record to be complete, especially the narrative, and
contain information such as the quantified contribution to the P2 program and payback period, in
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order for the reviewer to have sufficient information to determine item validity with policy and
law.
5.6 WIMS-ES
The WIMS-ES A-106 module is a computerized management information system for
programming, budgeting and tracking environmental projects (see API 32-7002, Environmental
Information Management System). It is a subsystem of Civil Engineering's WIMS computer
system. WIMS-ES allows daily transfer of data between bases, MAJCOMs, and Air Staff, and is
intended to be updated on a continuous basis. Each environmental funding requirement, whether
part of compliance, conservation, or pollution prevention, must have a record in the A-106
module. No new pollution prevention requirements can be submitted to HQ USAF/CEV during
budget exercises unless entered into the A-106 module, validated by the MAJCOM, and released
to the Air Staff. Before an environmental project can be funded, it must be submitted and
validated through the A-106 process.
When entering the project into the A-106, use the correct PEC and Element of Expense
Investment Code (EEIC) and sub-shred for the project. Also, ensure the narrative entered for the
project is complete and sufficiently detailed to provide anyone reviewing the project with enough
information to determine the project's contribution to the pollution prevention program as well as
the validity of the project.
A-106 records will reflect the current status of each project or requirement. When HQ USAF
processes an A-106 report, a copy of the record is placed in the History File. As the project
status changes, the A-106 record must be updated. Every item must eventually be updated to
show a progress code of "complete" or "discontinued."
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CHAPTER 6
TECHNOLOGY NEEDS
6.1 Overview
The Air Force (AF) uses the AFMC Technology Master Process (TMP) to assist with research,
development and acquisition (RD&A) planning. The TMP identifies and documents needs for
technologies that guide (or will guide) RD&A by AF laboratories. This program also ensures
that RD&A programs address only validated technology needs. Technical Planning Integrated
Product Teams (TPIPTs) are a key part of the TMP. These teams are comprised of users, system
program directorates, product and group managers, development planners, laboratory
technologists/planners, system engineers, test engineers and logisticians. A TPIPT examines
users' mission needs; prepares roadmaps for solutions at a systems level; divides, using system
methodology, those solutions into appropriate steps; and identifies the needed technologies for
the projected steps or solutions. TPIPTs aid in planning and developing technical solutions for
users' long- and short-term operational needs.
The Environment, Safety and Occupational Health (ESOH) planning process and TPIPT was
implemented because of the AF's commitment to minimize the environmental impacts of current
operations on community and global environments, while providing Air Force personnel with a
safe and healthy workplace. The Human Systems Center Directorate of Plans, Requirements and
Engineering (HSC/XR) function has been designated as the lead in the ESOH planning process
and TPIPT as outlined in API 63-118. This process produces two major documents: the AF
Technology Needs Survey and the ESOH RD&A Strategic Plan.
6.2 Technology Needs Survey (TNS)
The TNS process was created to facilitate ESOH RD&A to solve the AF's highest priority ESOH
needs. The TNS documents needs from multiple user communities to include:
• Users responsible for AF infrastructure;
• Users from MAJCOMs that develop and manage weapon systems;
• MAJCOMs that use these weapon systems and;
• Agencies responsible for collecting ESOH needs
The ESOH Planning Process produces a validated and prioritized list of technology needs.
Needs identified are ranked based on established criteria: mission impairment, pervasiveness,
environmental hazard severity, human hazard severity, regulatory risk, cost of not fixing the
problem, and AF goals and political sensitivity. The latest results are published in FY96 USAF
ESOH Needs Survey, dated December 1995. This report included 366 ESOH needs of which
135 were related to pollution prevention. 37 of the pollution prevention needs, over 10 percent
of the total ESOH needs identified, were identified as high priority needs.
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The FY97 needs collection process will start in the summer of 1996. This survey will also be
collecting requirements for the Air Force Material Command Hazardous Material Reduction
Prioritization Process (FIMRPP), a new initiative to improve weapon system pollution
prevention. This initiative ties the identification of hazardous material use for existing weapon
systems to issues such as the Environmental Protection Agency Toxic Releases Inventory
reporting process, ESOH installation concerns and installation pollution prevention management
plans. It will re-emphasize the important connection between the single manager and the
installation where weapon systems are used.
6.3 Technology Assessment
In the ESOH Planning process needs identified are analyzed through the Technology Assessment
(TA) Process. This process identifies the technologies available to satisfy those needs and
presents both the most feasible methods for implementing the solutions and the risks associated
with the solutions. The TA Process includes three parts: (1) the Requirements Analysis (RA);
the Technology Evaluation (TE) and the Systems Implementation Review (SIR). The RA and
TE help find the most effective technology solution.
The RA provides the preliminary information that can be used to select one of the following
options: (1) to pursue commercial off-the-shelf (COTS) technologies, if appropriate and readily
available; (2) to pursue RD activities that can lead to potential solutions for the technology needs;
(3) to maintain the status quo and the ongoing course of action; or (4) to formulate policy or
administrative changes. The TE provides more detailed information regarding the solution, and
is performed only if the cognizant MAJCOM decides to pursue an option outlined in the RA and
desires assistance in doing so. The SIR is conducted to evaluate the utility of the technology
solution(s) actually implemented. The TA process also aids in the development of the Strategic
Plan.
6.4 ESOH RD&A Strategic Plan
The Strategic Plan links the ESOH needs identified (or requirements) to programs and/or
solutions. This plan consists of four volumes. Volume I summaries the ESOH planning process,
and presents an overview of the ESOH technology needs and the programs by AF laboratories
that address them. The other volumes provide the detailed information about laboratory programs
in support of the Cleanup, Compliance and Pollution Prevention Pillars. The plan advocates the
customer's position, the need identifier, to influence the principal investigator, laboratory
directors, and science and technology managers to satisfy specific requirements.
6.5 Base Level Responsibilities
Environmental, safety, public health and logistics managers can play a key role in the
identification of technology needs. They should work with the users of ODS and hazardous
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materials (maintenance, logistics, civil engineering, etc.) to identify opportunities where new or
existing technologies could help reduce their dependence on these materials.
Other bases or MAJCOMs may have already identified your problem to HSC/XRE or PRO-ACT.
There may be an off-the-shelf solution, or an emerging lab technology that may meet your needs.
You can call HSC/XRE at DSN 240-2129/3455 or commercial (210) 536-2129/3455, (email:
whitfield@emgate.brooks.af.mil). See Chapter 7 for PRO-ACT contact information.
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CHAPTER 7
SUPPORTING ORGANIZATIONS
There are numerous sources of information that can be helpful to installation personnel in
conducting pollution prevention activities. Table 7-1 lists supporting organizations which can be
utilized as a source for answers to a wide range of environmental questions.
TABLE 7-1
SUPPORTING ORGANIZATIONS
ORGANIZATION
PRO-ACT (AF Environmental
Information Clearinghouse)
Defense Envr. Network & Information
exchange (DENIX)
(DoD Environmental Bulletin Board and
Web page - includes PRO-ACT products,
P2 Technical Library and other resources)
AF POL Technical Assistance Team
HQ AFCESA Library
Energy Program (Technical Advisors)
Water Program (Technical Advisors)
Integrated Pest Management
(Technical Advisors)
Wright-Patterson AFB "Tech Connect"
Management and Equipment Evaluation
Program (MEEP), Vehicle Maint & CE
Fuels Laboratory
Navy CFC/Halon Information
Clearinghouse (CHIC)
DOT Military Traffic Management
(Hazardous Material Transportation)
TELEPHONE NUMBER
DSN 240-42 14
(210) 536-4214 or (800) 233-4356
Web Page:
http://www.afcee.brooks.af.mil/PRO-ACT
BBS Access: call (217) 373-6790 to
request a password
Web Page:
http://denix.cecer.army.mil/denix/denix.html
(request passwords using on-line form)
DSN 945-4617
DSN 523-6285
DSN 523-6361
DSN 523-6338
DSN 523-6465
DSN 785-5940
DSN 872-42 17
DSN 576-505 1/5457
(703)769-1883
DSN 761-6951
(703)756-6951
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TABLE 7-1 (continued)
SUPPORTING ORGANIZATIONS
ORGANIZATION
GSA National Customer Service Center
Defense General Supply Center (DGSC)
Envr. Preferred Products Catalog
EPA Publications
Enviro$en$e (EPA Bulletin Board and
Web page - includes former PIES and
FFLEX systems)
EPCRA/S ARA Hotline
TSCA Hotline
RCRA/Superfund Hotline
Asbestos Hotline
Lead Hotline
Pesticides Hotline
Stormwater Hotline
Stratospheric Ozone Protection Hotline
Air Hotline
Radon Hotline
OSHA
NRC Spill Report
Emission Measurement Technical Center
Acid Rain Hotline
Pollution Prevention Information
Clearinghouse (PPIC)
Solid Waste Information Clearinghouse
Wetlands
TELEPHONE NUMBER
DSN 465-1416 or (800) 488-3 1 1 1
Web Page: http://www.gsa.com
(800) 352-2852
(202)260-7751
BBS Modem: (703)908-2092
Web Page: http://es.inel.gov/index.html [^j
(800) 535-0202
(202) 554-1404
(800) 424-9346
(800) 368-5888
(800) 532-3394
(800) 858-7378
(202) 260-7786
(800)296-1996
(919) 541-0800
(800) 767-7236
(800) 321-6742
(800) 424-8802
(919)541-1060
(202) 233-9620
(202)260-1023
(800) 677-9424
(800) 832-7828
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TABLE 7-1 (continued)
SUPPORTING ORGANIZATIONS
HQUSAF/CEVQ (P2 Policy)
HQ AFMOA/SGPA
HQ USAF/LGMM
HQ AFCEE/EP (P2 implementation
resources; contract support, workshops,
Pharmacy, EMIS, DENIX data management)
DSN 225-2797/2550
DSN 297-1731 ext. 360
DSN 225-0844
DSN 240-3371
Web Page:
http://www.afcee.brooks.af.mil
MAJCOM Pollution Prevention Offices
HQ ACC CES/ESC
HQ AETC/CEVP
HQ AFMC/CEVV
HQ AFPxES/CEVV
HQ AFSPC/CEVV
HQ AMC/CEVC
ANGRC/CEVC
HQ PACAF/CEV
HQ USAFA/CEVV
HQ USAFE/CEV
DSN 574-4430 /Fax DSN
DSN 487-3422 /Fax DSN
DSN 787-7414 /Fax DSN
DSN 497- 1073 /Fax DSN
DSN 692-5028 /Fax DSN
DSN 576-8332 /Fax DSN
DSN 278-8 197 /Fax DSN
DSN 449-6536 /Fax DSN
DSN 259-2289 /Fax DSN
DSN 480-63 82 /Fax DSN
574-5339
487-3597
787-5875
497-0108
692-3533
576-8376
278-8151
449-0427
259-3753
480-7306
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Appendix A
Glossary
and
Reference Tables
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APPENDIX A
GLOSSARY OF TERMS
Affirmative Procurement - The purchase of environmentally preferable products, required of
Federal agencies by RCRA Section 6002 and EO 12783. Affirmative procurement programs
must establish preference for products containing recycled material, must include a promotion
plan to place emphasis on buying recycled, and must have procedures for obtaining and verifying
estimates and certifications of recycled content.
Alternatives - Ways of reducing adverse effects of hazardous materials. Alternatives, as applied
to hazardous material decision-making, include, but are not limited to, such possibilities as
substituting less hazardous or nonhazardous material; redesigning a component such that
hazardous material is not needed in its manufacture, use, or maintenance; modifying processes or
procedures; restricting users; consumptive use; on-demand supply; direct ordering; extending
shelf life; regenerating spent material; downgrading and reuse of spent material; use of waste as
raw material in other manufacturing and combinations of those factors.
Baseline - Quantified starting points from which progress is measured. Baselines are quantities
of material purchased or generated over a specified period of time.
CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act
Closed-loop Recycling - Utilization of byproducts from a production process in the original
process, without significant alteration or reprocessing. There are three key requirements: The
byproduct must be returned to the process without first being reclaimed (i.e. distilled, dewatered,
or treated); the production process to which the byproduct is returned must be a primary
production process (a process that uses raw materials as the majority of its feedstock); and the
byproduct must be returned as feedstock to an operation within the original process from which it
was generated.
Compost - A mixture of garbage and degradable trash with soil in which certain bacteria in the
soil break down the garbage and trash into organic fertilizer.
Composting - A waste management option involving the controlled biological decomposition of
organic material in the presence of air to form a humus-like material. Controlled methods of
composting include mechanical mixing and aerating, ventilating the materials by dropping them
through a vertical series of aerated chambers, or placing the compost in piles out in the open air
and mixing it or turning it periodically.
EPA-17 Targeted Chemicals - Seventeen chemicals (or compounds) selected for reduction or
elimination based on their volume of use, toxicity, persistence, and mobility. Also known as
EPA Industrial Toxic Pollutant (ITP) chemicals.
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EPCRA - Emergency Planning and Community Right-to-Know Act
Fluorocarbons (FCs) - Any of a number of organic compounds analogous to hydrocarbons in
which one or more hydrogen atoms are replaced by fluorine. Once used in the US as a propellant
in aerosols, they are now primarily used in coolants and some industrial processes. FCs
containing chlorine are called chlorofluorocarbons (CFCs). They are believed to be modifying
the ozone layer in the stratosphere, thereby allowing more harmful radiation to reach the Earth's
surface.
Functional Areas - The operations or areas of responsibility that affect or are affected by the use
of hazardous material. These areas include, but are not limited to, budget and fiscal planning,
legal support, research and development, weapons systems acquisition and maintenance, material
and performance specifications and standards, design handbooks, and technical manuals;
maintenance and repair procedures, industrial processes, procurement policy, contracting
provisions, new material identification, public works operations, construction, management of
munitions, chemical agents, propellants, medical and other personnel support, safety and
occupational health, transportation, and logistics analysis; supply; warehousing; distribution;
recycling; disposal; spill prevention, control, and cleanup; contaminated site remediation;
staffing, education, and training; information exchange; public affairs; general administration;
and oversight.
Hal on - Bromine-containing compounds with long atmospheric lifetimes whose breakdown in
the stratosphere cause depletion of ozone. Halons are used in fire-fighting.
Hazardous Material Pharmacy - Single point of control for hazardous material.
Hazardous Material - Any material that poses a threat to human health and/or the environment
typically due to their toxic, corrosive, ignitable, explosive, or chemically reactive nature.
Hazardous Substance - 1. Any material that poses a threat to human health and/or the
environment. Typical hazardous substances are toxic, corrosive, ignitable, explosive, or
chemically reactive. 2. Any substance named by U.S. EPA to be reported if a designated
quantity of the substance is spilled in the waters of the US or if otherwise emitted into the
environment.
Hazardous Waste - By-products of society that can pose a substantial or potential hazard to
human health or the environment when improperly managed. Possesses at least one of four
characteristics (ignitability, corrosivity, reactivity, or toxicity), or are listed in 40 CFR 261.30 or
applicable state or local waste management regulations.
Industrial Solid Waste - Includes wastewater treatment sludges, solids from air pollution control
devices, trim or scrap materials that are not recycled, fuel combustion residues (such as the ash
generated by burning wood or coal), and mineral extraction residues.
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Life Cycle Economic Analysis - An evaluation of the cost associated with the use of hazardous
material and potential alternatives over the life of the investment or hazardous material. The
analysis is not a specific, step-by-step procedure that can be applied by rote to all cases. Analysis
shall be guided by basic principles of economics and informed judgment.
Management Action Plan - Within the AF, a single reference to manage the actions needed to
develop and execute an installation's pollution prevention program.
Metrics - Measurement used to measure progress.
Municipal Solid Waste (MSW) - Wastes generated by administrative and domestic activities.
Includes wastes such as durable goods, nondurable goods, containers and packaging, food
wastes, yard wastes, and miscellaneous inorganic wastes from residential, commercial,
institutional, and industrial sources. MSW does not include wastes from other sources, such as
municipal sludges, combustion ash, and industrial nonhazardous process wastes that might also
be disposed of in municipal waste landfills or incinerators.
Open-loop Recycling - A recycling system in which a product made from one type of material is
recycled into a different type of product. The product receiving recycled material itself may or
may not be recycled.
Opportunity Assessment - Systematic procedures to identify and assess ways to prevent pollution
by reducing or eliminating wastes.
OSHA - Occupational Health and Safety Administration
Ozone (Os) - Found in two layers of the atmosphere, the stratosphere and the troposphere. In the
stratosphere (the atmospheric layer beginning 7 to 10 miles above the earth's surface), ozone is a
form of oxygen found naturally which provides a protective layer shielding the earth from
ultraviolet radiation's harmful effects on humans and the environment. In the troposphere (the
layer extending up 7 to 10 miles from the earth's surface), ozone is a chemical oxidant and major
component of photochemical smog. Ozone can seriously affect the human respiratory system
and is one of the most prevalent and widespread of all the criteria pollutants for which the Clean
Air Act required EPA to set standards. Ozone in the troposphere is produced through complex
chemical reactions of nitrogen oxides, which are among the primary pollutants emitted by
combustion sources; hydrocarbons, released into the atmosphere through the combustion,
handling and processing of petroleum products; and sunlight.
Ozone Depletion - Destruction of the stratospheric ozone layer which shields the earth from
ultraviolet radiation harmful to biological life. This destruction of ozone is caused by the
breakdown of certain chlorine-, fluorine-, and/or bromine-containing compounds
(chlorofluorocarbons or halons) which break down when they reach the stratosphere and
catalytically destroy ozone molecules.
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Ozone Depleting Substances (OPS) and Ozone Depleting Chemicals (ODCs) - CFCs, halons,
and other substances that deplete the stratospheric ozone layer as classified by the Clean Air Act
of 1990.
Pollution/Pollutants - Refer to all nonproduct outputs, irrespective of any recycling or treatment
that may prevent or mitigate releases to the environment.
Pollution Prevention Hierarchy - The Pollution Prevention Act of 1990 established a hierarchy as
national policy. The hierarchy follows this order: (1) prevent or reduce pollution at the source
wherever feasible; (2) recycle, in an environmentally acceptable manner, pollution that cannot
feasibly be prevented; (3) treat pollution that cannot feasibly be prevented or recycled; and (4)
dispose of, or otherwise release into the environment, pollution only as a last resort.
PRO-ACT - An environmental information clearinghouse provided by the Pollution Prevention
Directorate, HQ AFCEE. They are available to AF customers who can ask an unlimited number
of environmental questions and receive up to 40 free hours of PRO-ACT research time per
question. They can be reached at DSN 240-4214 or 1-800-233-4356.
Program Element Code (PEC) - Funding designation required for budgeting and programming
AF projects. For Pollution Prevention the PEC is ***54 (see Chapter 5).
RCRA - Resource Conservation and Recovery Act
Recycle/Reuse - The process of minimizing the generation of waste by recovering usable
products that might otherwise become waste. Examples are the recycling of aluminum cans,
waste paper, POLs, engine coolants, and ODS.
Recycled Content - The amount of recovered material, either pre- or postconsumer, in a finished
product that was derived from materials diverted from the waste management system. Usually
expressed as a percent by weight.
Refuse Reclamation - Conversion of solid waste into useful products, e.g., composting organic
waste to make soil conditioners or separating aluminum and other metals for melting and
recycling.
Return on Investment (ROD - An attempt to quantify financial costs and benefits and determine a
project's payback period.
SARA - Superfund Amendments and Reauthorization Act.
Source Reduction - As defined in the Federal Pollution Prevention Act, source reduction is "any
practice which 1) reduces the amount of any hazardous substance, pollutant, or contaminant
entering any waste stream or otherwise released into the environment (including fugitive
emissions) prior to recycling, treatment, and disposal; and 2) reduces the hazards to public health
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and the environment associated with the release of such substances, pollutants, or contaminants.
The term includes equipment or technology modifications, process or procedure modifications,
reformulation or redesign of products, substitution of raw materials, and improvements in
housekeeping, maintenance, training, or inventory control." Source reduction does not entail any
form of waste management (e.g. recycling and treatment). The Act excludes from the definition
of source reduction "any practice which alters the physical, chemical, or biological characteristics
or volume of a hazardous substance, pollutant, or contaminant through a process or activity
which itself is not integral to and necessary for the production of a product or the providing of a
service."
Toxic Chemical - Those chemicals listed in 40 CFR 372.65, also known as the Toxic Release
Inventory (TRI) List. The list changes periodically as updates are published in the Federal
Register.
Toxic Chemical Use Substitution - This term describes replacing toxic chemicals with less
harmful chemicals, although relative toxicities may not be fully known. Examples would include
substituting a toxic solvent in an industrial process with a chemical having lower toxicity, or
reformulating a product so as to decrease the use of toxic raw materials or the generation of toxic
byproducts.
This also includes attempts to reduce or eliminate the use of chemicals associated with
health or environmental risks. Examples include the phaseout of lead in gasoline, the phaseout
of the use of asbestos, and efforts to eliminate emissions of chlorofluorocarbons and halons.
Some of these attempts may involve substitution of less hazardous chemicals for comparable
uses, while others involve the elimination of a particular process or product from the market
without direct substitution.
Toxic Use Reduction - This term refers to the activities grouped under "source reduction," where
the intent is to reduce, avoid, or eliminate the use of toxics in processes and/or products so as to
reduce overall risks to the health or workers, consumers, and the environment without shifting
risks between workers, consumers, or parts of the environment.
Treatment - Involves end-of-pipe destruction or detoxification of wastes from various
separation/concentration processes into harmless or less toxic substances.
Waste Minimization - Source reduction and the following types of recycling:
(1) beneficial use/reuse, and (2) reclamation. Waste minimization does not include recycling
activities whose uses constitute disposal and burning for energy recovery.
WIMS-ES - Work Information Management System-Environmental Subsystem. A subsystem of
Civil Engineering's WIMS computer management information system for programming and
budgeting environmental projects. Allows daily transfer of data between bases, MAJCOMs, and
Air Staff.
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TABLE A-l
OZONE LAYER DEPLETING CHEMICALS
Halocarbon
Number
CFC-11
CFC-12
CFC-113
CFC-114
CFC-115
Halon 1202
Halon 1211
Halon 1301
Halon 2402
CFC-13
CFC-111
CFC-112
CFC-211
CFC-212
CFC-213
CFC-214
CFC-215
CFC-216
CFC-217
Carbon
Tetrachloride
Methyl
Chloroform
Methyl
Bromide
Halocarbon #
HCFC-21
HCFC-22
HCFC-31
HCFC-121
HCFC-122
HCFC-123
HCFC-124
HCFC-131
HCFC-132
HCFC-133
HCFC-141
Chemical Name
CLASS I ODS
Trichlorofluoromethane
Dichlorodifluoromethane
Trichlorotrifluoroethane
Dichlorotetrafluoroethane
Chloropentafluoroethane
Dibromodifluoromethane
Bromochlorodifluoromethane
Bromotrifluoromethane
Dibromotetrafluoroethane
Chlorotrifluoromethane
Pentachlorofluoroethane
Tetrachlorodifluoroethane
Heptachlorofluoropropane
Hexachlorodifluoropropane
Pentachlorotrifluoropropane
Tetrachlorotetrafluoropropane
Trichloropentafluoropropane
Dichlorohexafluoropropane
Chloroheptafluoropropane
Tetrachloroethane
Trichloroethane (all isomers)
Bromomethane
CLASS II ODS
Dichlorofluoromethane
Chlorodifluoromethane
Chlorofluoromethane
Tetrachlorofluoroethane
Trichlorodifluoroethane
Dichlorotrifluoroethane
Chlorotetrafluoroethane
Trichlorofluoroethane
Dichlorodifluoroethane
Chlorotrifluoroethane
Dichlorofluoroethane
Primary
Uses
1,2,3,4,5
1,2,4
2,3,4
1,2,3,4,6
6
3
3,7
1,3,5
1,3
6,7
0
4
0
0
0
0
0
0
0
1,4,5,8
4,5,8
4,5,8
Uses
1,4
1,4,5
0
0
0
1,3
1,3
0
0
0
2
CAS Number
75-69-4
75-71-8
76-13-1
76-14-2
76-15-3
75-61-6
421-01-2
75-63-8
124-73-2
75-72-9
954-56-3
76-12-0
422-78-6
3182-26-1
2354-06-5
29255-31-0
4259-43-2
661-97-2
422-86-6
56-23-5
71-55-6
74-83-9
CAS Number
15-43-4, DR39289-28-6
75-45-6, DR73666-77-0
593-70-4
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
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HCFC-142
HCFC-221
HCFC-222
HCFC-223
HCFC-224
HCFC-225
HCFC-226
HCFC-231
HCFC-232
HCFC-233
HCFC-234
HCFC-235
HCFC-241
HCFC-242
HCFC-243
HCFC-244
HCFC-251
HCFC-252
HCFC-253
HCFC-261
HCFC-262
HCFC-271
Chlorodifluoroethane
Hexachlorofluoropropane
Pentachlorofluoropropane
Tetrachlorotrifluoropropane
Trichlorotetrafluoropropane
Dichloropentafluoropropane
Chlorohexafluoropropane
Pentachlorofluoropropane
Tetrachlorodifluoropropane
Trichlorotrifluoropropane
Dichlorotetrafluoropropane
Chloropentafluoropropane
Tetrachlorofluoropropane
Trichlorodifluoropropane
Dichlorotrifluoropropane
Chlorotetrafluoropropane
Trichlorofluoropropane
Dichlorodifluoropropane
Chlorotrifluoropropane
Dichlorofluoropropane
Chlorodifluoropropane
Chlorofluoropropane
1,4,5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
See Note 3 below
Notes on CAS Numbers:
1. DR in a number indicates a deleted registry number that was replaced with another registry number.
2. Some chemicals have multiple CAS numbers because registry numbers were assigned on premise that it was a
trade name, although the chemical may be the same as another one already listed.
3. Multiple forms of this chemical exist, all with different CAS numbers. A complete listing is available from PRO-
ACT (see Chapter 7for contact information).
The eight use categories are as follows:
1 Refrigeration: Air Conditioning
2 Blowing Agent for Plastics
3 Fire Extinguishing Agent
4 Solvent: Dry Cleaning Agent; Degreaser
5 Intermediate for Synthesis of Other Compounds
6 Dielectric Gas
7 Aerospace Chemical
8 Fumigant: Pesticide
0 An "0" in the use column indicates the compound has no practical use.
These compounds are not manufactured deliberately for any application.
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TABLE A-2
THE EPA-17 TARGET CHEMICAL LIST AND TYPICAL USES
ORGANICS
Benzene
Toluene
Xylene (includes ortho,
meta-, and para-)
Carbon Tetrachloride
Chloroform
Dichloromethane
(methyl ene chloride)
1,1,1 Trichloroethane
(1,1,1-TCA)
Trichloroethylene (TCE)
Perchloroethylene (PERK)
Methyl Ethyl Ketone
(MEK)
Methyl Isobutyl Ketone
(MIBK)
INORGANICS
Cadmium and Compounds
Chromium and Compounds
Cyanides
Lead and Compounds
Mercury and Compounds
Nickel and Compounds
TYPICAL USES
Fuels, solvents, inks, paint thinner,
component in plastics and tires
Solvent in paints and coatings,
fuels, cleaning agents, plastics
Solvent in paints and coatings,
cleaning agents, fuels
Bearing cleaning and PMEL
Cleaning agents in Bearing shop,
present in fluorocarbons
Wipe down cleaner, paint stripper,
foam blowing
Parts cleaning, degreasing
Degreasing, paints
Degreasing, dry cleaning
Paints, cleaning agents adhesives,
inks, gun cleaning, thinners
Paints, cleaning agents
TYPICAL USES
Plating operations, batteries,
pigments, chemical cleaning
Plating and paint preparation
Plating solutions
Batteries, paint, sealing compounds,
lead solders
Laboratories, mercury vapor lamps,
thermostats
Plating operations, batteries,
welding
CAS # (for pure
substance, not compounds)
71-43-2
108-88-3
varies
56-23-5
67-66-3
75-09-2
71-55-6
79-01-6
127-18-4
78-93-3
108-10-1
CAS # (for pure
substance, not compounds)
7440-43-9 (Pure Cd)
7440-47-3 (Pure Cr)
varies
7439-92-1 (PurePb)
7439-97-6 (Pure Hg)
7440-02-0 (Pure Ni)
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TABLE A-3
AFFIRMATIVE PROCUREMENT GUIDELINE ITEMS
Category
Vehicular Products
Construction Products
Transportation Products
Park and Recreation Products
Landscaping Products
Non-Paper Office Products
Products
Reclaimed engine coolants
Structural fiberboard
Laminated paperboard
Cement/concrete containing ground
granulated blast furnace slag
Carpet
Floor tiles
Patio blocks
Traffic barricades
Traffic cones
Playground surfaces
Running tracks
Hydraulic mulch
Yard trimmings compost
Office recycling containers
Office waste receptacles
Plastic desktop accessories
Remanufactured toner cartridges
Binders
Plastic trash bags
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Appendix B
Opportunity Assessments:
OA Process,
Data Collection Worksheets
and
Typical Opportunities
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APPENDIX B
PERFORMING OPPORTUNITY ASSESSMENTS
What is an Opportunity Assessment?
Identification of pollution prevention options is often called an "opportunity assessment" (OA).
This is a systematic approach to studying the selected process. The shop is visited and personnel
are interviewed. A process flow diagram (flowchart) is developed; material inputs and waste
outputs are listed for each step; and a brainstorming session identifies opportunities for reduction
in material use or waste generation . The information needed to evaluate the opportunities -
quantities of materials used and wastes generated, costs for materials and waste disposal,
environmental or health problems associated with the process, and mission constraints such as
MILSPECs or Technical Orders - is gathered during the opportunity assessment.
Opportunity assessments may be accomplished by trained base level personnel, contractors, or a
MAJCOM team. Many MAJCOMs decide to build their initial programs with contractor
support, but train their personnel to take over the process in the future. Base personnel working
in cross-functional teams can potentially generate the best options because of their familiarity
with the processes. Examples of worksheets to aid in conducting OAs are also ncluded in this
Appendix.
A completed OA includes:
• a description of the process (including Pharmacy or TRI process codes, if available); its
purpose; and constraints such as MILSPECs or Technical Orders
• a description of the pollution prevention opportunity
• current quantities of materials used and wastes generated
• the amount of expected reduction in wastes generated or hazardous materials used
• cost information including purchase or disposal costs for each substance; costs of special
process equipment; permit application fees; personal protective equipment costs; or costs for
training directly attributable to the material
• anticipated benefits and problems (financial, environmental, health, mission, etc.)
• the opportunity's total cost to implement, and
• the return on investment (ROI) or payback period, in years.
Use the following fundamental sources of information when quantifying chemical usage and
waste generation:
• purchase data from supply sources and contracting
• shop interviews (spend time to draw out information, otherwise the interviewee will not
realize what information he actually knows or remembers that will help you)
• inventory data from the Hazardous Materials Pharmacy or HazMart
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• Bioenvironmental Engineering annual shop surveys and inventories (AF Form 2761)
• any prior installation reports (Toxic Release Inventory, EC AMP, waste minimization studies)
• waste disposal data from hazardous waste manifests and reports as well as disposal
contracting information.
Sample Data and Calculations
The following example provides a hypothetical process description and example of the
calculations required to support an OA.
Process Description
Process ID: LGMA 14
Title: Wheel Stripping
Program Component(s): EPA-17 (methylene chloride), Hazardous Waste
Organization: LGMA Tire Shop
Purpose: Remove paint from aircraft wheels prior to non-destructive inspection
(NDI) as required by Tech Order XX-XX.
Description: Receive wheel, remove tire, soak in 30-gallon solvent vat of
methylene chloride for 2 hours, remove paint with air knife, rinse with water,
wipe with rags, send to NDI for penetrant application and inspection.
Input units and Origin: Painted wheels, removed directly from aircraft
Output units and Destination: Unpainted wheels; NDI shop.
Production Rate: 160 wheels/year
Wastes generated: Dirty methylene chloride, paint, wastewater, air emissions
Background data: Solvent requires changeout after 15 wheels
Solvent becomes hazardous waste (HW)
Rinse water goes down the drain, may be hazardous waste,
but has never been tested
Four pounds of paint are removed per wheel
Dirty rags are sent out for cleaning and returned for reuse
Solvent/paint mixture costs $2 per pound to dispose as HW
Replacement solvent purchase cost is $1 per gallon
Pollution Prevention Opportunities
1. Change process so paint is stripped using bead blasting or other alternate process
2. Contract for solvent recycling instead of disposing as hazardous waste
3. Buy a solvent distillation unit and recycle the solvent in-house
4. Purify (distill or filter) and reuse the rinse water
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5. Cover the solvent tank to minimize air emissions
6. Investigate alternate coatings on aircraft wheels to remove or delay the requirement for the
paint stripping process
7. Investigate NDI requirement for inspection (frequency, method, etc.)
Evaluation of Opportunities
1. An alternate stripping process would eliminate solvent purchase and disposal costs, reduce
worker exposure, reduce the base's EPA-17 usage, and reduce hazardous waste disposal.
However, Technical Order XX-XX requires paint stripping using methylene chloride.
Submit AFTO Form 22 for the tech order change, but in the meantime, continue using the
approved process.
2. Solvent recycling would not reduce EPA-17 usage or worker exposure, but would eliminate
material purchase costs and hazardous waste disposal costs. The base could take credit for a
reduction in hazardous waste. A local solvent recycling company with a good environmental
reputation is available. They charge $3.50 per gallon to recycle the waste and return clean
solvent to the base. The shop would have to purchase a tank and initial solvent supply from
the recycling company for $450.
3. There is a huge backlog of work orders in CE, not enough room in the shop for a solvent still,
and no manpower to run the still. This alternative may be cost effective but mission
constraints make it infeasible at present. Document this option and revisit it in the future.
4. Water recycling is feasible. Equipment is available through GSA and would not be difficult
to operate. Water conservation would be achieved and a potential hazardous waste disposal
violation would be avoided.
5. The new solvent tank provided by the recycling company has a cover. Keeping the tank
covered when not in use will minimize air emissions and avoid potential compliance
problems.
6. Alternate coatings will require extensive research and development and are beyond the
installation's ability to execute. Consider identifying this as a technology need.
7. Cracks seem to be detectable with ultrasonics; NDI penetrant inspection may be overkill.
The wheels may be inspected too often; if cracks are seldom found, consider increasing the
time between inspections. Work through the Item Manager Engineers to review the process
and submit AFTO 22 if changes are feasible.
Option 2 is the first opportunity selected for further evaluation. Calculate the costs and benefits
of this alternative as follows:
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(Quantity of hazardous material used)(Conversion factor-gal to lbs)/(# of wheels per vat)
= Ibs hazardous material used/wheel
(30 gal solvent/vat)(5.5 lbs/gal)/(15 wheels/vat) = (11 Ibs of methylene chloride/wheel);
(Ibs hazardous material/wheel) + (Ibs hazardous waste removed from wheel) = Total amount of
hazardous waste generated/wheel
(11 Ibs solvent/wheel) + (4 Ibs paint/wheel) = (15 Ibs of hazardous waste/wheel)
Gallons of solvent used/year =
[(# of wheels per year)/(# of wheels per changeout)] x (# of gal/changeout)
Gallons of solvent/year =160 wheels/year x 30 gal/changeout = 320 gal/year
15 wheel s/changeout
Annual HW disposal cost = (15 Ib HW/wheel) x (160 wheels/year) x $2/lb = $4800/year
Annual solvent replacement cost = 320 gal/year x $l/gal = $320/year
Calculate the Return on Investment (ROI):
Payback (yr) = (Project Cost)
[(Annual Savings)-(Annual Cost)]
1) Project Cost = Initial cost of new tank with solvent
2) Annual Savings ($/yr) = HW disposal cost + Replacement solvent cost
3) Annual Cost ($/yr) = Cost to recycle solvent = 320 gal/year x $3.50/gal = $1,120
Payback = $450 = 0.11 years
($4800+ $320)-($1,120)
This option would be selected for implementation and documented in the MAP:
• The hazardous waste reduction (number of pounds per year) would be added to the
hazardous waste reduction the base expects from other selected options, and the total would
be shown in the Program Summary Sheet, Chapter 2 of the MAP.
• The cost, benefit, and ROI would be listed along with other selected options in the table for
Hazardous Waste Disposal in Chapter 2 of the MAP. Action offices would be assigned to
award the contract and train the shop workers on the new procedures and these OPRs would
also be listed in the table.
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• Required actions, OPRs and estimated completion dates would be shown in the Hazardous
Waste Disposal section of Chapter 3 of the MAP.
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WORKSHEET 1
SITE DESCRIPTION
List the operations at this shop/building:
What are the major products?:
Provide a rough estimate of production volume per month (e.g., the number of circuit boards
produced):
What are the major waste streams? What media do they affect? How much waste is
generated in each?
Has the shop/building already implemented any waste reduction or recycling techniques? If
yes, describe the technique results to date.
How many people work in this shop/building? How many hours is it operational?
The following sources contain information that may help you determine the type and amount
of waste generated at your shop:
• Work Flow Diagram
• Hazardous Waste Manifests
• Emission Inventories
• Annual/Biennial Reports
• Permit/Permit Applications
• Material Safety Data Sheets
• Chemical Materials Inventory
• Permitting Details/Conditions
• Environmental Audit Reports
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WORKSHEET 2
WASTE STREAM ASSESSMENT FORM
Questions
Waste Stream #/
Process Unit
Brief Description
of how waste is
generated
Waste Stream Name
(A) air emission
(WW) waste water
(SW) solid waste
(HW) haz waste
Occurrence
(R) regularly
(NR) non-recurrent
Monthly generation
rate
Treatment/Disposal
method
(R) recycled
(L) landfill
(S) sewage treatment
plant
(I) incinerator
(O) other
Disposal Cost
Waste #1
Waste #2
Waste #3
Waste #4
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WORKSHEET 3
MANAGEMENT PRACTICES
Questions
GENERAL
Does the shop have written procedures for shop inspection/ maintenance?
Does the shop show signs of poor housekeeping (cluttered walkways, uncovered
drums, etc.)?
Does the aisle space appear adequate for equipment, bulky items?
Is the drum storage area covered (e.g., all containers are protected from the weather)?
Are all drums raised off the ground (e.g., on pallets)?
Does the shop have equipment to prevent releases caused by over-filling of storage
tanks (e.g., high level shutdown/alarms, secondary containment)?
Are there noticeable spills, leaking containers, or leaking valves, pumps, hose fittings
Are containers labeled as to their contents and hazards?
Is there smoke, dust or fumes indicating material losses?
Does the shop have a training program for raw materials handling, spill prevention,
proper storage techniques and waste handling procedures?
If this is a training facility, are students trained to be environmentally aware?
INVENTORY CONTROL
Does the shop have a single point of contact for ordering and distributing new
supplies?
Does the shop have written procedures regarding inventory control?
Is inventory used in first-in, first-out order?
Do you dispose of products due to expired shelf-life?
Are empty containers returned to the supplier, or re-used on-site?
Does the shop buy products in bulk?
Estimate the volume of chemicals maintained on-site:
If figures are unavailable, provide qualitative assessment:
Low, Medium, High (Low = one supply cabinet/ Medium = 1 to
3-55 gallon drums/ High = stock room with more than 50 products
with > 5-55 gallon drums)
Check the inventory quickly - are there any toxic substances?
(E.G., benzene, methyl ethyl ketone, methylene chloride,
tetrachloroethylene, toluene, trichloroethylene, xylene - these might
be present in degreasers, adhesives, epoxies)
Y
N
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Appendix
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WORKSHEET 4
OPPORTUNITY ASSESSMENT
Opportunity Title:
Describe the Opportunity:
Waste Stream(s) Affected:
Input Material(s) Affected:
Product(s) Affected:
Indicate Type of Opportunity : (the opportunity may be a combination of source reduction,
recycling, and treatment)
Source Reduction
Equipment Change
Personnel/Procedure Change
Material Change
Recycling/Reuse
Onsite
Offsite
Treatment/Disposal
After source reduction and/or recycling have been implemented, residual wastes may still require
treatment and disposal (e.g., still bottoms or spent filters from an on-site solvent recycler).
Treatment required
Biological
Incineration
pH adjustment
Precipitation
Solidification
Other
Disposal
Landfill
Surface Impoundment
Deep Well
Other
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Feasibility Assessment
Explain why the opportunity appears to be technically feasible:
Estimate the one-time cost to implement the opportunity, taking into account equipment costs,
labor, etc.
Estimate the annual recurring costs to implement the opportunity, taking into account materials,
manpower, utilities, etc.
Estimate how much money implementation will save the facility annually.
Would the opportunity be difficult to implement? Y N
Staff training required Y N
Staff/management resistance expected Y N
Cost to implement is high Y N
Labor is required to install and maintain new equipment Y N
Other factors (please add) Y N
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Typical Opportunities for EPA-17 Reduction
Physical Removal of Paint: The substitution of chemical stripper with media blasting or other
physical methods of paint removal such as sanding with vacuum capabilities. This opportunity
for pollution prevention can be applied to the following EPA-17 chemicals: benzene; toluene;
xylene; dichloromethane; methyl ethyl ketone (MEK); and methyl isobutyl ketone (MIBK). The
evaluation of this opportunity must take into account the occupational safety and health
implications of process changes. Physical methods of paint removal have the potential to
generate hazardous emissions of paint constituents such as lead, hexavalent chromium, and
cadmium.
Recycling: Although the Air Force's EPA-17 reduction goals exempt jet fuels, recycling of other
petroleum products and plastics helps reduce the purchase of materials containing benzene and
toluene. For benzene the recycling of tires is also applicable, in two ways. Using retread tires
saves production of new tires from benzene-containing petroleum products, and burning old tires
for energy saves the use of fuel oils which contain benzene.
Parts Washers: The use of parts washers with an aqueous base soap and water rather than solvent
as replacement for degreasers. This opportunity can be applied to: toluene; xylenes; carbon
tetrachloride; chloroform; dichloromethane; trichlorethane (TCA); trichloroethylene (TCE);
perchloroethylene ("PERK"); MEK; and MIBK. Hot water and citric-based compounds can also
be used as a substitute for MEK and MIBK degreasers.
Product Substitution: There are many opportunities to substitute other materials as a form of
source reduction for all EPA-17 chemicals. Opportunities include avoiding the use of canisters
which contain fluorocarbons to reduce the use of chloroform, and substitute solvents to replace
TCA, TCE, PERK, MEK, and MIBK.
Opportunities for the Inorganics: Reduction opportunities for the inorganic chemicals include
reducing the amount of water used in electroplating, to concentrate the cadmium, chromium and
nickel, then remove them through precipitation, evaporation, etc. from the waste water. The
cadmium, chromium and nickel can then be reused or recycled. Reduction in the use of cyanide
can be achieved though avoiding its use in electroplating compounds. Reduction in mercury use
can be achieved through substitution of other chemicals. Lead usage can also be reduced through
the avoidance of paint and solder containing lead.
Pollution Prevention Program Guide Appendix
-------
Typical Hazardous Waste Processes and Opportunities
Typical Industrial
Operation or Process
Metal working/
heat treating
Painting
Hazardous
Waste Generated
Coolants; quenching
oils; salt baths
Thinners; heavy metals;
polyurethanes;
wastewater
Waste MEK
Alodine/Chromic Acid
Rags
Paint Booth Filters
Hazardous Waste
Minimization/Source
Reduction Opportunities
Filtration Work
Centrifuge for reuse
Fuel supplements
Process change
- airless sprays
- powders
- water base primers
- HVLP spray guns
Segregation
Replace water curtain with
dry filters in spray booth
Solvent substitution
Paint substitution
Recycle solvents
Enzyme wipes
On-site treatment
(Hexavalent chrome to
trivalent chrome)
Dry cleaning system
Less frequent filter changes
(do not compromise air
emissions and workplace
exposure control)
Dissolvable filters
Paint booth baffles
Pollution Prevention Program Guide
Appendix
-------
Typical Hazardous Waste Processes and Opportunities (cont'd)
Typical Industrial
Operation or Process
Fluids change out/
transport vehicle
maintenance
Cleaning, degreasing,
metal preparation
El ectri cal/el ectronic
maintenance
Stripping
Hazardous
Waste Generated
Aerosol Cans
Oils; lubricants;
coolants; petroleum;
alcohols
Fuel filters
Oil filters
Solvents; detergents;
ketones; freon; alkalis;
heavy metals
Heavy metals; poly-
chlorinated biphenyls;
solvents; freon
Solvents; caustics
Hazardous Waste
Minimization Opportunities
Empty and puncture cans,
then recycle with scrap
metal contract
Fuel supplements
Waste segregation
Good housekeeping
Recycling & Recovery
Contact manufacturer for
reuse
Crush and drain, recycle oil,
recycle filters with scrap
metal contract
Fuel supplements
Recovery
Substitution
Jet Washers
Filtration
Chemical rejuvenation
No-clean
Substitution
Freeze guns
Process change:
- dry media blasting
(plastic beads)
- water jet
- soda bicarbonate blasting
Review stripping schedule
Reduce # of planes
stripped/year
Reduce # times plane must be
stripped
Pollution Prevention Program Guide
Appendix
-------
Typical Hazardous Waste Processes and Opportunities (cont'd)
Typical Industrial
Operation or Process
Metal plating/
finishing
Battery shop operations
Hazardous
Waste Generated
Acids; bases; metal
rinses
Battery repair and
replacement
Laboratory operations
Bulk Petroleum, Oils, and
Lubricants (POL) Storage
Acids; bases; cyanides;
heavy metals
Heavy metals, acids
Spent, used, expired
chemicals; silver
(photography)
Water contaminated w/
benzene
Hazardous Waste
Minimization Opportunities
Process change:
- aluminum coating by ion
vapor depositing
- discharge hard chrome
plating
- fume suppressants
- proprietary solutions
Industrial waste treatment
- neutralization
- ion exchange
- electrolyte precipitation
- non cyanide baths
Neutralization
Battery contractors will
accept w/o draining fluids
Reclamation
Neutralization
Material control
Industrial or domestic waste-
water treatment
Install covers on tanks
On-site carbon absorption
treatment
Pollution Prevention Program Guide
Appendix
-------
Typical Affirmative Procurement Opportunities
This list of examples should not be a limitation, instead, use it to generate ideas and actions
unique to your installation. Each action is followed by the office(s) typically responsible for
initiating any changes.
Review and revise specifications for the designated items not only to eliminate requirements
for newly produced raw material, but to give preference to recycled material. (Contracting,
Civil Engineering)
Require recycled content in all writing and copy paper. (Contracting, Supply, Defense
Printing Service, Government Printing Office)
Establish preference procedures for chlorine free paper for paper products. (Contracting,
Information Management, Defense Printing Service)
Require all paper deliverables be on recycled, chlorine-free paper and double-sided.
(Contracting)
Require recycled letterhead paper. (Information Management, Defense Printing Service)
Require recycled newsprint in all base newspapers, news magazines, and base directories.
(Public Affairs)
Require all newly acquired/leased copy machines to be capable of using recycled paper and
automatically producing two sided copies. (Contracting)
Where possible without damage to equipment, require recycled toner cartridges for copy
machines and laser printers. (Information Management)
Require documents to be transferred electronically where possible. (Contracting, Information
Management, all base organizations)
Require grounds maintenance contractors to use composted materials in mulching and
landscaping. (Civil Engineering and Contracting)
Require janitorial contractors to supply trash bags made from recycled plastics. (Civil
Engineering and Contracting)
Require the use of building products containing recycled materials when designing and
writing specifications for facility repair or new construction projects. (Civil Engineering and
Contracting)
Pollution Prevention Program Guide Appendix
-------
• Specify the use of re-refined oil and reclaimed engine coolants. (Civil Engineering,
Transportation)
• Specify retread tires for all vehicles approved for retread use. (Transportation)
• Purchase office products (desk accessories, recycling and trash receptacles, binders) which
are made using recycled plastics or other recycled materials. (All)
• Exhaust existing supplies of non-recycled products before using new recycled products. (All)
Pollution Prevention Program Guide Appendix
-------
Typical Energy Reduction Opportunities
Low Cost/No Cost Measures
• Turning off unneeded lights, computers, copiers, etc.
• Reducing heating temperature/increasing cooling temperature
• Insulating walls, ceilings, floors
• Installing storm doors and windows
• Installing weather stripping and caulking
• Keeping furnace serviced
• Planting shrubs around windy side of building to block wind and decrease heat
loss from both conduction and convection
Some Investment Required
• Automatic energy control systems and associated equipment
• Furnace modifications including replacement burners, furnaces and/or boilers
• Cogeneration systems
• Solar energy systems
Load Reduction
• Reducing lighting level or using energy efficient bulbs or fixtures, as
encouraged by DOE's Federal Lighting Initiative or EPA's Green Lights
Program, helps reduce electric and cooling loads.
• Use of efficient computers (such as those that meet EPA's Energy Star
Computer requirements) helps reduce cost of energy for personal computers
and peripherals.
Air Handling Opportunities - to reduce air handling energy and reduce cost of Variable Speed
Drive (VSD) technology
• Variable speed drive fan motor controls
• Smaller, high-efficiency motors and fans
• High-efficiency diffusers
Chiller Plant Opportunities - to eliminate CFCs, reduce chilling energy, reduce reheat, reduce
dehumidification costs, avoid disruption of service and reduce technology costs
• Replace older inefficient chillers or retrofit with CFC substitute refrigerants
• VSD on compressor where appropriate
• Downsize pump
• VSD on pumps and cooling tower fans
• Heat pipes and desiccant dehumidification
Pollution Prevention Program Guide Appendix
-------
• Thermal storage systems
Heating - reduce electric resistance use and lower electric and thermal load.
• Heat recovery
• Heat pumps
• Gas
• Solar space heating systems
Hot Water - Improve thermal efficiency and reduce electric resistance use.
• Heat recovery
• Heat pumps
• Cogeneration
• Solar thermal water heaters
Other
• Passive solar systems (wind energy devices, earth-sheltered buildings, etc.)
Pollution Prevention Program Guide Appendix
-------
Appendix C
Sample
Pollution Prevention
Management
Action Plan
Pollution Prevention Program Guide Appendix
-------
SAMPLE MANAGEMENT ACTION PLAN
TABLE OF CONTENTS
Page
ACRONYMS AND ABBREVIATIONS iii
SECTION 1 PROCESS -1
1.1 Policy -2
1.2 Baseline -3
1.3 Requirements -4
1.4 Options -5
1.5 Solutions -6
1.6 Program -7
1.7 Execution -8
1.8 Metrics and Reporting -9
SECTION 2 PROGRAM 2-1
2.1 Ozone Depleting Substances (ODS) 2-4
2.2 EPA 17 Industrial Toxics Program Chemicals 2-4
2.3 Hazardous Waste 2-5
2.4 Municipal Solid Waste 2-6
2.5 Affirmative Procurement 2-7
2.6 Energy Conservation 2-8
2.7 Pesticide Management 2-8
2.8 TRI Chemicals 2-9
SECTIONS EXECUTION 3-1
3.1 Ozone Depleting Substances 3-1
3.2 EPA 17 Chemical Purchases 3-2
3.3 Hazardous Waste Disposal 3-4
3.4 Municipal Solid Waste Disposal 3-8
3.5 Affirmative Procurement 3-11
3.6 Energy Conservation 3-12
3.7 Pesticide Management 3-13
3.8 TRI Chemicals 3-14
APPENDIX A PROJECT NARRATIVES
(NOTE: THIS SAMPLE PLAN CONTAINS ONLY ONE EXAMPLE NARRA TIVE FROM EA CH
P2 PROGRAM AREA)
APPENDIX B CALENDAR YEAR 1994 HAZARDOUS WASTE GENERATION
SUMMARY
APPENDIX C SUMMARY OF TRI CHEMICALS
Pollution Prevention Program Guide
Appendix
-------
LIST OF FIGURES
No. Title
1-1 The Pollution Prevention Process
Page
1-1
No.
LIST OF TABLES
Title
Page
1-1 Establishment of Pollution Prevention Policies
1-2 Establishment of Pollution Prevention Baselines
1-3 Pollution Prevention Program Requirements
1-4 Actions for Conducting and Maintaining Opportunity Assessments
1-5 Management Actions Necessary to Identify Solutions
1-6 The Decision-Making Process
1-7 Management Action Execution of the P2 Program
1-8 Measuring and Reporting Progress
2-1 CY 1994 Summary of AFB's Pollution Prevention Program
2-2 ODS Elimination Options
2-3 EPA 17 Chemical Reduction Options
2-4 Hazardous Waste Reduction Options
2-5 Municipal Solid Waste Reduction Options
2-6 Affirmative Procurement Options
2-7 Pesticide Management Options
2-8 TRI Chemicals
3-1 Achieving P2 Goals: ODSs
3-2 Achieving P2 Goals: EPA 17 Chemical Purchases
3-3 Achieving P2 Goals: Hazardous Waste Disposal
3-4 Achieving P2 Goals: Municipal Solid Waste Disposal
3-5 Achieving P2 Goals: Affirmative Procurement
3-6 Achieving P2 Goals: Pesticide Management
3-7 Achieving P2 Goals: TRI Chemicals
1-2
1-3
1-5
1-6
1-7
1-8
1-9
1-9
2-2
2-4
2-5
2-5
2-7
2-7
2-8
2-9
3-1
3-2
3-5
3-8
3-12
3-13
3-14
Pollution Prevention Program Guide
Appendix
-------
ACRONYMS AND ABBREVIATIONS
AFB Air Force Base
API Air Force Instructions
AFPD Air Force Policy Directive
AGE Aerospace ground equipment
AP Affirmative Procurement
BE Bioenvironmental Engineering
CAA Clean Air Act
CEO Civil Engineering Operations
CFC Chlorofluorocarbon
CFR Code of Federal Regulations
CY Calendar year
DoD Department of Defense
DRMO Defense Reutilization and Marketing Organization
EO Executive Order
EPA Environmental Protection Agency
EPA-17 EPA's Industrial Toxics Project Chemcials
EPC Environmental Protection Committee
EPCRA Emergency Planning and Community Right-to-Know Act
ESG Energy Steering Group
FEMIA Federal Energy Management Improvement Act
FY Fiscal year
HCFC Hydrochlorofluorocarbon
HM Hazardous materials
HQ Headquarters
HVAC Heating, ventilation, and air conditioning
HW Hazardous wastes
ITP Industrial Toxics Project
Ibs Pounds
LP Local purchase
MAJCOM Major Command
MAP Management Action Plan
Pollution Prevention Program Guide
Appendix
-------
MedLog Medical Logistics
MSW Municipal solid waste
NSN National stock number
OA Opportunity Assessment
OCR Office of Collateral Responsibility
ODS Ozone Depleting Substance
OPR Office of Primary Responsibility
OSHA Occupation Safety and Health Act
P2 Pollution Prevention
P2OA Pollution Prevention Opportunity Assessment
PM Pest Management
PPA Pollution Prevention Act
QA/QC Quality assurance and quality control
RCRA Resource Conservation and Recovery Act
ROI Return on investment
TRI Toxic Release Inventory
US United States
USAF United States Air Force
Pollution Prevention Program Guide
Appendix
-------
SECTION 1
PROCESS
Pollution prevention programs seek to eliminate the purchase of materials and
generation of wastes known to be hazardous or otherwise non-recoverable. USAF
activities may be modeled as processes which may include base industrial activities,
vehicle maintenance, printing operations, or pest management. Each process relies on a
steady stream of materials and may generate wastes as by-products of these processes.
The specific effort of a P2 program is to target process inputs (sources) and outputs
(wastes) for reduction or elimination where possible. This is known as source reduction.
Where source reduction is not feasible or cannot eliminate waste, materials may be reused
or recycled to reduce waste and purchase requirements. Goals to purchase products with
recycled content through affirmative procurement help close the recycling loop by
creating demand for recycled products.
This section describes the process needed to develop a pollution prevention program
to meet Air Force P2 reduction goals. This P2 process is divided into the eight elements
as illustrated in Figure 1-1. The following subsections describe each element of the P2
process and list the management actions needed to initiate the P2 activity and to continue
functioning in the future (recurring actions). The tables included in the following
subsections assign Offices of Primary Responsibility (OPR), Offices of Collateral
Responsibility (OCR), when necessary, and the dates of estimated completion and actual
completion for each management action.
Figure 1-1 The Pollution Prevention Process
FIGURE 2-2
THE POLLUTION PREVENTION PROCESS
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
1.1 POLICY
Policy is defined as a statement of values embodied in a goal that the USAF will
achieve through commitment of resources. Pollution prevention policy is contained in
Air Force Policy Directive (AFPD) 32-70, Environmental Quality, and API 32-7080,
Pollution Prevention Programs. This section describes the areas in which AFB
outlines its internal policies and procedures for meeting the USAF P2 goals listed in the
guide. It includes assigning responsibilities and deadlines to each management action.
These responsibilities and management actions are presented in Table 1-1.
Table 1-1 Establishment of Pollution Prevention Policies
Action
Initial: Incorporate AFB P2
program into the Environmental
Protection Committee (EPC)
Recurring: None
Initial: Establish a P2 working group
under the EPC and establish teams in the
areas of ODSs, EPA 17s, HW, MSW, AP,
PM, and TRI chemicals.
Recurring: Staff the teams with
necessary personnel; evaluate
effectiveness of each group; modify
structure as required
Initial: Establish format for team
meetings and task accomplishments
toward meeting P2 goals
Recurring: Meet as necessary; assign
responsibilities based on needs at that
time
Initial: Develop P2OA to establish
program organization and strategies for
meeting all USAF P2 reduction goals
Recurring: Update P2OA
Initial: Develop the Facility Energy Plan
Recurring: Update Facility Energy Plan
Initial: Establish Energy Management
Steering Group (EMSG), staff
appropriately. Establish supporting
Energy Working Groups for all
appropriate organizations
OPR
Wing Commander
EPC
EPC
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
CES/CEOE
CES/CEOE
CES/CEOE
Estimated
Completion
Annually
As needed
Annually
1997
Annually
Actual
Completion
1993
1993
1993
1995
1995
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 1-1 Establishment of Pollution Prevention Policies (continued)
Action
Recurring: Staff the teams with
necessary personnel; evaluate
effectiveness of each group; modify
structure as required
OPR
EMSG
Estimated
Completion
Annually
Actual
Completion
1.2 BASELINE
A baseline is a measurement of the amount of a targeted substance purchased or
generated during a specified time period. Baselines establish the beginning numerical
status of a targeted substance relative to the P2 goals. Information collected to determine
the baseline includes descriptions and quantities of materials purchased or generated, unit
costs of purchase or disposal, and a description of each process using the material and
generating the waste. As described in a 2 May 1995, memorandum from Headquarters
(HQ) USAF/CEV, baselines are not to be adjusted after 26 May 1995, except under the
conditions described in the Metric Reporting Guidance attached to the memorandum.
The Metric Reporting Guidance only allows for baseline adjustments when an installation
is transferred from one MAJCOM to another. Furthermore, no adjustments will be
allowed to compensate for mission changes, personnel increases or decreases, or Base
Realignment and Closure Commission actions for installations within the same
MAJCOM. The establishment of baselines and the assignment of OPR are presented in
Table 1-2.
[Contractor Name] prepared baseline data for the program elements ODSs, EPA 17s,
PM, and TRI chemicals. Data for ODSs, EPA 17s and TRI chemicals are based on the
Toxic Chemical Inventory Technical Report prepared by [Contractor] in August 1995.
The purpose of the report was to identify those EPCRA Section 313 toxic chemicals that
were manufactured, processed, or otherwise used in CY94 on AFB. Baseline and
inventory data for PM was compiled by AFB and [Contractor] during the P2OA.
HW and MSW baselines have been set by AFB based on [MAJCOM] guidance
dated . Baseline data collected for ODSs, EPA 17s, PM, and TRI chemicals
result from annual quantities of products and chemicals procured for AFB.
Table 1-2 Establishment of Pollution Prevention Baselines
Action
Initial: Establish CDS CY94 baseline
Recurring: Track progress toward
reaching compliance of elimination of
ODS purchases
OPR
CES/CEV
Estimated
Completion
Annually
Actual
Completion
Feb 1996
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 1-2 Establishment of Pollution Prevention Baselines (continued)
Action
Initial: Establish EPA 17 CY92 baseline
Recurring: Modify baseline based on
variations in mission and in accordance
with [MAJCOM]/CEV
Initial: Establish HW CY92 baseline
Recurring: Modify baseline based on
variations in mission and in accordance
with [MAJCOM]/CEV
Initial: Establish MSW CY92 baseline
Recurring: Modify baseline based on
variations in mission and in accordance
with [MAJCOM]/CEV
Initial: Identify EPA Guideline Items
purchased by AFB and determine
which purchases do not meet EPA
recycled content standards
Recurring: Evaluate program to ensure
all current Guideline Item purchases are
addressed
Initial: Establish energy conservation
CY85 baseline
Recurring: Modify baseline based on
variations in mission and in accordance
with [MAJCOM]/CEV
Initial: Establish pesticide management
CY93 baseline
Recurring: Modify baseline based on
variations in mission and in accordance
with [MAJCOM]/CEV
Initial: Establish TRI chemical CY94
baseline
Recurring: Modify baseline based on
variations in mission and in accordance
with [MAJCOM]/CEV
OPR
CES/CEV
CES/CEV
CES/CEV
CES/CEV
CES/CEOE
CES/CEOE
CES/CEV
CES/CEV
Estimated
Completion
As required
As required
As required
Dec 1996
Annually
As required
As required
As required
Actual
Completion
Feb 1996
Feb 1996
Feb 1996
1985
Feb 1996
Feb 1996
1.3 REQUIREMENTS
Installation requirements identify the quantity of material or waste that must be
reduced to meet the Air Force P2 reduction goals. The requirement is the difference
between the goal and the baseline, and it identifies what the program needs. For example,
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
the first energy goal is to reduce energy use by 10 percent by 1995 when compared to a
1985 baseline. If the 1985 energy consumption was 0.149 MBtu, a 10 percent reduction
amounts to 0.0149 MBtu; this is the requirement. If energy consumption efforts after
1985 have already yielded a reduction of 0.004 MBtu, this can be subtracted, and the
remaining requirement is 0.0109 MBtu, or the amount of reduction still needed to attain
the reduction goal. This process is repeated to obtain the requirements for the second and
third phase energy reduction goals (20 percent by 31 December 2000 and 30 percent by
31 December 2005, respectively). For non-baseline areas (e.g., affirmative procurement),
the requirement will equal the difference between the goal and the current measurement.
The identification of the requirements for meeting the P2 goals is outlined below in Table
1-3.
Table 1-3 Pollution Prevention Program Requirements
Action
Initial: Determine requirements for
ODSs
Recurring: Update requirements
Initial: Determine requirements for
EPA 17 chemicals
Recurring: Update requirements
Initial: Determine requirement for HW
Recurring: Update requirements
Initial: Determine requirement for MSW
Recurring: Update requirements
Initial: Determine requirement for AP
Recurring: Update requirements
Initial: Determine requirements for
energy conservation program
Recurring: Update requirements
Initial: Determine requirements for
pesticide management program
Recurring: Update requirements
Initial: Determine requirements for TRI
chemical program
Recurring: Update requirements
OPR
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
CES/CEOE
CES/CEOE
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
Estimated
Completion
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Actual
Completion
Feb 1996
Feb 1996
Feb 1996
Feb 1996
Feb 1996
Feb 1996
Feb 1996
Feb 1996
1.4 OPTIONS
When base requirements are outlined, P2 options for meeting the requirements must
be identified, and these options are identified through OAs. The Air Force Installation
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Pollution Prevention Program Guide and the AFB P2OA Report outline the method
for conducting OAs. The OAs identify the following: specific waste generating
processes, a description of P2 options, the option's cost, the option's value in terms of
which substances and program components are affected, how much each substance is
reduced for each affected process, the unit cost of purchase or disposal for each
substance, and the ROI. Table 1-4 lists the actions necessary to conduct and maintain
current OAs.
Table 1-4 Actions for Conducting and Maintaining Opportunity Assessments
Action
Initial: Develop P2 options that will
achieve base requirements for ODSs,
EPA 17s, HW, MSW, AP, PM, and TRI
chemicals through OAs
Recurring: Accomplish periodic OAs
and develop new options as necessary
Initial: Develop expertise to conduct in-
house OAs
Recurring: None
Initial: Develop site-specific OA
worksheets
Recurring: Update worksheets
Initial: Conduct site-specific OAs
Recurring: Accomplish site-specific
OAs and develop new options as
necessary
Initial: Develop energy conservation
options that will achieve base
requirements
Recurring: Accomplish periodic OAs
and develop new options as necessary
OPR
P2 Subcommittee
and Teams
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
CES/CEOE
CES/CEOE
Estimated
Completion
As required
Ongoing
As required
As required*
Ongoing
As required
Actual
Completion
Dec 1995
Dec 1995
Dec 1995
As required, at a minimum bi-annually, to assure compliance with reduction goals and review of processes.
1.5 SOLUTIONS
Solution sets that allow the USAF to meet its reduction requirements, are compiled
from the range of options identified as a result of the OAs. The options in the solution set
have been selected for implementation based on their technical feasibility, cost-
effectiveness, prevention of pollutant cross-media transfer, and significant contribution to
meeting the Air Force P2 reduction goals. The options within the solution set for each
reduction goal year are first prioritized based on ROI (when available) and on cost when
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
ROIs are not available. Table 1-5 lists the management actions necessary to identify
solutions.
Table 1-5 Management Actions Necessary to Identify Solutions
Action
Initial: Select implementable options for
CDS, EPA 17, HW, MSW, AP, PM and
TRI chemicals
Recurring: Continue to accept, evaluate,
and prioritize options to maintain a viable
pool of solutions for the above goal areas
Initial: Select implementable energy
conservation options
Recurring: Continue to accept, evaluate,
and prioritize options to maintain a viable
pool of solutions for the goal area
Initial: Consider various Federal
threshold levels (EPCRA, OSHA, CAA,
etc.) when selecting implementation
options
Recurring: Continue to evaluate and
update threshold levels and requirements
when selecting options
Initial: Document implementable
options in the Program Section of this P2
MAP
Recurring: Continue to update and
prioritize options in the Program Section
of this P2 MAP
OPR
P2 Subcommittee
P2 Subcommittee
CES/CEOE
CES/CEOE
P2 Subcommittee
and CEOE*
P2 Subcommittee
and CEOE*
P2 Subcommittee
and CEOE*
P2 Subcommittee
and CEOE*
Estimated
Completion
Ongoing
Ongoing
Ongoing
Ongoing
Ongoing
Actual
Completion
Feb 1996
1994
Feb 1996
Indicates that P2 Subcommittee is OPR for program elements ODSs, EPA 17s, MSW, AP, PM, and TRI;
CES/CEOE is OPR for energy conservation.
1.6 PROGRAM
Once the best solution sets have been identified, the actual program must be
constructed based on the options in the solution sets. A decision-making body and
process must be established to ensure funds are allocated against the highest priority
options and that the program is carried into the future. Once funds have been allocated,
the options may become projects. Table 1-6 describes this decision-making body and
process.
Civil Engineering is the lead organization for consolidating and managing
AFB's P2 and budget. P2 projects must be programmed and budgeted in accordance with
the associated rules for each appropriation. API 32-7001, Environmental Budgeting,
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
provides programming and budgeting information. The following projects are not
eligible for P2 funds:
Acquisition projects
Air conditioning projects
Depot level equipment
Energy conservation MilCon projects
Halon projects (except for prototype
projects for aircraft)
• Environmental certifications and licenses
• Fire extinguisher projects
• Maintenance projects
• Non-environmental projects
Table 1-6 The Decision-Making Process
Action
Initial: Submit the initial P2 budget to
[MAJCOM]
Recurring: Submit annual P2 budgets to
[MAJCOM]
Initial: Enter initial projects and
equipment items into the A- 106
Recurring: Enter annual projects and
equipment items into the A- 106
Initial: Submit initial unfunded P2
projects to [MAJCOM]
Recurring: Submit annual unfunded P2
projects to [MAJCOM]
Initial: Establish procedures to classify
projects
Recurring: Review procedures and
classification system
Initial: Establish decision-making body
to review solutions and determine P2
programs
Recurring: Submit annual options to
committee for review
OPR
CES/CEV
CES/CEV
CES/CEV
CES/CEV
CES/CEV
CES/CEV
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
Estimated
Completion
Dec 15,
Annually
Dec 15,
Annually
June 15,
Annually
Dec 1996
Annually
Dec 1996
Annually
Actual
Completion
1994
1994
1994
1.7 EXECUTION
The tabular information in this section outlines the management actions that must
occur to execute a successful P2 program. Timely execution is critical to program
success and resource allocation. The management actions that correspond to the
execution of the P2 program are listed below in Table 1-7.
Appendix C, Pollution Prevention Program Guide
Sample MAP
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Table 1-7 Management Action Execution of the P2 Program
Action
Initial: Establish execution goals and
track percentage of projects executed
throughout the fiscal year
Recurring: Update goals as projects are
completed
OPR
P2 Subcommittee
and CEOE*
P2 Subcommittee
and CEOE*
Estimated
Completion
Ongoing
Actual
Completion
Feb 1996
* Indicates that P2 Subcommittee is OPR for program elements ODSs, EPA 17s, MSW, AP, PM, and TRI;
CES/CEOE is OPR for energy conservation.
1.8 METRICS AND REPORTING
The actual benefit of implemented ideas should be measured and compared with the
projected benefit. This is done through the use of metrics: measurements used to
measure progress. Established metrics are founded upon baselines for each program
element. Metrics will be tracked by the ## CES/CEV annually to determine whether the
Air Force P2 reduction goals are being met for each program element. Metrics use actual
execution data to measure program performance. Modifications to the program will be
based on the difference between estimated completion and actual performance. Table 1-8
outlines the actions necessary to measure and report progress.
Table 1-8 Measuring and Reporting Progress
Action
Initial: Establish procedures to capture and
record data for the AFPD metrics in ODSs,
EPA 17s, HW, MSW, AP, PM, TRI chemicals
and any other legally mandated reports
Initial: Establish procedures to capture and
record data for the AFPD metrics in EPA 17s
and TRI chemicals
Recurring: Enter reportable data into the P2
module of the WIMS-ES for AFPD metrics
Recurring: Measure actual benefits of
completed projects for all goal areas
OPR
P2 Subcommittee
HazMat Pharmacy
CES/CEV
P2 Subcommittee
and CEOE*
Estimated
Completion
Jun 1996
Annually
Semi-
Annually
Annually
Actual
Completion
Appendix C, Pollution Prevention Program Guide
Sample MAP
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Table 1-8 Measuring and Reporting Progress (Continued)
Recurring: Compare actual benefit and cost
of each project completed in this reporting
cycle with estimated completion benefit and
cost for all goal areas
Recurring: Update requirements with actual
benefit data and modify program accordingly
for all goal areas
Recurring: Record actual cost data for
improving future cost estimates for all goal
areas
Recurring: Evaluate the results of
implementing solutions, determine the
deviation from projected results, and initiate
the requirements to generate new options for
all goal areas
Recurring: Provide status briefings to Wing
Commander
Recurring: Initiate requirement for more
options to be generated for all goal areas
P2 Subcommittee
and CEOE*
P2 Subcommittee
and CEOE*
P2 Subcommittee
and CEOE*
P2 Subcommittee
and CEOE*
CES/CEV
P2 Subcommittee
and CEOE*
Annually
Annually
Annually
Ongoing
Quarterly
As required
* Indicates that P2 Subcommittee is OPR for program elements ODSs, EPA 17s, MSW, AP, PM, and TRI;
CES/CEOE is OPR for energy conservation.
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
SECTION 2
PROGRAM
This section contains a program summary and listing of P2 projects for each program
element. Table 2-1 summarizes and describes the relationship among the policy goals,
baselines, requirements, benefits, and costs for each of the program elements. The policy
goals are quantified according to percent reduction, and projected deadlines are specific
for each program element.
Tables 2-2 through 2-7 in this section provide a listing of the P2 options by program
element with associated costs, benefits, ROI, and OPR. These tables reflect where each
program element stands in regard to HQ and AETC goals. If the program element has
previously met Air Force P2 goals, the options listed assist with future reductions. If the
program has not met its goals, the options specify what actions may be taken and the
reductions that may be realized. Various assumptions were made when calculating
benefits and costs. "NA" was entered as not applicable, "NC" was entered as not
calculated due to insufficient data, and "Unknown" was entered if the benefit could not be
calculated. ROI may be a value of zero because costs may exceed net operating savings,
or because no capital costs are incurred with the action. Total benefits on the following
charts represent the benefit if all of the proposed options were implemented. The base
may choose to use a combination of options to reach the HQ and MAJCOM goals. The
purpose of the P2 MAP is to provide adequate reduction options. Therefore, the figure for
total benefits may exceed the actual amount of materials to be reduced.
Baseline data collected for ODSs, EPA 17s, PM, and TRI chemicals result from
annual quantities of chemicals procured for AFB. HW and MSW baselines are set
based on AFB and MAJCOM guidance dated . The quantity of products
issued are assumed to be equivalent to the quantity of products used during that
respective year. Therefore, reductions in application, release, disposal, and transfer are
associated with the quantity of chemical purchased for data collection and tracking
purposes. Data for MSW is based on actual volumes of MSW being disposed.
All the options and initiatives addressing each of the program elements specified in
Air Force Installation Pollution Prevention Program Guide originated from the
following sources:
• AFB Pollution Prevention Opportunity Assessment
• AFB Energy Conservation and Reduction Plan
• [Contractor Name]
Appendix C, Pollution Prevention Program Guide Sample MAP
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Table 2-1. Summary of AFB's Pollution Prevention Program
Pollution Prevention
Program Elements
Baseline Year
Baseline Quantity
Goal Reduction Year End
Goal Reduction Percent
Reduction Quantity
Goal
ODS
(Ibs)
NA
NA
NA
100%
8,606
0
EPA 17a
(Ibs)
CY92
37,636
CY96
50%
18,818
18,818
TRI
Chemicals
(Ibs)
CY94
16,500C
CY99
50%
8,250
8,250
Pesticide
Management
(Ibs)
CY93
9,636d
CYOO
50%
4,818
4,818
AP
NA
NA
Annually
NA
NA
NA
Energy Conservation
(KBtu/SF)
CY85
96,636d
CY95
10%
9.63
86.67
CYOO
20%
19.26
77.04
CY05
30%
28.89
67.41
Comparison of Inventory Quantities with Baseline Quantities
CY94 Inventory
Quantity
Reduction Quantity
Achieved through CY94
CY94 Percent
Reduction Achieved
8,606
NA
NA
24,695
12,941
34%
16,500b
0
0%
9,259
377
4%
NA
NA
NA
98. 5b
+2.5
-2.6%
—
~
—
—
~
—
Summary of Additional Requirements to Meet Reduction Goals
Additional Reduction
Quantity Required
Percent Remaining to Meet
Reduction Goal
Total Costs Expected
8,606
100%
$7,200
5,877
16%
$201,710
8,250
50%
$33,710
4441
46%
$9,960
NA
NA
NA
12.13
12.6%
$Unknown
21.76
22.6%
$Unknown
31.39
32.6%
$Unknown
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 2-1. (Continued) Summary of AFB's Pollution Prevention Program
Pollution Prevention
Program Elements
Baseline Year
Baseline Quantity
Goal Reduction Year End
Goal Reduction Percent
Reduction Quantity
Goal
Hazardous Waste Municipal Solid Waste
(Ibs) (tons)
CY95
142,000
CY96
11%
15,620
126,380
CY97
22%
31,240
110,760
CY98
33%
46,860
95,140
CY99
44%
62,480
79,520
CYOO
55%
78,100
63,900
CY95
4,907
CY96
6%
294.42
4,612.58
CY97
23%
1,128.61
3,778.39
CY98
30%
1,472.10
3,434.90
CY99
39%
1,913.73
2,993.27
CYOO
45%
2,208.15
2,698.85
Comparison of Inventory Quantities with Baseline Quantities
CY96 Inventory
Quantity
Reduction Quantity
Achieved through CY96
CY96 Percent
Reduction Achieved
-
-
-
-
-
-
-
-
-
-
Summary of Additional Requirements to Meet Reduction Goals
Additional Reduction
Quantity Required
Percent Remaining to Meet
Reduction Goal
Total Costs Expected
15,620
11%
-
31,240
22%
-
46,860
33%
-
62,480
44%
-
78,100
55%
$328,570
294.42
6%
-
1,128.61
23%
-
1,492.10
30%
-
1,913.73
39%
-
2,208.15
45%
$778,750
a CY 1992 baseline excludes quantities from fuel purchases. Source: USAF, 1995a.
b Data from FY95.
c TRI chemical data totals are from non-exempt amounts in inventory and are inclusive of non-exempt totals for EPA 17s.
d Measured in pounds of active ingredients.
+ No reduction achieved. Indicates amount above baseline.
NA Not Applicable.
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Each project option or action was given a code based on the program element to
which the project applies (e.g., HW-1 for HW project number 1, MSW-1 for MSW
project number 1, etc.). The initiating source for each option is provided in the narratives
in Appendix A. The narratives identify many costs and benefits that are not represented
in the tables in this section. Many assumptions for the projects were based on limited
data. Prior to implementation of a project, all costs and benefits should be reviewed
carefully to verify the true costs and benefits for AFB.
2.1 OZONE DEPLETING SUBSTANCES (ODSs)
Goal: Eliminate the purchase of ODSs as soon as possible.
AFB is in the process of eliminating the new purchase of all pure Class I ODSs
in accordance with the deadlines specified in the Air Force P2 program. The options
listed in Table 2-2 are designed to eliminate the new purchase of products containing
ODSs. The Bioenvironmental Engineering (BE) office at AFB evaluates suitable
product substitutes and assist shops in implementing the substitutions.
Table 2-2 ODS Elimination Options
(FY) Project Title
(FY96) ODS-1
Replace Current ODSs with Low- or No-
ODS Substitutes
(FY96) ODS-2
Monitor ODS -using Equipment
TOTAL
ROI
None
>None
Capital
Cost3
$4,000
$3,200
$7,200
Benefit
(Ibs/yr)
6,500
6,000
> 8,606
OPR
CEV
CEV
Total only for known capital costs. Does not assume costs not calculated.
2.2 EPA 17 INDUSTRIAL TOXICS PROGRAM CHEMICALS
Goal: Reduce the purchase and use of EPA 17 chemicals by 50 percent by 31
December 1996 from a CY92 baseline of 37,636 pounds (Ibs). The CY92 baseline does
not include EPA 17 chemicals contained in fuels. This also does not include EPA 17
chemicals that are included in fuels used for fire training.
AFB is progressing toward the 31 December 1996 reduction goal. The base
has currently achieved a cumulative reduction of 12,941 Ibs, or 34 percent through CY94.
To achieve the CY96 goal, AFB must reduce EPA 17 purchases by 16% which is
an additional 5,877 Ibs. The options presented in Table 2-3 are recommendations for
continued reduction and product substitutions which will assist AFB in reducing
the amount of EPA 17 chemical purchases beyond the Air Force P2 reduction goals.
The Bioenvironmental Engineering (BE) office at AFB also evaluates suitable
product substitutes and assists shops in implementing the substitutions.
Appendix C, Pollution Prevention Program Guide
Sample MAP
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Table 2-3 EPA 17 Chemical Reduction Options
(FY) Project Title
(FY96) EPA-1
Solvent Substitution
(FY96) EPA-2
Solvent Recycling
(FY96) EPA-3
Paint Gun Cleaner
(FY96) EPA-4
HVLP Sprayer
(FY96) EPA-5
Integrated Pest Management
(FY96) EPA-6
Purchase and Implement Automated Paint
Mixer with Electrostatic Sprayers
TOTAL
ROI
None
1.99a
1.35
0.07
None
2.4
Costb'c
$13,560C
$19,500a
$6,000
$1,650
10,000
151,000
$201,710
Benefit
(Ibs/yr)
3,500
4,850a
1,775
1,480
aprox 100
2,800
14,505
OPR
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
a Figures represents shared options applicable to multiple processes. See Appendix A for details.
b Total only for capital costs.
c Total for annual cost, if no capital costs apply.
NC Not calculated due to insufficient data.
2.3 HAZARDOUS WASTE
Goal: Reduce HW disposal by 11 percent by CY96, 22 percent by CY97, 33 percent
by CY98, 44 percent by CY95, and 55 percent by CYOO from a CY95 baseline of
142,000 Ibs.
AFB received guidance for new HW pollution prevention metrics from
[MAJCOM] on (date). The new metrics begin with a CY95 baseline of 142,000 Ibs.
Reduction goals are set incrementally until the year 2000 for a total reduction of 55
percent, or 78,100 Ibs of hazardous waste. A summary of AFB's hazardous waste
generation is provided in Appendix B. Implementation of the projects listed in Table 2-4
will assist AFB in reducing the amount of HW generation toward the Air Force P2
reduction goals.
Table 2-4 Hazardous Waste Reduction Options
(FY) Project Title
(FY96) HW-1
Solvent Recycling
(FY96) HW-2
Solvent Substitution
ROI
1.99a
None
Costb
$19,500a
$13,560C
Benefit
(Ibs/yr)
3,700a
4,200
OPR
P2
Subcommittee
P2
Subcommittee
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 2-4 Hazardous Waste Reduction Options (continued)
(FY) Project Title
(FY96) HW-3
On-Site Metals Treatment
(FY96) HW-4
Filter Analysis
(FY96) HW-5
Rechargeable Batteries
(FY96) HW-6
Alternative Paint Stripper
(FY96) HW-7
Paint Gun Cleaner
(FY96) HW-8
Hazardous Waste Tracking Team
(FY96) HW-9
HVLP Sprayer
(FY96) HW-10
Purchase and Implement Automated
Paint Mixer with Electrostatic Sprayers
(FY96) HW-11
Replace Lead Acid Batteries with Gel-
Cell Batteries
TOTAL
ROI
6.9
0.85
0.46
None
1.35
None
0.07
2.4
0
Costb
101,000
$12,800
$300
$3,990C
$6,000
$11,520
$1,650
$151,000
$7,250C
$328,570
Benefit
(Ibs/yr)
12,000
19,400
3,500
950
1,775
25,000
3,700
4,000
3,000
81,225
OPR
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
Figures represents shared options applicable to multiple processes. See Appendix A for details.
Total only for capital costs.
Total for annual cost, if no capital costs apply.
2.4 MUNICIPAL SOLID WASTE
Goal: Reduce MSW disposal by 6 percent by CY96, 23 percent by CY97, 30 percent
by CY98, 39 percent by CY95, and 45 percent by CYOO from a CY95 baseline of 4,907
tons.
AFB received guidance for new MSW pollution prevention metrics from
[MAJCOM] on (date). The new metrics begin with a CY95 baseline of 4,907 tons.
Reduction goals are set incrementally until the year 2000 for a total reduction of 45
percent, or 2,208 tons of municipal solid waste. Implementation of the projects listed in
Table 2-5 will assist AFB in reducing the amount of MSW generated and assist in
reaching the Air Force P2 reduction goals. These options are detailed in the project
narratives in Appendix A.
Appendix C, Pollution Prevention Program Guide
Sample MAP
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Table 2-5 Municipal Solid Waste Reduction Options
(FY) Project Title
MSW-1
Source Reduction Education Program
MSW-2
Reduce collection of MFH Grass Clippings
MSW-3
Point Papers from Waste Generators
MSW-4
Electric Hand Dryers
MSW-5
Improve Existing Recycling Program
MSW-6
Wood Waste Recycling Program
MSW-7
Yard Waste Composting
MSW-8
Mixed Waste Composting
MSW-9
Backyard Composting
TOTAL
ROI
None
None
None
3.51
5.47
6.28
21
8.64
6.35
Cost
$0
$0
$0
$108,000
$107,000
$30,000
$241,500
$247,250
$45,000
$778,750a
Benefit
(tons/yr)
233
69
558
30
783
1,000
700
l,295b
284C
>2,208
OPR
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
a Total includes capital costs only.
b Includes 700 tons of MSW-7.
c Includes 69 tons of MSW-2.
2.5 AFFIRMATIVE PROCUREMENT
Goal: Ensure 100 percent of all EPA Guideline Items purchased each year contain
recycled materials meeting EPA guideline standards.
Currently AFB has not implemented an affirmative procurement program or a
system that routinely monitors the procurement of EPA Guideline Items. The single
option presented in Table 2-6 is a recommendation for developing an affirmative
procurement program at AFB. The program should address affirmative procurement
of all current and proposed EPA Guideline Items.
Table 2-6 Affirmative Procurement Options
(FY) Project Title
AP-1
Develop Affirmative Procurement
Program
Cost
NC
Benefit
Unknown
OPR
P2
Subcommittee
Not calculated due to insufficient data.
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
2.6 ENERGY CONSERVATION
Goal: Reduce energy consumption by 10 percent by 31 December 1995, 20 percent
by 31 December 2000, and 30 percent by 31 December 2005 from CY85 baselines.
AFB's CY85 baseline is 96.3 KBtu/SF. In 1995, AFB's energy consumption
was 98.8 KBtu/SF. They currently are not meeting their energy conservation goals.
The base Energy Management Program is managed by the Civil Engineer Squadron's
Maintenance Engineering Element. Further information can be obtained from the Chief,
Maintenance Engineering at (xxx) xxx-xxxx.
2.7 PESTICIDE MANAGEMENT
Goal: Reduce purchases and application of pesticides 50 percent by 31 December
2000 from a CY93 baseline of 9,636 Ibs.
AFB is progressing toward the CYOO reduction goal. A total reduction of 4
percent of the baseline, or 377 Ibs of active ingredients, was achieved in CY94. To reach
the 50 percent reduction goal by CYOO, AFB must reduce pesticide active ingredient
application by an additional 46 percent, or 4,441 Ibs. Table 2-7 presents an option to
assist AFB in meeting this goal.
Table 2-7 Pesticide Management Options
(FY) Project Title
PM-1
Integrated Pest Management Program
TOTAL
ROI
None
Cost
$9,960
$9,960
Benefit
(Ibs/yr)
>4,818
>4,818
OPR
P2
Subcommittee
2.8 TRI CHEMICALS
Goal: Reduce release and off-site transfers of TRI chemicals 50 percent by 31
December 1999 from a CY94 baseline of 16,500 pounds.
In order for AFB to reach the 50 percent goal, a reduction of 8,250 Ibs of TRI
chemicals must be made. Implementation of the projects listed in Table 2-8 will assist
AFB in reducing release and off-site transfers of TRI chemicals. A summary of
AFB's TRI chemicals is provided in Appendix C.
Appendix C, Pollution Prevention Program Guide
Sample MAP
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Table 2-8 TRI Chemical Reduction Options
(FY) Project Title
TRI-1
Replace Lead Acid Batteries with Gel Cell
TRI-2
Replace ODSs
TRI-3
Solvent Substitutes
TRI-4
Glycol Ether Solvent Substitutes
TOTAL
ROI
None
None
None
None
Cost3
$7,250a
$7,200a
$13,560a
$5,700a
$33,710
Benefit
(Ibs/yr)
500
5,000
3,500
5,000
14,000
OPR
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
P2
Subcommittee
Total for annual cost, if no capital costs apply.
Appendix C, Pollution Prevention Program Guide
Sample MAP
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SECTION 3
EXECUTION
This section summarizes the management actions necessary to initiate and implement
options identified in Section 2. These actions are specific to each AFB project.
Prior to implementation, a detailed engineering cost estimate should be prepared. The
costs and benefits provided in the project narratives are estimates. This section is
subdivided by each of the eight program elements (ODSs, EPA 17, HW, MSW, AP,
energy conservation, pesticide management, and TRI chemicals). The options chosen to
help achieve the reduction goals for each program element are listed under the element,
and each option has a table outlining the steps to execute the option.
3.1 OZONE DEPLETING SUBSTANCES
The Clean Air Act identified many substances that contribute to the depletion of the
Earth's stratospheric ozone layer. USAF policy outlines a plan to eliminate the purchase
of newly-produced ODSs. The purchase ban takes effect on different dates for different
ODS applications. AFB has curtailed the new purchase of all Class I ODS
refrigerants and equipment utilizing Class I ODS refrigerants, including air conditioning
units and vehicles. For products containing ODSs, the [MAJCOM] goal is to eliminate
all purchases as soon as possible. Table 3-1 illustrates projects which will contribute to
AFB achieving the USAF P2 goals while avoiding any negative mission impacts.
Table 3-1 Achieving P2 Goals: ODSs
Action
OPR
Completion Date
Estimated
Completion
Actual
Completion
ODS-1 Replace Current Freon with Low-or No-ODS Substitute
Identify all ODS uses (See ODS-1
narrative)
Determine which systems may be able
to use ODS substitutes
Evaluate potential substitute products
for effectiveness
Discontinue purchase of current
products
Purchase and use substitute products
CEV
CEV
CEV
HazMat Pharmacy
HazMat Pharmacy
Jan 1997
Ongoing
Ongoing
Ongoing
Feb 1996
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 3-1 Achieving P2 Goals: ODSs (continued)
Action
OPR
Completion Date
Estimated
Completion
Actual
Completion
ODS-2 Monitor Equipment Using ODSs
Identify team of two individuals that
will set up a system for tracking ODS-
containing equipment
Maintain the tracking system to
identify the equipment that needs
maintenance
Commit personnel and materials to
conduct routine maintenance and
modifications
CEV
CEV
CEV
Feb 1997
Ongoing
Jun 1997 &
Ongoing
3.2 EPA 17 CHEMICAL PURCHASES
Controlling hazardous materials is essential to a successful P2 plan. This includes
reducing the quantity and types of hazardous wastes, as well as implementing proper
distribution, use, storage, and disposal. The EPA has targeted 17 chemicals and chemical
categories from the list of substances identified under Title III of the Superfund
Amendments and Reauthorization Act for voluntary purchase reduction. USAF has made
the reductions mandatory for all bases as part of the Air Force P2 program. These
chemicals will be tracked and measured against a CY92 baseline. As stated in Section 2,
AFB has achieved a 34 percent cumulative reduction in the purchase of EPA 17
chemicals since the CY92 baseline. To reach the reduction goals, an additional 16
percent reduction must be made. Table 3-2 illustrates management actions for options
essential to reducing the purchase of EPA 17 chemicals in order to reach the Air Force P2
reduction goals.
Table 3-2 Achieving P2 Goals: EPA 17 Chemical Purchases
Action
OPR
Completion Date
Estimated
Completion
Actual
Completion
EPA-1 Solvent Substitution
Identify solvents that are used on the
base that contain EPA 17 chemicals
Determine potential substitutes of
EPA 17 chemicals used on the base
CEV
CEV
Feb 1996
Feb 1996
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 3-2 Achieving P2 Goals: EPA 17 Chemical Purchases (continued)
Action
Access and evaluate substitute
chemicals for use in the different
applications
Begin to phase out EPA 17 chemicals
Sample and analyze resultant waste
for TCLP
OPR
CEV
CEV
CEV
Completion Date
Estimated
Completion
Dec 1996
Feb 1997
May 1997
Actual
Completion
EPA-2 Solvent Recycling
Evaluate the requirements for a
solvent recycling unit
Determine all potential paint shop
users of centralized unit
Identify vendor and allocate system
Allocate transfer devices for shops
that will use the system
Begin implementation of the solvent
recycling for paint shops
CEV
CEV
CEV
CEV
CEV
Oct 1996
Oct 1996
Jan 1997
Feb 1996
Feb 1996
EPA-3 Paint Gun Cleaner
Determine all potential users on
closed-loop paint gun cleaners
Evaluate the applicability of cleaning
system with existing equipment
Evaluate potential vendors and
determine cost for multiple purchase
Purchase and install systems
CEV
CEV
CEV
CEV
Jun 1996
July 1996
Dec 1996
Feb 1996
EPA-4 HVLP Sprayers
Determine all potential users of HVLP
sprayers
Evaluate potential vendors
Develop appropriate parameters for
design and purchase of system
Purchase and install systems
Train shop personnel in new
procedures and monitor use
CEV
CEV
CEV
CEV
CEV
July 1996
July 1996
Dec 1996
Jan 1997
Feb 1996
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 3-2 Achieving P2 Goals: EPA 17 Chemical Purchases (continued)
Action
OPR
EPA-5 Integrated Pest Management
Contact state extension service for
information on IPM plan, base
specific
Access Model Pesticide Reduction
Guide (to be released in Jun 1996)
Evaluate potential for IPM
Train personnel in IPM techniques
CEV
CEV
CEV
CEV
Completion Date
Estimated
Completion
Dec 1996
Jul 1996
Feb 1997
Jun 1997
Actual
Completion
EPA-6 Implement Automated Paint Mixer and Electrostatic Sprayers
Identify automated paint mixer system
and electrostatic sprayers
Identify funding for purchase
Purchase system
Install system
Train employees on proper use
Corrosion Control
CEV
CEV
CEV/Corrosion
Control
CEV/Corrosion
Control
Jun 1996
Sep 1996
Jan 1997
Mar 1997
Jun 1995
3.3 HAZARDOUS WASTE DISPOSAL
Hazardous wastes are most often regulated under the Resource Conservation and
Recovery Act (RCRA) and the Toxic Substance Control Act for polychlorinated biphenyl
waste. RCRA requires that a generator of RCRA hazardous waste certify that a waste
minimization program is in place as part of the biennial report for hazardous waste
generators. The EPA's interim final guidance, published in January 1993, identifies what
is necessary to included in a program in order to comply with certification requirements.
This plan should include efforts undertaken during the year to reduce the volume or
toxicity of wastes generated and changes in the volume and toxicity actually achieved in
comparison to previous years. Efforts listed in the HW section of this plan fulfill the
requirements of RCRA and of the P2 MAP. AFB must reduce hazardous waste by 55
percent to reach the 31 December 2000 goal from the updated CY95 baseline quantity.
Table 3-3 lists those management actions required to implement each additional HW
project and continue to reduce HW generation beyond the Air Force P2 reduction goals
already achieved.
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 3-3 Achieving P2 Goals: Hazardous Waste Disposal
Action
HW-1 Solvent Recycling
Evaluate the requirements for a
solvent recycling unit
Determine all potential paint shop
users of centralized unit
Identify vendor and allocate system
Allocate transfer devices for shops
that will use the system
Begin implementation of the solvent
recycling for paint shops
OPR
CEV
CEV
CEV
CEV
CEV
Completion Date
Estimated
Completion
Oct 1996
Oct 1996
Jan 1997
Actual
Completion
Feb 1996
Feb 1996
HW-2 Solvent Substitution
Identify solvents that are used on the
base that contain EPA 17 chemicals
Determine potential substitutes of
EPA 17 chemicals used on the base
Access and evaluate substitute
chemicals for use (by application)
Begin to phase out EPA 17 chemicals
Sample and analyze resultant waste
for TCLP
HW-3 On-Site Metals Treatment
Identify all shops that could use metal
removal technology
Identify appropriate metal treatment
system for the components and
concentrations in the waste waters
Identify vendor and select metal
treatment system
Possibly conduct treatability study
with vendor support
Identify best treatment technology
Purchase and implement treatment
technology
Identify personnel to operate the
system
CEV
CEV
CEV
CEV
CEV
CEV
CEV
CEV
CEV
CEV
CEV
CEV
Dec 1996
Feb 1997
May 1997
Dec 1996
Feb 1997
April 1997
Aug 1997
Aug 1997
Feb 1996
Feb 1996
Feb 1996
Feb 1996
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 3-3 Achieving P2 Goals: Hazardous Waste Disposal (continued)
Action
OPR
Completion Date
Estimated
Completion
Actual
Completion
HW-4 Filter Analysis
Identify all shops that currently
dispose paint overspray waste as
hazardous
Contract with laboratory for TCLP
analysis of paint booth filters and
paint waste
Establish tracking of filter disposal (as
hazardous waste of municipal solid
waste)
HW-5 Rechargeable Batteries
Determine amount of rechargeable
batteries that require purchase
Determine applicability; test several
flashlights with the rechargeable
batteries on a two month trial period
Purchase necessary batteries and
chargers for use if applicable
CEV
CEV
CEV
CEV
CEV
CEV
July 1996
Dec 1996
Mar 1996
Aug 1996
Dec 1996
Feb 1996
HW-6 Alternative Paint Stripper
Identify alternative paint stripper to
DX-440
Evaluate effectiveness of substitute
chemical
Purchase appropriate chemical
substitute for use
CEV
CEV
CEV
Aug 1996
Oct 1996
Feb 1996
HW-7 Paint Gun Cleaner
Determine all potential users on
closed-loop paint gun cleaners
Evaluate the applicability of cleaning
system with existing equipment
Evaluate potential vendors and
determine cost for multiple purchase
Purchase and install systems
CEV
CEV
CEV
CEV
Jun 1996
July 1996
Dec 1996
Feb 1996
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 3-3 Achieving P2 Goals: Hazardous Waste Disposal (continued)
Action
OPR
Completion Date
Estimated
Completion
Actual
Completion
HW-8 Hazardous Waste Tracking Team
Scope and develop a tracking system
to track hazardous waste generation at
. — AFB
Load information for 1995 and begin
loading 1996 information
Track hazardous waste information
monthly
Begin specified opportunity
assessments for large generators
Identify new generators and increased
generation, determine reduction
alternatives
CEV
CEV
CEV
CEV
CEV
July 1996
Aug 1996
Jan 1997
Ongoing
April 1996
HW-9 HVLP Sprayer
Determine all potential users of HVLP
Sprayers
Evaluate potential vendors
Develop appropriate parameters for
design and purchase of system
Purchase and install systems
Train shop personnel in new
procedures and monitor use
CEV
CEV
CEV
CEV
CEV
July 1996
July 1996
Dec 1996
Jan 1997
Feb 1996
HW-10 Purchase and Implement Automated Paint Mixer and Electrostatic Sprayers
Identify automated paint mixer system
and electrostatic sprayers
Identify funding for purchase
Purchase system
Install system
Train employees on proper use
Corrosion Control
CEV
CEV
CEV/Corrosion
Control
CEV/Corrosion
Control
Jun 1996
Sep 1996
Jan 1997
Mar 1997
Jun 1995
HW-11 Replace Lead Acid Batteries with Gel Cell Batteries
Identify shops using lead acid batteries
Determine applicability to gel cell
batteries
CEV
CEV
Jun 1996
Sep 1996
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 3-3 Achieving P2 Goals: Hazardous Waste Disposal (continued)
Action
Purchase applicable gel cell batteries
to acceptable equipment
Install gel cell batteries
OPR
CEV
CEV
Completion Date
Estimated
Completion
Dec 1996
Feb 1997
Actual
Completion
3.4 MUNICIPAL SOLID WASTE DISPOSAL
MSW is generated from various sources on-base including military family housing
(MFH), non-appropriated fund activities (e.g., auto hobby shop, arts and crafts, etc.),
administrative offices, commercial areas (e.g., commissary and base exchange), industrial
shops, and operational squadrons. Refuse collection at AFB, with the exception of
refuse generated by construction contracts, is managed by CE Maintenance Engineering
with separate contracts for the main base and military family housing (MFH). Resource
Recovery and Recycling Program (RRRP) and the Defense Reutilization and Marketing
Office (DRMO) are the two principal organizations at AFB tasked with managing
the collection and sale of recyclable and reusable materials. Table 3-4 outlines the
actions required to implement each of the MSW projects outlined in the program section
of this report.
Table 3-4 Achieving P2 Goals: Municipal Solid Waste Disposal
Action
OPR
Completion Date
Estimated
Completion
Actual
Completion
MSW-1 Source Reduction Education Program
Design program guidelines to
accomplish MSW education and
communication
Choose personnel for program team
Establish milestones and tracking
criteria for program team
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
Dec 1998
Dec 1998
Dec 1998
MSW-2 Reduce Collection of MFH Grass Clippings
Develop information and strategy for
communicating option to MFH
residents
Choose personnel for program team
Establish milestones and tracking
criteria for program team
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
Dec 1998
Dec 1998
Dec 1998
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 3-4 Achieving P2 Goals: Municipal Solid Waste Disposal (continued)
Action
OPR
Completion Date
Estimated
Completion
Actual
Completion
MSW-3 Point Papers from Waste Generators
Develop required format and schedule
for point papers
Identify party to evaluate papers
Determine facility managers which
participate
Establish evaluation criteria and
implementation timeline
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
Feb 1998
Feb 1998
Feb 1998
Jun 1998
MSW-4 Electric Hand Dryers
Identify number and placement of
dryers
Evaluate potential vendors
Purchase systems and contract
installation
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
Feb 1998
Feb 1998
Feb 1998
MSW-5 Improve Existing Recycling Program
Provide communication and education
materials to promote the program
Choose location most beneficial for
additional receptors
Purchase additional receptors to sort
office / mixed paper
Purchase additional receptors to
collect aluminum cans
Develop monitoring program for
recyclables collected through program
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
Feb 1998
Feb 1998
Feb 1998
Feb 1998
Feb 1998
MSW-6 Wood Waste Recycling Program
Arrange for Golf Course Maintenance
to lease the CE chipper
Coordinate with industrial facilities to
accept processed chips from base
Insure contractors sort C&D wood and
pallets
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
Jun 1998
Sept 1998
Jun 1998
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 3-4 Achieving P2 Goals: Municipal Solid Waste Disposal (continued)
Action
Purchase truck scale to measure wood
waste quantities
Develop system for tracking tonnage
and monitoring disposal of wood
waste
OPR
P2 Subcommittee
P2 Subcommittee
Completion Date
Estimated
Completion
Jun 1998
Jun 1998
Actual
Completion
MSW-7 Yard Waste Composting
Develop program materials for
education and communication on yard
waste composting
Choose source reduction team staff to
implement program
Select and purchase necessary
equipment for composting process
Develop tracking system of
composting benefits to MSW disposal
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
Jul 1998
Jul 1998
Jul 1998
Sept 1998
MSW-8 Mixed Waste Composting
Develop program materials for
education and communication on
mixed waste composting
Choose source reduction team staff to
implement program
Select and purchase necessary
equipment for composting process
Develop tracking system of
composting benefits to MSW disposal
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
Jul 1998
Jul 1998
Jul 1998
Sept 1998
MSW-9 Backyard Composting
Develop program materials for
education and communication on
backyard composting
Choose source reduction team staff to
implement program
Select and purchase bins necessary
composting process
Develop tracking system of
composting benefits to MSW disposal
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
Jul 1998
Jul 1998
Jul 1998
Sept 1998
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
3.5 AFFIRMATIVE PROCUREMENT
Affirmative procurement is the process of procuring products containing recovered
materials. RCRA, as amended, and EO 12873 establish federal requirements for
management of MSW and the procurement of products containing recovered materials.
The EPA has designated the following specific items ("guideline items") containing
recovered materials for procurement:
• Building insulation products
• Cement and concrete containing fly ash
• Paper and paper products
• Retreaded tires
• Lubricating oils
• Ground granule furnace slag
• Engine coolants
• Structural fiberboard
• Laminated paperboard
• Carpet
• Floor tile
• Patio blocks
• Traffic cones
• Traffic barricades
• Playground surfaces
• Running tracks
• Hydraulic mulch
• Yard trimming compost
• Office recycling containers
• Office waste receptacles
• Plastic desktop accessories
• Toner cartridges
• Binders
• Plastic trash bags
The EO requires agencies to review their specifications for these designated items
and to procure materials containing recovered materials whenever possible. Establishing
an affirmative procurement plan is integral to achieving this reduction goal and should
include the following:
• A preference program that establishes open competition between products
containing recycled and non-recycled materials
• A promotion program that actively promotes the desire to buy recycled products
• An annual review and monitoring program that evaluates the success of the
affirmative procurement program
The single option in the area of affirmative procurement is the recommendation that
AFB develop an affirmative procurement program to incorporate the above items. Table
3-5 outlines the actions required to develop the program.
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 3-5 Achieving P2 Goals: Affirmative Procurement
Action
OPR
Completion Date
Estimated
Completion
Actual
Completion
AP-1 Develop Affirmative Procurement Program
Evaluate the current status of
affirmative procurement at AFB
Develop and implement a program to
affirmatively procure 100 percent of
EPA Guideline Items
Track and record progress toward
annual achievement of affirmative
procurement requirements
CEV,
P2 Subcommittee
CEV, P2
Subcommittee,
Logistics
Organizations
Contracting
Dec 1996
Jun 1997
Sep 1997
3.6 ENERGY CONSERVATION
EO 12902 and the Energy Policy Act of 1992 extended the energy conservation goals
of the Federal Energy Management Improvement Act (FEMIA) of 1988. FEMIA had
initially established the goal to reduce energy consumption by 10 percent per square foot
in federal buildings between CY85 and CY95. The new requirements extended the
FEMIA Federal Building Reduction Goal to a required reduction of 20 percent per gross
square foot by 31 December 2000 and 30 percent by 31 December 2005, as measured in
BTUs. AFB has a proactive energy conservation program that is pursuing programs
to accomplish these conservation goals. The Chief of Maintenance Engineering is
responsible for the energy program, meeting Energy Conservation goals, and obtaining
funding for projects.
Currently, AFB is 3 percent above the CY85 energy baseline. To meet their
goals, reductions of 23 percent and 33 percent must be made for CYOO and CY05,
respectively. AFB's Energy Management Program is managed by the Civil Engineer
Squadron's Maintenance Engineering Element. Further information can be obtained from
the Chief, Maintenance Engineering at (xxx) xxx-xxxx.
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 3-6 Achieving P2 Goals: Energy Conservation
Action
Promote base-wide energy
conservation awareness
Present a mock energy bill to
commanders and shop chiefs,
demonstrating requirements
Make items available to base
populace to help conserve
heating/cooling energy
Investigate feasibility of
implementing physical controls on
heating/cooling
Provide incentives for energy
conservation
OPR
CEOE and
P2 Subcommittee
CEOE
CEOE and
P2 Subcommittee
CEOE
P2 Subcommittee
Completion Date
Estimated
Completion
Ongoing
Sept 96
Feb97
Jun97
Sept 97
Actual
Completion
3.7 PESTICIDE MANAGEMENT
AF P2 programs are committed to reducing the release of pollutants into the
environment by minimizing or eliminating harmful discharges to air, land, and water at
the source. A key component in this process for AFB will be the reduction or
elimination of pesticide applications. Table 3-6 outlines the actions needed to implement
the pest management options which are necessary to achieve pollution prevention goals.
Table 3-6 Achieving P2 Goals: Pesticide Management
Action
OPR
Completion Date
Estimated
Completion
Actual
Completion
PM-1 Integrated Pest Management Program
Establish pest management team
Obtain Pest Management Guide from
AFCEE/EP
Develop pest identification
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
Jun 1996
Jul 1996
Sep 1996
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 3-6 Achieving P2 Goals: Pesticide Management (continued)
Action
Establish tolerance levels
Establish pest monitoring program
Establish approved treatment
processes
Track pesticide usage reduction
OPR
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
P2 Subcommittee
Completion Date
Estimated
Completion
Oct 1996
Dec 1996
Apr 1997
July 1997
Actual
Completion
3.8 TRI CHEMICALS
Executive Order 12856 requires all federal agencies to comply with EPCRA and to
commit resources to fulfill the intentions of the Pollution Prevention Act. Section 313 of
EPCRA requires AF installations to submit annual TRI reports by 1 July each year for the
previous calendar year's data. The first report covered 1994 and stands as the baseline by
which the progress toward [MAJCOM] goals will be measured.
[Contractor] compiled baseline TRI (EPCRA) data for AFB in an August 1995
technical report. TRI chemicals for AFB, including the EPA 17 chemicals, are
listed in Appendix C. Table 3.7 lists the actions needed to implement the options
necessary to reduce TRI chemical total releases and off-site transfers in accordance with
reduction goals.
Table 3-7 Achieving P2 Goals: TRI Chemicals
Action
OPR
Completion Date
Estimated
Completion
Actual
Completion
TRI-1 Replace Lead Acid Batteries with Gel Cell
Identify shops that use lead acid
batteries
Determine applicability to gel cell
batteries
Purchase applicable gel cell batteries
to acceptable equipment
Install gel cell batteries
CEV
CEV
CEV
CEV
Jun 1996
Sep 1996
Dec 1996
Feb 1997
TRI-2 Replace All ODS Compounds
Implement ODS-1 and ODS-2
CEV
Feb 1997
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
Table 3-7 Achieving P2 Goals: TRI Chemicals (Continued)
Action
OPR
Completion Date
Estimated
Completion
Actual
Completion
TRI-3 Solvent Substitutes
Identify solvents that are used on the
base that contain EPA 17 chemicals
Determine potential substitutes of
EPA 17 chemicals used on the base
Access and evaluate substitute
chemicals for use in the different
applications
Begin to phase out EPA 17 chemicals
Sample and analyze resultant waste
for TCLP
CEV
CEV
CEV
CEV
CEV
Dec 1996
Feb 1997
May 1997
Feb 1996
Feb 1996
TRI-4 Replace Glycol Ether Containing Materials
Identify the products that contain
Glycol Ether and determine the shops
that the materials are issued
Identify potential substitutes to Glycol
Ether containing materials
Allocate substitutes and test their
applicability to the cleaning processes
Identify and purchase larger quantities
of substitute products for use
CEV
CEV
CEV
CEV
Aug 1996
Dec 1996
Feb 1996
Feb 1996
Appendix C, Pollution Prevention Program Guide
Sample MAP
-------
SAMPLE MAP APPENDIX A: Examples of Project Narratives
PROJECT NUMBER: ODS-1
PROJECT TITLE: Replace Current Freon (and other ODS containing substances)
with Low- or No-ODS Substitutes
FUNDING REQUIREMENT: None
INSTALLATION: —- AFB
Current Process: Some products issued at AFB during CY94 contain ODSs. Equipment used at AFB,
including water coolers, chillers, and air conditioners, use freon. These equipment, in some cases, leak. The
necessitates purchase of freon to replace the freon which is lost. Other ODS containing chemicals used at AFB
include solvents, lubricants, cleaners, insecticides, and sealants. The materials issued at AFB that contain
ODSs are listed in Table ODS-1.1. Table ODS-1.1 identifies the material name and NSN, ODSs contained in the
material, the organization/shop/building that the materials were issued, and the quantity in pounds.
New Process: This option involves identifying and replacing Ozone Depleting Substances (ODSs) with compatible
substitutes that do not contain ODSs. Material substitution of ODS-containing products will help AFB achieve
its ODS reduction goals. There are basically two types of ODS containing materials: 1) cleaning compounds, and 2)
freon for cooling equipment. Table ODS-1.2 lists alternatives to the ODS containing cleaning materials. The base
must evaluate whether these substitutes will be applicable to the current process.
Most products used in conjunction with aircraft or AGE maintenance are designated by TO specifications.
Therefore, before products designated by a TO can be substituted with another product, the substitute product must
first be approved by a single point manager at a designated depot base. TO substitutes may be researched on the
PRO-ACT database system operated by the Air Force Center for Environmental Excellence, Brooks AFB, at (800)
233-4356. PRO-ACT is an environmental literature clearing house that offers free database and literature searches.
POLLUTION PREVENTION GOAL: [MAJCOM] has mandated a goal of eliminating all purchases of ODSs as
soon as possible.
SAVINGS/BENEFITS: Using the issue inventory prepared for the CY94 EPCRA survey at AFB, products
containing ODSs issued through Base Supply, and Medical Logistics, as well as those in the available CEMAS
information, were identified. These products, and the workplaces which they were assigned to, are shown in Table
ODS-1.1. Off-base purchases of ODS containing materials may not be identified on Table ODS-1.1. If strictly
enforced, this option could reduce the ODS purchase by 80%. Therefore, a reduction of roughly 6500 Ibs of ODS
purchases could be realized.
COSTS: In general, costs associated with product substitution will be considered negligible if comparable products
can be obtained. Initially one person would be required to identify ODS substitutions basewide. The cost
associated with this would be approximately $4,000 (or 200 hours). The costs associated with the purchase of
specific alternative materials are presented in Table ODS-1.3.
Addition costs associated with this option could result from required changes or upgrades in process equipment.
IDENTIFIED ALTERNATIVES: Alternatives for major identified ODSs are presented in the Table ODS-1.2.
Appendix C, Pollution Prevention Program Guide Sample MAP - Appendix
-------
Table ODS-1.2
ODS
1,1,1-TCA
CFC-12
HCFC-22
CFC-11
Freon 113
Alternative
Various products are available
depending on application (see list
below)
SUVA- 134
(Freon- 134)
SUVA- 134
(Freon- 134)
SUVA-123a
Various products are available
depending on application (see list
below)
Vendor
Ecolink
1-800-886-8240
Dupont-Fluorochem Lab
1-800-242-4618
Dupont-Fluorochem Lab
1-800-242-4618
Dupont-Fluorochem Lab
1-800-242-4618
Ecolink
1-800-886-8240
a SUVA-123 contains low levels of ODSs, but contains much less than CFC-11.
The most commonly encountered ODSs at AFB were CFC-113 and HCFC-22 (Class II ODS). Suva-134 is an
acceptable alternative for each of these materials.
Any shops using 111-TCA and/ or CFC-113 for cleaning applications should consider one or more of the alternative
materials listed in Table ODS-3 on the desired application. Each of the listed products can be used in place of either
111-TCA or CFC-113. All of the listed products are available through Ecolink. Vendor information is provided
below.
Table ODS-1.3
PRODUCT
ECOLINK 2005
ELECTRON
(aerosol & bulk)
ELECTRON QED
ELECTRON QEDT
MICROPURE CDF
DESCRIPTION
Non-flammable aerosol.
CFC-Free contact cleaner/
electrical solvent.
Non-Aqueous Dielectric
Solvent
Fast drying, non-aqueous (also
available with
terpene=QEDT).
Fast drying, non-aqueous
solvent, (like QED) w/distilled
terpene.
Electronics Grade De-Flux,
Board solvent
PRICE
$60/ gallon
$107 14 oz. aerosol
$157 gallon
$77 15 oz. aerosol
$207 gallon
$237 gallon
$357 gallon
APPLICATIONS
Cleaning electrical contacts
and other critical components
in spot-cleaning applications.
Electrical Maintenance,
Degreaser Motors, Generators,
Hydraulics, brake Cleaner,
Hand Wipe.
Wipe-down or dip tank when
very fast dry, non-aqueous
cleaning is required.
Wipe-down or dip tank when
high solvency, very fast dry,
non-aqueous cleaning is
required.
Printed circuit boards,
microcircuits.
Appendix C, Pollution Prevention Program Guide
Sample MAP - Appendix
-------
Table ODS-1.3 - Cont'd
PRODUCT
PARTS PREP*
POSITRON
VORTEX
VORTEX-NS
DESCRIPTION
Semi-Aqueous Degreaser
Non-Aqueous, Ultra-High
Purity Dielectric solvent.
Water rinsable citrus terpene
blend.
PRICE
$357 gallon
$177 gallon
$227 gallon
$227 gallon
APPLICATIONS
removes carbon, grease, flux,
lubricating oils, and uncured
epoxy resins.
Ultra low non-volatile residue
(NVR), critical cleaning,
electrical maintenance.
Aggressive solvent for
cleaning all organic and
inorganic soils, (grease,
cosmoline, rosin flux). Wipe,
rinse or steam off after use.
Aggressive solvent for
cleaning all organic and
inorganic soils. Non-rinsable,
no surfactant.
* Recommended to replace III-TCA only.
FUND APPROPRIATION: PPP
FEDERAL STOCK NO./CLASS:
INITIATIVE SOURCE: [Contractor name]
APPLICATION TO OTHERS: Industry-wide
VENDORS:
Ecolink
1-800-886-8240
Various ODS alternative materials
Dupont Fluorchem Lab
1-800-242-4618
Suva-123
Suva-134
Appendix C, Pollution Prevention Program Guide
Sample MAP - Appendix
-------
PROJECT NUMBER:
PROJECT TITLE:
EPA-1
Solvent Substitution
FUNDING REQUIREMENT: Nonrecurring
INSTALLATION: —- AFB
Current Process: The shops listed below currently use EPA-17 compound containing solvents for cleaning
purposes. Most of the cleaning applications are for painting operations, while others are for degreasing and grime
removal. In using these solvents for these applications, EPA-17 chemicals are purchased, the volatile chemicals are
released as air emissions, and the resultant contained materials must be disposed as hazardous waste. The shops that
currently use these compounds are listed below.
Shop
Identification
Building
Maintenance
Allied Trades /
Welding
CEMIRT
Fuel System
Maintenance
AGE
Test Fabrication
Shop
Auto Hobby
Shop
Vehicle
Maintenance
84 Test
Fabrication
Shop
Watercraft
Maintenance
Process Code
PTSPO01
ATWCPO01
CEMAB01
NA
AGEFC01
NA
AHSPO01
VHMPO01
84TPO01
WCMPO01
Building
6027
558
1134
316
264
156
934
559
729
5025
Chemical
Thinners -
Acetone, Toluene,
MEK
DX-440
Methylene
Chlonde
MEK
MEK
MEK
MEK
MEK
MEK
Thinners -
Acetone, Toluene,
MEK
Amount
Used
1000
1050
600
66
98
1600
60
420
270
80
Purpose
Painting operation
clean-up
Painting operation
clean-up
Removing carbon
scale from parts
Solvent - cleaning
Solvent - cleaning
Solvent - cleaning
Solvent - cleaning
Painting clean-up
Painting clean-up
Painting operation
clean-up
New Process: The shops identified above could use substitute solvents for conducting their cleaning applications.
Available substitutes for painting operation clean-up include Safe Strip and Prep Rite. These alternatives do not
contain EPA-17 materials. These alternatives are not intended for use as paint thinners. However, they are effective
for cleaning brushes, rollers, and overspray. An alternative to methylene chloride for carbon deposit removal has
also been identified. Rip Tide, a product from Ecolink, has been proven by several other Air Force Bases to provide
clean-up capabilities similar to methylene chloride. Degreasing and grime removal can be achieved with Prep Solv
and Blend 300.
Several types of substitutes and vendors of these materials are available. One vendor, that carries a very diverse
product line is Ecolink (800) 886-8240. The base can discuss their cleaning application, and upon request, Ecolink
Appendix C, Pollution Prevention Program Guide
Sample MAP - Appendix
-------
will send several samples of their product(s) for testing. As a suitable substitute is identified, larger purchases can
then be made.
Shops and suitable substitutes that have been identified are provided in the following:
Shop
Building
Maintenance
Allied Trades /
Welding
CEMIRT
Fuel System
Maintenance
AGE
Test Fabrication
Shop
Auto Hobby
Shop
Vehicle
Maintenance
84 Test
Fabrication
Shop
Watercraft
Maintenance
Chemical
Thinners -
Acetone, Toluene,
MEK
DX-440
Methylene
Chloride
MEK
MEK
MEK
MEK
MEK
MEK
Thinners -
Acetone, Toluene,
MEK
Amount
Used
1000
1050
600
66
98
1600
60
420
270
80
Purpose
Painting operation
clean-up
Painting operation
clean-up
Removing carbon
scale from parts
Solvent - cleaning
Solvent - cleaning
Solvent - cleaning
Solvent - cleaning
Painting operation
clean-up
Painting operation
clean-up
Painting operation
clean-up
Identified
Substitute
Safe Strip or
Prep Rite
Safe Strip or
Prep Rite
Rip Tide
Safe Strip or
Prep Rite
Safe Strip or
Prep Rite
Safe Strip or
Prep Rite
Safe Strip or
Prep Rite
Safe Strip or
Prep Rite
Safe Strip or
Prep Rite
Safe Strip or
Prep Rite
POLLUTION PREVENTION GOAL: The 1992 baseline for EPA-17 chemicals at —- AFB is 37,636 Ibs. In
1994, AFB achieved a 34 percent reduction in the purchase of EPS-17 chemicals from the CY92 baseline. An
additional 16 percent reduction is required to achieve the 31 December 1996 goal of 50 percent. Implementation of
this option is estimated to provide a reduction of 10 percent (approximately 3,500 Ibs) of the baseline procurement.
SAVINGS/BENEFITS: Use of solvents that do not contain EPA-17 chemicals would contribute to AFB's
goal of reduced EPA-17 procurement. The substitute solvent would also reduce air emissions and may reduce
hazardous waste generation.
COSTS: There are no initial investment costs associated with this option. Because the substitute solvents are more
expensive than the thinner currently used this option will also result in an estimated annual additional cost of
$13,560. See the EPA-1 Costs Comparison table for a full breakdown of cost information.
FUND APPROPRIATION: PPP
FEDERAL STOCK NO./CLASS:
INITIATIVE SOURCE: [Contractor Name]
APPLICATION TO OTHERS: Industry-wide
Appendix C, Pollution Prevention Program Guide
Sample MAP - Appendix
-------
VENDORS/ PRODUCTS:
Ecolmk (800)886-8240
Safe Strip - Paint and Resin Solvent
Prep Rite - Paint and Coatings Remover
Prep Solv - Grease and grime
Rip Tide - Cleaning chemical for more difficult residues
Appendix C, Pollution Prevention Program Guide Sample MAP - Appendix
-------
EPA-1 Solvent Substitution Costs Comparison
None
None
Cost Element
DIRECT CAPITAL COSTS
INDIRECT CAPITAL COSTS
OPERATING COSTS
ENV. MANAGEMENT (hours)
THINNER (gallon)
SUBSTITUTE SOLVENT (gallon)
HAZ WASTE DISPOSAL (dram)
ANALYTICAL COSTS
Status Quo Operational
Cost
Unit
Cost
$20.00
$11.00
I $490.00
No. of
Units
40
390
Cost
$0.00
$0.00
$0.00
$0.00
$800.00
$4,290.00
$0.00
$2,450.00
$0.00
EPA-2
Inltal Investment Costs
Unit
Cost
No. of
Units
Cost
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
Diff.
Savings
EPA-2
Annual Operating Costs
Cost
Summary
Unit
Cost
Present
Value
$20.00
$33.00
$490.00
390
1
$200.00
$0.00
$12,870.00
$245.00
$0.00
$600.00
($8,580.00)
$1,960.00
$0.00
1.5
0.0
94.9
3.6
0.0
$1,596.45
$0.00
$47,414.43
$1,955.65
$1,000.00
TOTAL COSTS/SAVINGS
$3,760.00
$0.00
PAYBACK PERIOD (YEARS):
NET PRESENT VALUE OF BENEFITS AND INVESTMENT:
($26,830.00)
$13,560.00 ($6,020.00)
100
$51,966.52
NOTE: () INDICATE NEGATIVE VALUE
Appendix C, Pollution Prevention Program Guide
Sample MAP - Appendix
-------
PROJECT NUMBER:
PROJECT TITLE:
FUNDING REQUIREMENT:
INSTALLATION:
HW-1
Solvent Recycling
Nonrecurring
—-. AFB
Current Process: Paint and clean-up solvents represent a significant quantity of hazardous waste generated at
AFB. The paint and clean-up solvents at several shops are drummed and disposed as hazardous waste at several
AFB shops. The shops that dispose their clean-up solvents are listed below.
Shop
Building
Maintenance
Allied Trades /
Welding
Corrosion
Control
84th Test
Fabrication
Shop
Auto Hobby
Shop
Process Code
PTSPO01
ATWCPO01
CRCPO01
84TPO01
AHSPO01
Building
6027
558
315
156
934
Solvents
Thinners -
Acetone, Toluene,
MEK
Thinners -
Acetone, Toluene,
MEK
Thinners -
Acetone, Toluene,
MEK
Thinners -
Acetone, Toluene,
MEK
Thinners -
Acetone, Toluene,
MEK
Haz Waste
(Ibs)
1000
800
600
1250
400
Purpose
Painting operation
clean-up
Painting operation
clean-up
Painting operation
clean-up
Painting operation
clean-up
Painting operation
clean-up (separate
from customer
painting)
New Process: Under this option, a solvent distillation system would be used to reclaim paint solvents from solvent
waste. The reclaimed solvents would be used for equipment cleaning. Use of reclaimed solvents would reduce the
amount of hazardous waste generated. Typically up to ninety percent of paint and thinner wastes can be reclaimed
as thinner. A solvent distillation system is currently in use at several shops at AFB, including Corrosion
Control. Corrosion Control, however, needs a larger recycling system in order to make better use of their solvent
recycling system.
A centralized distillation system can be used for the paint wastes. A central location (to these shops) could be
identified by the base. A larger distillation system (for over 5000 gallons/year) could be purchased to recycle the
paint solvent wastes from these and other shops. In addition, a civilian or military individual would need to be
identified to operate the system. Based on the total quantity of material requiring reclaiming, one individual would
operate the system approximately sixty hours per month.
This type of centralized system is used very effectively at other Air Force Bases. For example, at Robins AFB
(Warner Robins, GA) several distillation systems are used to recycle solvents from different applications. Robins
AFB has been operating these systems for nearly 10 years.
The individual savings in EPA-17 materials are provided in the following:
Appendix C, Pollution Prevention Program Guide
Sample MAP - Appendix
-------
Shop
Building
Maintenance
Allied Trades /
Welding
Corrosion
Control
84th Test
Fabrication
Shop
Auto Hobby
Shop
Building
6027
558
315
156
934
Chemicals
Thinners - Acetone,
Toluene, MEK
Thinners - Acetone,
Toluene, MEK
Thinners - Acetone,
Toluene, MEK
Thinners - Acetone,
Toluene, MEK
Thinners - Acetone,
Toluene, MEK
Amount
Potentially
Saved (Ibs)
900
720
540
1125
360
% of Baseline
2.3
2.5
3.3
3.7
<1
POLLUTION PREVENTION GOAL: New hazardous waste reduction goals and pollution prevention metrics
have been set by the base based on [MAJCOM] guidance dated 6 February 1996. The new metrics begin with a
1995 baseline of 142,000 Ibs and set incremental goals for reductions each year until 2000. The reduction goals for
hazardous waste are as follows: 11 percent by CY96, 22 percent by CY97, 33 percent by CY98, 44 percent by
CY99, and 55 percent by CYOO. This option is estimated to achieve a reduction of nearly 3 percent (3,700 Ibs) of
the baseline generation.
SAVINGS/BENEFITS: A significant quantity of solvent waste would be saved through this option. Savings in
disposal and procurement costs would generate a net revenue savings for the base in addition to reducing hazardous
waste generation. Implementation of this option will provide an environmental benefit by reducing the amount of
purchased products with EPA-17 materials.
COSTS: There are capital and operational costs associated with this option. The capital cost for a large distillation
system would be approximately $17,000 for the system, shipping, and set-up. The other primary cost for each shop
will be associated with purchase and installation of a drum transfer system. The estimated cost for the drum transfer
systems are $1000 each. Estimated annual savings are $9,800 basewide. See the HW-1 Costs Comparison table for
a full breakdown of cost information.
FUND APPROPRIATION: PPP
FEDERAL STOCK NO./CLASS:
INITIATIVE SOURCE: [Contractor name]
APPLICATION TO OTHERS: Industry-wide
VENDORS/ PRODUCTS:
Finish Thompson, Inc. Renzmann Solvent Distillation Hoyt Corporation
814-455-4478 516-231-3030 800-343-9411
Appendix C, Pollution Prevention Program Guide
Sample MAP - Appendix
-------
HW-1 Solvent Recycling: Costs Comparison
Cost Element
DIRECT CAPITAL COSTS
PROCESS EQUIPMENT
Status Quo Operational EPA-3
Cost
Unit
Cost
UTILITY CONNECTIONS/SYSTEMS
SITE PREPARATION
INDIRECT CAPITAL COSTS
None
OPERATING COSTS
ELECTRICITY (Kw-hr)
WATER (1000 gal)
ENV. MANAGEMENT (hours)
THINNER (gallon)
HAZ WASTE DISPOSAL (dram)
LABOR
TOTAL COSTS/SAVINGS
$0.05
$1.92
$20.00
$11.00
$490.00
$10.00
No. of
Units
200
900
15
400
Cost
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$4,000.00
$7,350.00
$7,350.00
$4,000.00
$10,450.00
Initial Investment Costs
Unit
Cost
$18,000.00
$1,000.00
$500.00
$0.05
$1.92
$10.00
PAYBACK PERIOD (YEARS):
NET PRESENT VALUE OF BENEFITS AND INVESTMENT:
No. of
Units
1
1
1
1.99
$58,831.19
Cost
$18,000.00
$1,000.00
$500.00
$0.00
$0.00
$0.00
$0.00
$19,500.00
Diff.
Savings
(2,000)
(500)
(250)
0
EPA-3 || Cost
Annual Operating Costs Comparison
Unit
Cost
No. of
Units
Cost
$0.00
$0.00
$0.00
Diff.
Savings
%of
Cost
Present
Value
^^^™
$0.00
$0.00
$0.00
$0.00
12.6
0.7
0.4
0.0
$18,000.00
$1,000.00
$500.00
$0.00
^^•^•••^•^•M
0
0
0
0
0
(19,500)
$0.05
$1.92
$20.00
$11.00
$490.00
$10.00
11,000
40
100
150
4.00
920
$528.00
$76.80
$2,000.00
$1,650.00
$1,960.00
($5,200.00)
$15,436.80
($550.00)
($76.80)
$2,000.00
$8,250.00
$5,390.00
($5,200.00)
$9,813.20
3.1
0.4
11.2
9.2
11.0
51.5
100
$4,390.23
$613.04
$15,964.45
$13,170.00
$15,645.17
$73,436.49
$142,720.05
Appendix C, Pollution Prevention Program Guide
Sample MAP - Appendix
-------
PROJECT NUMBER: MSW-1
PROJECT TITLE: Source Reduction Education Program
FUNDING REQUIREMENT: Recurring
INSTALLATION: —- AFB
Current Process: Refuse collection at AFB, with the exception of refuse generated by construction contracts,
is managed by CE Maintenance Engineering with separate contracts for the main base and military family housing
(MFH). Contractors collect garbage from dumpsters located on the base. Several dumpsters collect bulk waste
items with service costs the same as for garbage. CE Grounds maintains AFB's grounds including the airfield,
flight line, general office areas, and MFH. Also Grounds is responsible for fallen limbs and trees and roadside
wastes. Golf Course Maintenance maintains the Golf Course. The tree waste from the course is burned one
or two times annually under state permit. Resource Recovery and Recycling Program (RRRP) and the Defense
Reutilization and Marketing Office (DRMO) are the two principal organizations at AFB tasked with managing
the collection and sale of recyclable and reusable materials. At present, no formal source reduction program exists
at —- AFB.
New Process: A comprehensive source reduction education program may reduce the amount of MSW generated at
AFB up to 5 percent. Source reduction would be initiated and promoted through educational and informational
exchanges on the base. Such exchanges would be initiated by a waste reduction program staff. The main method of
promoting a source reduction program would include distributing educational materials designed to give consumers
specific recommendations on how to use source reduction to reduce MSW.
At a residential level, the waste reduction program staff would inform base residents how to adopt less wasteful
practices at home by giving guidelines on purchasing decisions and waste recycling and prevention. Billboards
would be placed at base gates and base shopping areas to raise awareness of MSW reduction goals, the reduction
hierarchy (source reduction, recycling, composting), and to track progress in solid waste disposed. Education
programs would be used to increase consumer's demand for source reduction practices. For example, stimulating
the market for bulk food purchases would eliminate packaging and individual container needs.
POLLUTION PREVENTION GOAL: New municipal solid waste reduction goals and pollution prevention
metrics have been set by the base based on [MAJCOM] guidance dated 6 February 1996. The new metrics begin
with a 1995 baseline and set incremental goals for reductions each year until 2000. The reduction goals for MSW
are as follows: 6 percent by CY96, 23 percent by CY97, 30 percent by CY98, 39 percent by CY99, and 45 percent
by CYOO. This option is estimated to reduce solid waste by 5 percent of the baseline quantity.
SAVINGS/BENEFITS: The source reduction program would result in savings from avoiding the cost of disposal.
It is estimated the program would divert 233 tons from landfill disposal at a cost of $25/ton for a savings of $5,813.
COSTS: No capital costs are associated with the development of a source reduction program. Operation and
Maintenance costs are estimated at $13,400/yr for salary of one half-time staff member ($10,400) and a program
budget for educational materials of $3,000. However with the diverted waste from landfill disposal, the total
estimated annual cost is $7,588 with a cost of $33 per ton of MSW diverted. Table MSW-1 provides a cost
breakdown for this option.
FUND APPROPRIATION: PPP
FEDERAL STOCK NO./CLASS:
INITIATIVE SOURCE: Parsons Engineering-Science
APPLICATION TO OTHERS: Limited
Appendix C, Pollution Prevention Program Guide Sample MAP - Appendix
-------
MSW-1 Source Reduction Education
Program
Item
Capital Equipment
None
Subtotal
Operation and Maintenance
Staff (1 person, half time)
Educational Materials
Subtotal
Cost Avoidance
Disposal
Subtotal
Net Annual Cost
Tons of MSW Diverted
Cost per ton of MSW Diverted2
Unit Cost
$10.00 /hr
$3,000.00 /year
$25.00 /ton
Quantit
y
1040 hours
1 unit
233 tons
Estimated
Cost1
$0
$0
$10,400
$3,000
$13,400
($5,813)
($5,813)
$7,588
233
$33
1 Parentheses indicate cost savings. Savings on
disposal cost is computed only on
tons currently disposed off base (that is,
does not include tons disposed on base).
2 Does not include capital cost.
Appendix C, Pollution Prevention Program Guide
Sample MAP - Appendix
-------
PROJECT NUMBER: AP-1
PROJECT TITLE: Develop Affirmative Procurement Program
FUNDING REQUIREMENT: Recurring
INSTALLATION: —- AFB
Current Process: Currently, AFB has not implemented an affirmative procurement program or a system that
routinely monitors the procurement of EPA Guideline Items.
New Process: The new process will assist AFB in meeting affirmative procurement goals by outlining actions
required to procure EPA Guideline Items and develop a tracking system to monitor progress toward these goals.
Dedicated attention to the affirmative procurement program will allow AFB to achieve the goal of 100 percent
of all EPA Guideline Items purchased each year contain recycled materials.
POLLUTION PREVENTION GOAL: AFB has not met its affirmative procurement goal of ensuring that
100 percent of all EPA Guideline Items purchased each year contain recycled materials meeting EPA guideline
standards.
SAVINGS/BENEFITS: In order to determine savings, benefits, and costs resulting from the implementation of
this project, the following should be determined on a quarterly basis by both the Civil Engineering and the Logistics
Squadron, Supply Flight:
• Identify the number of stock numbers and quantity of procured recycled paper products, retread tires, recycled building
thermal insulation, cement containing fly ash, and re-refined lubricating oil;
• Identify the total number of stock numbers and quantity of all procured paper products, tires, building insulation,
cement, and lubricating oil;
• Identify the amount of recycled building insulation and cement containing fly ash used by Base contractors; and
• Identify the total amount of building insulation and cement used by Base contractors.
COSTS: Costs associated with this option cannot be quantified based on the data currently available. In order to
determine the true costs and benefits for this project, the following information should be determined:
• The unit costs and quantities procured of currently used non-recycled products and the associated substitute materials;
and
• The recurring costs associated with the labor and materials needed to track the information listed above.
FUND APPROPRIATION:
FEDERAL STOCK NO./CLASS:
INITIATIVE SOURCE: Parsons Engineering-Science
APPLICATION TO OTHERS: Limited
Appendix C, Pollution Prevention Program Guide Sample MAP - Appendix
-------
PROJECT NUMBER: PM-1
PROJECT TITLE: Integrated Pest Management Program
FUNDING REQUIREMENT: Recurring
INSTALLATION: —- AFB
Current Process: Many of the pesticide activities performed at AFB include alternative pest management
techniques. Examples of these activities include roach baiting and glue traps. However, a significant portion of the
pest management activities include spray pesticides. Pesticides are generally dissolved in a solvent and applied with
either vehicle or backpack sprayers.
New Process: Development of a full integrated pest management program is recommended for AFB. The
major steps involved in developing and implementing an integrated pest management program are presented below.
The overall goal of integrated pest management is to reduce pesticide usage through a variety of techniques
designed to minimize the requirements for pesticide usage while maximize the effectiveness of those pesticides
which are used.
Development and implementation of an integrated pest management program includes the following processes:
• Establish a Pest Management Team
A Pest Management Team would be established for AFB. The team would include members from each shop
that use pesticides as well as representatives of the P2 subcommittee. The Pest Management Team would be
responsible for tracking and maintaining the Integrated Pest Management Program. Records of pesticide usage and
reductions would be maintained by the team. Effective usage reduction techniques and problem areas would be
identified. The team would also be responsible for identifying and maintaining current integrated pest
management/pesticide minimization techniques for the base.
• Pest Identification
Awareness of which organisms inhabiting base grounds are true pests is an important step in the Integrated Pest
Management Program. Most of the organisms which are commonly found cause little or no damage or serve
beneficial roles. Only a few of the species are actually plant feeding or nuisance pests. Because many of the pests
and nonpests are similar, accurate identification is essential to an effective Integrated Pest Management Program.
Major pest species include aphids, lace bugs, spider mites, tent caterpillars, webworms, roaches, and certain beetles.
• Establish Tolerance Levels
Tolerance levels for identified pests should be established. Treatment should not be applied when pests are below
the tolerance levels and should be discontinued when population are returned to below the tolerance levels. It is
important to remember that most pests may exist at limited population levels without representing any threat.
Eradication attempts, however, can lead to reduction of the natural enemies of pests, pesticide resistance, and
pesticide overuse.
Tolerance levels should be established using a variety of criteria. These criteria should include the pest type,
species, abundance, and life stage, as well as the vigor and value of the plant forms that they threaten. Effectiveness
and costs of pesticide usage should also be considered.
The tolerance levels should provide effective guidelines for pesticide usage, but should not be considered strict
rules. Each application of pesticides should be considered individually.
• Establish Pest Monitoring
Effective pest monitoring is a key to a successful Integrated Pest Management Program. Early detection of pests
can allow quick treatment when populations reach tolerance levels. This strategy will allow the pest population to
be maintained under control with a minimum of both pesticide usage and landscape damage.
Pest monitoring should include detailed record keeping. Well maintained records will allow the Integrated Pest
Management Team to identify key problem pests, problem regions, and seasonal patterns in pest populations.
Appendix C, Pollution Prevention Program Guide Sample MAP - Appendix
-------
There are several techniques available for pest monitoring. These techniques include monitoring turf and landscape,
bird and animal feeding, and physical evidence of pests as well as insect sampling. Each of these techniques should
be implemented in the monitoring program.
Turf monitoring should include awareness of symptoms of pest damage. If landscape is observed to be deteriorated,
further investigation should be used to confirm the exact cause of the damage. Recognition of other possible
sources of damage is important. Alternative causes include heat or drought stress, disease, chemical damage,
nutritional deficiencies or other problems.
Physical evidence includes skeletonized leaves, fecal pellets, sawdust-like debris, stem tunneling, silken tubes
and/or webbing.
A variety of insect sampling techniques are available. Because no one technique is effective for all pest insects, the
sampling program should included varied sampling strategies.
Insect sampling strategies include:
Disclosing Solution - A disclosing solution is used to flush out insects. Either two to four tablespoons of
liquid dish washing soap or one tablespoon of one percent pyrethrins should be added to two gallons of water and
poured over one square meter (1.2 square yards) of turf. Insects will come to the surface within five to ten minutes.
They can then be collected, identified, and counted. This technique is effective for such insects as webworms, army
worms, bill bugs, and mole crickets.
Flotation - This technique takes advantage of the fact that many insects float in water. Insert a metal
cylinder about an inch into the ground. The cylinder should be around eight to nine inches in diameter. A coffee
can with both ends cut off is suitable. Fill the cylinder with water and maintain the water level well above the soil
surface for three to five minutes. Insects which float to the surface can be easily collected and identified. As an
alternative, a large soil core can be collected with a golf course cup cutter or similar tool and placed in a bucket of
water.
Soil Examination - For insects which can not be observed by the above methods, direct examination is
required. The simplest method is to cut away three sides of a square into the ground with a knife or shovel and peel
back the sod. It is important to examine the entire root zone. The process should be repeated several times to assure
representative population levels.
A soil core can also be collected and examined. If the soil is replaced in the hole and the sod cap replaced, followed
by irrigation, the turf damage can be minimized.
Traps - A variety of traps using lights, pheromones, and food scents can be used to monitor insect levels.
Other Methods - Many other methods of monitoring pests may also be identified. Determining exactly
which methods are the most effective for AFB would be the responsibility of the Integrated Pest Management
Team.
• Establish Treatment Processes
Alternative treatment process are also important to the Integrated Pest Management strategy. Available techniques
include Cultural Methods, Biological Control, and lastly Pesticides.
Cultural Methods of pest management include selection of turfs which tend to attract a minimum of pests or are pest
resistant. Turfs which are selected should be maintained effectively. Healthy plants are most able to withstand
pests at higher levels with minimal damage.
Biological Pest management is a developing technique. Microorganisms which are harmful to pests are used to
control populations. This strategy is effective for treatment without damaging landscape or the environment.
However, there are drawbacks including storage and distribution. Biological controls are generally most effective
on areas where relatively high pest levels can be tolerated.
At some point pesticide application becomes necessary. But integrated pest management strategy should still be
included at this time. Pesticides should be applied only in the limited areas which are identified as problematic.
Application of pesticides should be used at times when the life cycle of the pests make them the most susceptible.
Appendix C, Pollution Prevention Program Guide Sample MAP - Appendix
-------
Use of a small amount of pesticide during an early vulnerable stage of development can prevent the need for larger
applications later. Knowledge of the target pests and their life cycles will allow effective use of this strategy.
Application technique is also important. When treating turf the lawn should be mowed first, if possible. In
addition, the turf should be watered before application to drive insects to the surface. Each of these activities will
increase the effectiveness of the applied pesticide. Irrigation of the area after application will help protect the turf
and other animals from exposure. Always read labels and follow all pesticide instructions completely. Never mix
pesticides unless the instructions say to do so.
• New Guidance
Currently AFCEE/EP is developing a Model Pesticide Reduction Guide in cooperation with AFCESA/CEO due to
be released in June 1996. AFB should access this guide and identify applications to the base's pest management
program.
POLLUTION PREVENTION GOAL: The CY93 baseline for pesticide usage is 9,636 Ibs. The pollution
prevention goal is a reduction of total active ingredients of 50 percent by CYOO. The CY94 usage of pesticides was
9,259 Ibs, an decrease of 377 Ibs from the baseline. A reduction of 4,441 Ibs is required to meet the CYOO goal.
This quantity represents 46 percent of the baseline usage. This option is estimated to achieve significant reductions
in pesticide usage reduction. Dedicated commitment to this program should allow AFB to achieve or exceed
the CYOO goal.
SAVINGS/BENEFITS: This program is capable of achieving significant reductions in pesticide usage levels. A
dedicated effort to maximized integrated pest management should provide steady reductions in the amount of
pesticides used. If fully implemented, this option should achieve a reduction of at least the 46 percent required to
meet the P2 goal by CYOO.
COSTS: The primary costs associated with this option are labor. Initial establishment of the Integrated Pest
Management Team, including database set-up, is estimated to require 320 hours (4 individuals for 2 weeks), at a
cost of $6400. Maintenance of the program is estimated to require 448 hours per year (2 individuals for 8 hours
every other week plus quarterly meetings of 4 individuals for 2 hours). A budget of $1000 per year for testing and
materials could also be required. The total annual costs are estimated to be $9,960.
FUND APPROPRIATION: PPP
FEDERAL STOCK NO./CLASS:
INITIATIVE SOURCE: [Contractor Name]
APPLICATION TO OTHERS: Industry Wide
Appendix C, Pollution Prevention Program Guide Sample MAP - Appendix
-------
PROJECT NUMBER: TRI-1
PROJECT TITLE: Replace Lead Acid Batteries with Gel Cell Batteries
FUNDING REQUIREMENT: Recurring
INSTALLATION: —- AFB
Current Process: Lead acid batteries are used by many of the shops at AFB. When the batteries are drained
they are taken to the Electro/Environmental Shop for servicing. The sulfuric acid is drained from the batteries and
neutralized with sodium bicarbonate in water and then discharged to the sanitary sewer. If the batteries can be
recharged, they are filled with fresh sulfuric acid and returned to service. If the batteries are dead, they are disposed
to DRMO as hazardous waste.
Sulfuric Acid is a TRI chemical.
New Process: Gell Cell batteries can be used to replace conventional lead acid batteries. Approximately 3000 Ibs
of lead acid batteries are purchased and disposed each year at AFB. Under this option, the HazMat Pharmacy
Administrator can identify the shops that currently purchase lead-acid batteries and determine those that can be
replaced with Gel Cell batteries. Gel Cell batteries are fully enclosed and last several lifetimes longer than
conventional lead-acid batteries. Therefore, purchase of sulfuric acid is not warranted and excessive disposal is
avoided. Gel Cell batteries do not contribute to TRI releases or off-site transfers. Gel Cell batteries do, however,
contain some hazardous metals.
POLLUTION PREVENTION GOAL: The CY94 baseline for TRI chemicals is 16,499 pounds. The pollution
prevention goal is a reduction of TRI chemicals by 50 percent by CY99. A reduction of 8,249.5 pounds is required
to meet the CY99 goal. Replacing the conventional lead-acid batteries with Gel Cell batteries is estimated to
achieve a reduction of 3 percent (5,000 Ibs) of the baseline generation.
SAVINGS/BENEFITS: The Gel Cell batteries cost more than the lead-acid batteries. However, they are
maintenance free (as claimed by current users at other bases (Maxwell AFB) and vendors). The reduced labor
associated with these batteries will provide economic savings exceeding the increases material costs. Estimated
annual savings are $58,000. A summary of economic estimates is presented in the TRI-1 Cost Comparison table.
COSTS: No capital costs are associated with this program. The primary cost for this program is the cost of Gel
Cell batteries. Labor of one hour per Gel Cell battery is assumed in the TRI-1 Cost Comparison table. Actual labor
required to implement this option should be lower than this estimate.
FUND APPROPRIATION: PPP
FEDERAL STOCK NO./CLASS:
INITIATIVE SOURCE: [Contractor Name]
APPLICATION TO OTHERS: Limited
VENDORS/ PRODUCTS:
Power Sonic
(415)364-5001
Concorde Battery
(818)813-1234
Appendix C, Pollution Prevention Program Guide Sample MAP - Appendix
-------
TRI-1 Replace Lead Acid Batteries with Gel Cell Batteries: Cost Comparison
Cost Element
DIRECT CAPITAL COSTS
None
INDIRECT CAPITAL COSTS
None
OPERATING COSTS
LEAD ACID BATTERIES
HAZARDOUS WASTE DISPOSAL
SODIUM BICARBONATE (50
pound)
SULFURIC ACID (5 gal)
GEL CELL BATTERIES
HW Manager Labor
LABOR
Status Quo Operational
Cost
Unit
Cost
$61.00
$0.80
$10.00
$15.00
$20.00
$10.00
No. of
Units
50
3,000
24
20
40
200
Cost
$3,050.00
$2,400.00
$240.00
$300.00
$0.00
$800.00
$2,000.00
HW-8
Initial Investment Costs
Unit
Cost
No. of
Units
Cost
$0.00
$0.00
$0.00
$0.00
Diff.
Savings
HW-8 ||
Annual Operating Costs
Unit
Cost
No. of
Units
TOTAL COSTS/SAVINGS
$6,390.00
PAYBACK PERIOD (YEARS):
NET PRESENT VALUE OF BENEFITS AND INVESTMENT:
$0.00
0.00
$5,526.40
NOTE: () INDICATE NEGATIVE VALUE
Appendix C, Pollution Prevention Program Guide
Sample MAP - Appendix
-------
SAMPLE MAP APPENDIX B: Hazardous Waste Generation
1994 Hazardous Wastes Shipped
Waste Description
Process Description
Weight (Ibs)
Mercury
Alkaline Batteries
Lead
Mercury Batteries
Nickel Cadmium Batteries
Sulfuric/Chromic Acid Solution
Waste Batteries, Wet Acid
Waste Sulfuric Acid, Spent
Methylene Chloride, Isopropyl Alcohol
Monoethanolamine (Cleaning Liquid)
Petroleum Distillates
Xylene / MEK
Xylene Isopropanol
Xylene, MEK
Waste Isopropanol
Benzene, Aliphatic Hydrocarbons
Xylene, Paint Residue
Benzene, Ethyl Benzene
Lead, Chromium
Benzene, MEK
Benzene-Chloroform
Chromium
Chromium
Cyanide Wastes
Hazardous Waste Liquid
Lead /Chromium
Methylene Chloride, 1,1,1 Trichloroethane
Petroleum Naptha
Propane / Isobutane
Sodium Hydroxide, Hydroxy Benzole Acid
Sodium Hydroxide, Sodium Bromide
Toluene Naphtha
Waste Aerosol
Waste Compressed Gas
Waste Flammable Liquid
Waste Sodium Hydroxide
Waste Trichloroisocyanuric Acid, Dry
Waste Article Explosive
Waste Booster, Explosive
Waste Cartridge for Weapons, Blank
Waste Cartridges, for Weapons, Inert Projectile
Waste Cartridges, Power Device
Aircraft Maintenance & Spills 500
Batteries: Maintenance Operations 1,500
Batteries: Maintenance Operations 2,500
Batteries: Maintenance Operations 500
Batteries: Maintenance Operations 1,850
Batteries: Maintenance Operations 800
Batteries: Maintenance Operations 3,000
Batteries: Maintenance Operations 300
Degreasing / Cleaning Solvents 1,400
Degreasing / Cleaning Solvents 180
Degreasing / Cleaning Solvents 1,200
Degreasing / Cleaning Solvents 4,800
Degreasing / Cleaning Solvents 200
Degreasing / Cleaning Solvents 2,550
Degreasing / Cleaning sovents 200
Degreasing / Stoddard Solvents 7,095
Degreasing: Small Arms Cleaning 300
Gas Fuel Filters 2,900
Gas Mask Filters 4,005
Miscellaneous Processes 800
Miscellaneous Processes 2,400
Miscellaneous Processes 1,200
Miscellaneous Processes 1,500
Miscellaneous Processes 200
Miscellaneous Processes 200
Miscellaneous Processes 2,100
Miscellaneous Processes 200
Miscellaneous Processes 1,027
Miscellaneous Processes 1,500
Miscellaneous Processes 200
Miscellaneous Processes 1,200
Miscellaneous Processes 2,500
Miscellaneous Processes 1,200
Miscellaneous Processes 290
Miscellaneous Processes 100
Miscellaneous Processes 100
Miscellaneous Processes 40
Munitions & Explosives Handiling <1
Munitions & Explosives Handiling 1,500
Munitions & Explosives Handiling <5
Munitions & Explosives Handiling 140
Munitions & Explosives Handiling 20
Appendix C, Pollution Prevention Program Guide
Sample MAP - Appendix
-------
Waste Cartridges, Power Device Munitions & Explosives Handiling <1
Waste Cartriges for Weapons, Inert Projectile Munitions & Explosives Handiling <1
Waste Flares, Aerial Munitions & Explosives Handiling 10
Waste Igniters Munitions & Explosives Handiling <1
Waste, Rocket Motor Munitions & Explosives Handiling 630
Toluene, Xylene Painting Operations 3,960
Toluene, Xylene, Paint Residue Painting Operations 24,480
Waste Paint Painting Operations 1,380
MEK, Cadmium Painting Operations: Paint Booth 19,400
Benzene, Xylene Petroleum / Hydrocarbon Spills 8,830
Silver Photo / X-Ray Processing Waste 6,500
Cadmium, Chromium Sand Blasting Grit (Bead) 800
Appendix C, Pollution Prevention Program Guide Sample MAP - Appendix
-------
SAMPLE MAP APPENDIX C: EPCRA Section 313 Chemicals
CAS#
Total Issued
Quantity (Ibs)
Non-Exempt
Quantity (Ibs)
1,1,1-Trichloroethane (Methyl chloroform)
1 ,2,4 - Trimethylbenzene
1 ,2-Butylene oxide
1 ,2-Dichloroethylene
1 ,4-Dioxane
2,4-D [Acetic acid, (2,4-dichloro-phenoxy)-]
2,4-Dinitrotoluene
4,4' Isopropylidenediphenol
Acetaldehyde
Acetone
Acetonitrile
Acrylamide
alpha-Naphthylamine
Aluminum (fume or dust)
Aluminum oxide (fibrous form)
Ammonia
Ammonium nitrate (solution)
Ammonium sulfate (solution)
Antimony
Antimony Compounds
Arsenic
Asbestos (friable)
Barium
Barium Compounds
Benzene
beta-Naphthylamine
Bromochlorodifluoromethane (Halon 1211)
Cadmium
Cadmium Compounds
Carbon tetrachloride
Chlorine
Chlorodifluoromethane (HCFC-22)
Chromium
Chromium Compounds
Cobalt
Cobalt Compounds
Copper
Copper Compounds
Cumene hydroperoxide
Cyanide Compounds
Cyclohexane
Di(2-ethylhexyl) phthalate (DEHP)
Dibutyl phthalate
Dichlorodifluoromethane (CFC-12)
Dichloromethane (Methylene chloride)
Epichlorohydrin
71-55-6
95-63-6
106-88-7
540-59-0
123-91-1
94-75-7
121-14-2
80-05-7
75-07-0
67-64-1
75-05-8
79-06-1
134-32-7
7429-90-5
1344-28-1
7664-41-7
6484-52-2
7783-20-2
7440-36-0
N010
7440-38-2
1332-21-4
7440-39-3
N040
71-43-2
91-59-8
353-95-3
7440-43-9
N078
56-23-5
7782-50-5
75-45-6
7740-47-3
N090
7740-48-4
N096
7440-50-8
N100
80-15-9
N106
110-82-7
117-81-7
84-74-2
75-71-8
75-09-2
106-89-8
991.75
10.64
0.08
0.00
0.54
12.75
0.05
0.18
0.02
1,731.55
166.00
4.96
0.03
6.02
7.50
6.50
1.10
88.02
68.26
10.39
1.79
5.50
1.67
110.51
2,388,983.93
0.03
29.70
256.64
30.75
0.00
22865.5
5,070.34
1.67
260.02
316.37
3.86
3.84
1.39
0.18
1,680.85
2,899,692.70
2.11
0.12
6.34
955.88
0.00
947.51
7.24
0.08
0.00
0.54
0.00
0.00
0.18
0.00
73.98
0.00
0.00
0.03
2.25
0.00
3.68
0.00
0.00
0.00
4.73
0.00
5.50
0.00
1.56
7,186.72
0.03
29.70
0.00
0.00
0.00
16,000.00
142.03
0.00
5.53
0.00
0.00
3.55
1.39
0.00
24.56
8,994.79
0.00
0.00
6.34
178.75
0.00
Appendix C, Pollution Prevention Program Guide
Sample MAP - Appendix
-------
Ethylbenzene
Ethylene glycol
Formaldehyde
Freon 1 1 3 [Ethane, 1 , 1 ,2-trichloro- 1 ,2,2
Glycol Ethers
Hydrochloric Acid
Hydrogen fluoride
Hydro quinone
Isopropyl alcohol (mfg-strong acide process)
Lead
Lead Compounds
m-Xylene
Manganese
Manganese Compounds
Mercury
Mercury Compounds
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl ter-butyl ether
n-Butyl alcohol
Nickel
Nickel Compounds
Nitric acid
Nitrilotriacetic acid
Nitorbenzene
o-Dinitrobenzene
Pentachloroethane
Phenol
Phosphoric acid
Phthalic anhydride
Propoxur [Phenol, 2-(l-methylethoxy...
Propylene oxide
Saccharin (manufacturing)
sec-Butyl alcohol
Silver
Styrene
Sulfuric Acid
tert-Butyl alcohol
Tetrachloroethylene (Perchloroethylene)
Toluene
Trichlorofluoromethane (CFC-11)
Vinyl chloride
Vinylidene chloride
Xylene (mixed isomers)
Zinc (fume or dust)
Zinc Compounds
TOTAL
50% Reduction Quantity
100-41-4
107-21-1
50-00-0
76-13-1
N230
7647-01-0
7664-39-3
123-31-9
67-63-0
7439-92-1
N420
108-38-3
7439-96-5
N450
7439-97-6
N458
67-56-1
78-93-3
108-10-1
1643-04-4
71-36-3
7440-02-0
N495
7697-37-2
139-13-9
98-95-3
528-29-0
76-01-7
108-95-2
7664-38-2
85-44-9
114-26-1
75-56-9
81-07-2
78-92-2
7440-22-4
100-42-5
7664-93-9
75-65-0
127-18-4
108-88-3
75-69-4
75-01-4
75-35-4
1330-20-7
7440-66-6
N982
1,161,605.45
9,740.14
4.43
2,554.50
16,630.16
22.93
7.28
260.44
1,744.99
2,458.15
2,848.78
0.38
308.69
1,134.87
0.45
14.16
283.62
7,276.42
318.26
4,059,553.83
1,097.85
565.75
552.00
5.43
6.38
1.38
0.05
0.02
160.39
308.73
0.04
18.11
0.00
0.21
0.46
0.47
34.15
5,309.77
2.31
164.19
12,779,317.48
6.34
0.00
0.01
5,818,861.28
179.60
1,686.36
29,198,434.72
3,593.55
254.24
3.26
2,554.50
14,911.12
22.69
7.19
260.19
1,003.18
0.00
2.59
0.00
0.00
0.00
0.00
0.00
197.51
2,618.37
1.35
12,576.76
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
4.06
8.42
0.00
0.00
0.00
0.00
0.00
0.47
21.25
2,508.80
1.85
146.09
39,591.35
6.34
0.00
0.00
18,640.79
0.00
1.40
132,557.99
66,279.00
Appendix C, Pollution Prevention Program Guide
Sample MAP - Appendix
-------
Green Zia Environmental Excellence Program
New Mexico Environment Department
PO Box 26110
Santa Fe, NM 87502
505-827-0677
Pat_gallagher@nmenv. state, nm.us
Green Zia Environmental
Excellence Program
Printing
Guidance for improved environmental
performance and pollution prevention in
your printing business
-------
-------
Acknowledgements
The material in this booklet is based on the Systems Approach to Pollution
Prevention, developed by Dr. Robert Pojasek of Pojasek and Associates and
the Nothing to Waste Manual developed by US Environmental Protection
Agency Region 1. Process maps were developed by Ms. Alicia Hale of Los
Alamos National Laboratory. Special thanks also to Annie Porras of
Cottonwood Printing in Albuquerque for her assistance in preparing these
maps.
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 Pagel
Green Zia Tools for Printing Page 5
Process Maps for Printing Tab 1
Pollution Prevention Ideas, Regulatory Guidance and
Other Resources Tab 2
-------
Ill
-------
-------
The Green Zia Environmental
Excellence Program
Guidance materials for printing.
Introduction
This workbook contains information on how to establish a pollution prevention program
specific for a printing operation. The workbook also contains waste management and
regulatory guidance materials to help assure that you are in compliance with
environmental, health, and safety regulations. Used together, this information can help
you establish a pollution prevention program that will help you be in compliance and
reduce waste. Use of the tools from start to finish also helps you qualify for the Green
Zia Environmental Excellence Program.
The Green Zia Environmental Excellence Program is a voluntary program based on
quality management principles that is designed to help New Mexico businesses achieve
environmental excellence through pollution prevention programs.. This program is
administered by a partnership of state, local, and federal agencies, academia, private
industry, and environmental advocacy groups. This packet has been specifically
developed for a printing operation and is designed to meet the needs of a small business.
The basic logic of the Green Zia Environmental Excellence Program is that:
• waste or pollution is the result of inefficiency;
• reducing waste increases profits;
• waste that is not created cannot pollute.
This guidance has been developed to aid in your company's understanding of best
management practices to help your company comply with environmental health and
safety regulations and to reduce waste and associated liabilities.
It is important to remember that environmental health and safety regulations are triggered
by the use of equipment and chemicals. Better use of chemicals, use of safer chemicals,
and efficient operation of machinery can help reduce your regulatory burden—if you
aren't using hazardous materials, then you have fewer regulations to be concerned with!
This program is based on first understanding work processes and materials use and then
improving work practices to reduce cost, waste, and regulatory concerns.
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.
-------
The Green Zia Tools
The Green Zia Program provides tools to establish a basic prevention-based
environmental management system. Management and employees walk through the tools
as a team to gain a complete understanding of their operation. Examples have been
worked out for the auto repair business. We encourage you to customize the examples to
your own operations. The packet includes a series of process maps (Tool 1) for some
operational areas of the auto repair business. Tools 2-6 are also explained and illustrated
to help you develop your program. Use of these tools on a regular basis will help your
company qualify for the Green Zia Environmental Excellence Program.
Green Zia Tools:
Knowledge of
Process
Full Cost
Accounting
Pinpointing
Problems
Problem
Solving
Prioritization
of Options
Ensuring
Success
Tool 1: Process Mapping: Illustrates the work steps materials pass
through as they are transformed into your final product. Maps allow for the
identification of all inputs and outputs such as water, chemicals, electricity or
other materials from a process, helping you to understand wastes and their
sources. Maps also help you understand regulated activities.
Tool 2: Activity-Based Costing: Identifies the true costs of wastes or losses
and helps participants identify areas to target for pollution prevention, by
assigning dollar values to these wastes and losses.
Tool 3: Root Cause Analysis: Creates a cause and effect diagram to
highlight why and where the losses occur in the process. Understanding why
and where the loss occurs will help participants focus on specific areas for
improvement.
Tool 4: Brainwriting: Addresses problems by generating as many
alternatives as possible to minimize loss.
Tool 5: Bubble-up-bubble-down: Ranks alternatives to determine the
optimal solution. Factors such as cost, ease of implementation and
effectiveness are considered in evaluating and ranking the alternatives.
Tool 6: Action Plan: Details each step that needs to be taken to implement
the alternative and reduce or eliminate the loss from the process.
-------
-------
Tool#l: Process Mapping
To begin incorporating pollution prevention into your business,
you must first get a full understanding of where wastes are being
generated. This tutorial will discuss the advantages of using
process maps to logically evaluate each step of your process.
'arm-up Exercise
Maps have been used throughout the ages for many
purposes from helping sailors navigate the seas to
providing a safe route for climbers hiking to the tallest
peaks. You have probably drawn maps to your home
or office so that someone could visit. It is important
that the information on this map is complete and
accurate or, as you may have found, your guest will
get lost!
Take a minute now and think of a coffee shop or restaurant nearby that
everyone in the group knows. Draw a map from the building you are
currently in to this establishment - include traffic lights, landmarks, and
any other important features along the way. Now compare maps with the
other members of your group. Are they the same? If a per son not familiar
with the area were to use your map, would they have found their way?
-------
Introduction
Are you aware of the amount of waste that your business generates? Could this waste be
turned into profit? By considering methods of reducing wastes, recycling used and
unused raw materials, and reusing lost material, you could not only help the
environment but also reduce your raw material and waste disposal costs.
This section discusses process mapping, a method of analyzing a process in order to
catalogue all the materials used and lost in the process. With process mapping, you will
systematically identify the series of steps materials pass through as they are transformed
into the final product. Evaluating your process in this manner will allow you to
recognize the opportunities to prevent losses and possibly streamline operations. Each
loss identified during the process mapping is an opportunity to prevent that loss.
A series of process maps have been developed for printing operations and are included
in this packet. You should customize these maps for your operation, since no two
businesses are exactly alike. These maps become a reference for you to use for your
pollution prevention program and can be updated to reflect changes as you improve your
operations. These maps are also great for training new employees and for other problem
solving needs.
Large businesses and manufacturers use these tools to understand and improve their
manufacturing processes. Small businesses can benefit by using these tools as well!
It is helpful to also prepare a narrative to go along with your process maps to explain the
process in detail. We recommend that you include regulatory activities in the narratives
as part of your environmental management system. Narratives are also included in this
packet; please revise to reflect your business operations.
Create a team of employees to complete this exercise. During this exercise you will:
• Examine and revise the process maps and narratives in the packet to accurately
reflect your operation
• Fully understand the functionality of each step of a process
• Identify the inputs and outputs/losses within the process
• Communicate findings in a clear and concise manner to members of the team.
-------
Example of a process map for printing:
Process Map 3.0: Printing Press Process
Energy
Ink vapors Cans Film
Coating
Pa
1
1
Per Energy Ir
r T i
3.4
Print Paper
\
' Paper V\
r
aste 1
k
\
3.5
Coating
1
Spent Coating
Ink Water
Dampening solution
Blanket Press
T " T
Spent Ink ™a'er Spent solution
Support Process: Cleaning
Printing Plates
Rags
Cleaning Solvent
mg Solvent
I I
Dirty rags Spi||s
Solvent vapors
Please review the process maps in the back of this booklet and make changes to reflect
your operation.
Once you have reviewed and revised the process maps to your operation,
move to the next section...Activity-Based Costing!
-------
-------
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 or support operations - Operations that occur once in a while that are
necessary for the key processes to operate.
Pareto principle - A principle that suggests that 80% of anything can be attributed to 20%
of the factors involved. For example, 80% of your environmental costs can be attributed
to 20% of your activities.
10
-------
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:
• Making proofs
• Developing film
• Printing
• Mixing inks
• Selecting paper
• Binding
• Packaging
Support activities:
• Cleaning print presses
• Record keeping
• Equipment maintenance
• Recycling solvent
• Cleaning ink cans and ink-covered items
• Managing waste ink
• Managing dirty rags
• Equipment maintenance
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 plant that generate
most of your waste or pollution problems. For example, does solvent use cause
most of your environmental problems? Do wastewater from roller washes or air
emissions from solvent-based inks your biggest problem result in your biggest
problem? Does the 80/20 Rule apply? Focus your efforts for now on the areas of
your operations that you do the most or that create the biggest environmental
problem for you.
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
11
-------
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 goggles, monitoring,
record keeping, maintenance, permits, rag laundering service, waste management
service contracts, fees to the state or city, storage space for chemicals, the cost of
spill clean-up and reporting). These activities are not usually considered when
thinking about the cost of a process, yet the costs associated with them can be
significant.
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 estimate only the cost of each of these top 20% of activities that you circled
and write them in a new table. Cost estimates are allowable as you are using this
method to prioritize your most expensive activities. You can refine costs once
you have chosen a project to work on. (In the example, the top 20% of the cost
categories chosen have the estimate beside them.) Add these numbers into Table
1 under the appropriate waste stream in the "Hidden costs" line.
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 (vertical), place costs in dollars, on the y axis (horizontal), show the true
costs of the wastes. This chart will help graphically show how all the costs stack
up against each other. Does the 80/20 Rule apply here? Use this chart to identify
the most expensive processes. This can be used to identify the first area for
improvement. Which waste stream do you think you should focus on from this
Pareto chart?
An example of Activity-Based Costing is provided in the next section. Please note that
this is an example to demonstrate how to assess costs. The costs included are not from an
actual case study. Water and energy costs are not included in this example but should be
considered in developing improvement and cost saving projects. The example provided
addresses only the major processes in a printing operation. Environmental improvement
can be applied to every waste generating activity in your operation!
12
-------
Activity-Based Costing Example
Process Map 3.0: Printing Press Process
Ink Water
Dampening solution
f
Spent Coating
Blanket Press
Spent Ink ir Water Spent solution
' fountain
Air emissions
Support Process: Cleaning
Printing Plates
Cleaning Solvent
Rags
ing Solvent i
I I
Dirty rags Spi||s ,
W astewater
Air emissions
Activities
Materials and Losses
Proof Making
Printing
Binding
Maintenance
Wastewater
* Fountain Solution
* Energy (major cost across organization)
Silver from developing
*Waste Ink
* Solvent
*Rags
*Paper
(*) indicates most important waste streams and
materials
13
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Table 1. Activity-Based Costing Analysis (Per year)
Workstep
Costs/Losses
Raw material
Disposal fees
Other ledger
costs
Hidden Costs
Total
%of Total
Solvent
$2,000
$2,500
$11,700
$16,200
.320
Waste Ink
$3,000
$6,000
$3,650
$12,650
.250
Fountain
Solution
$2,500
$500
$1,650
$4,650
.092
Silver
Recovery
$2,000
+$500
$500
$2,000
.039
Waste
Paper
$2,500
$5,000
$150
$7,500
$15,150
.300
Total
$12,000
$13,500
$150
$25,000
$50,650
1.0
Table 2. Hidden Cost Analysis (per year)
Solvent
Activities/Cost
Factors
HW Gen. fees
Reporting
Red rags
laundering
Recycling
contract
Vent, equip
Air Permit
Materials
X
X
X
X
Space
X
X
Utilities
X
Services
X ($4,000)
X ($5,200)
X
X
Total hidden costs for solvents
Labor and or
fee costs
X ($2,000)
X
X
X
X ($500)
X
($11,700)
Ink
Record
keeping
HW Gen. fees
Recycling
services
Cleaning
equip.
X
X
X
X ($3,000)
X
Total hidden costs for ink
X
X ($650)
X
($3,650)
Fountain solution
HW Gen. fees
Discharge fees
Cleaning
equip/filters
Water use fees
X
Total hidden costs for fountain solution
X
X ($1,650)
X
X
($1,650)
Silver Recovery
Materials
mgmt.
Discharge fees
Filters
X
X
X
X
X
Total hidden costs for silver recovery
X
X ($500)
X
($500)
Paper
Handling
X
Total hidden costs for waste paper
X ($7,500)
($7,500)
14
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Pareto Chart of Printing Waste Costs
18000
16000
14000
ICost in Dollars per Year
Solvent
Paper Waste Ink Ftn. Solution Silver Recovery
Pareto Chart for Printing. The Pareto Chart illustrates costs relative to each other and
helps choose areas to target for pollution prevention activities. In this example,
solvent use, the most expensive loss, will be the focus of the pollution prevention
efforts in the following sections.
Now that the process mapping and activity-based costing are completed, you have a
sense of the relative environmental costs of your operations. Since solvent use is the
target, we will use the following problem-solving and decision-making tools to find a
way to reduce solvent use, increase efficiency and save money.
Most of your work is done. These two tools can be revised as
needed. Use these maps and information annually (or more
often!) to keep improving your operation on an ongoing basis.
Now that you have identified your most expensive wastes, you
can now move towards solving problems and eliminating
waste... the next tool is Root Cause Analysis!
15
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Table 1. Activity-Based Costing Analysis (Per year)
Workstep
Costs/Losses
Labor
Raw
material
Disposal
fees
Other ledger
costs
Hidden
Costs
Total
%of Total
Total
16
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Table 2. Hidden Cost Analysis (per year)
Activities/Cost
Factors
Materials
Space
Utilities
Services
Labor
Waste Stream
Monitoring
Reporting
Repairs
Recycling
disposal
service
Spill clean-up
Storage
Record
keeping
Generator fees
Total hidden costs for (waste stream)
Waste Stream
Monitoring
Reporting
Repairs
Recycling
disposal
service
Spill clean-up
Storage
Record
keeping
Generator fees
Total hidden costs for (waste stream)
Waste Stream
Monitoring
Reporting
Repairs
Recycling
disposal
service
Spill clean-up
Storage
Record
keeping
Generator fees
Total hidden costs for (waste stream)
17
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18
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Tool #3: Root Cause
Analysis
Now that you have recognized the activities in your process that
are costly or expensive to your business, you can begin to focus
your efforts on pollution prevention. This tool presents a
method of detecting the underlying reason for an environmental
loss so that the loss can be prevented.
Warm-up Exercise
Think of all of the times that you have been late for work
and list the different reasons for your delay. Maybe your
alarm clock did not go off, or perhaps your child was sick
and you needed to arrange for a sitter. Did you spend too
much time reading the newspaper or did you need to run
to the store to pick up milk.
Arrange all these reasons in the categories listed below,
or create an additional category. Some of the items on
your list may be entered more than once. Now consider
the last time you were late for work. Why were you late?
Circle the reason.
MACHINES
broken alarm clock
PEOPLE
sick child
METHODS
reading the newspaper
MATERIALS
out of milk
19
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Introduction
In the last tool you determined the key losses responsible for the greatest amount of
environmental costs. In order to try to prevent a loss, you must first understand why
it is occurring. The underlying reason for a loss is also known as its "root cause".
The root cause will answer the question: What ultimately caused the loss?
Determining the root cause of an environmental loss is very similar to determining
the root cause of being late for work
A cause and effect diagram is one method of determining the root cause for a loss.
This tool provides a visual description of all possible causes for a specific loss. Once
all the possible causes are depicted on the diagram, the most plausible cause or
causes are identified. It is imperative that all persons involved in determining the
root cause are in agreement. The next step is to write a "Dear Abby" letter
summarizing the cause or causes for a loss will ensure that all participants see the
problem in the same way.
During this exercise you will:
• Construct a cause and effect diagram with all potential causes for a loss.
• Discuss the most probable cause or causes.
• Write a Dear Abby letter describing the reason for the loss.
Root Cause Analysis
After participating in process mapping and activity based costing exercises, it was
determined that the largest loss, solvent use, accounts for approximately 80% of all
environmental costs in the printing operation. The next step is to discover the root
cause of this loss.
To determine the root cause of a loss, you must ask, "Why is the loss occurring?" One
way of gathering information concerning the generation of a loss is called a cause and
effect diagram, or fish bone diagram, since it resembles a fish bone. Major categories
of possible causes for the loss are first defined and entered on the diagram as an
offshoot from a main horizontal line. Next, all possible causes of the waste are
assigned to a category and entered on the diagram. Once all the causes are defined, an
agreement is made as to the most plausible reason for the loss.
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.
20
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Several things may come to mind. Inks must be mixed to meet color specifications.
Fountain solutions containing solvents must be prepared. Rollers must be cleaned
thoroughly. Waste drums containing inks and solvents must be managed properly.
Red rags from cleaning processes generate hazardous waste. Drums containing red
rags accumulate liquid solvent in the bottom of storage drums creating health and
safety issues and hazardous waste. Spills must be cleaned. Machine maintenance is
critical in assuring production with minimal downtime. Also people operating the
machines are critical and training and a good work attitude are critical to efficient
operations. All of these ideas should be entered under one of the four categories in
the fishbone diagram: Machines, Methods, Materials and People as in the example in
Figure 2.
Now that all the possible causes of solvent being lost during the printing process are
categorized, it is time to determine the most probable cause. Go back to the diagram
and circle the most probable causes. One of these should be the root cause. Then,
working with employees as a team, discuss which one of these major causes is the
root cause. To come to clear understanding of the root cause, we suggest that the team
write a short "Dear Abby" letter describing his or her interpretation of the problem to
ensure that each person sees the problem the same way. Once the letter is in place,
the group becomes Abby and seeks to solve the problem, (see Figure 3)
Another method for determining the root cause of a problem is the "5 whys".
By asking the question "why?" five times, you may get to the root cause of a
problem. An example of how the five whys works is as follows.
The Five Whys:
1. Why has the machine stopped forcing an interruption in production?
A circuit breaker tripped due to an overload.
2. Why was there an overload?
There was not enough lubrication for the bearings.
3. Why was there too little lubrication for the bearings?
The pump was not pumping enough lubrication.
4. Why was there not enough lubricant being pumped?
The pump shaft was vibrating because of abrasion
5. Why was there abrasion?
There was no filter, which allowed chips of metal to get into the pump.
The solution is then to place a filter on the pump to capture metal chips.
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.
21
-------
Understanding all the contributing factors will help facilitate problem solving. The
Five Whys will also help you move past dealing with the symptoms of the problem to
solving the real problem.
Examples of the fishbone diagram and a Dear Abby letter are included as well as a
blank fishbone diagram for your use.
The next tool will present brainwriting - a method to
generate ideas.
22
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Figure 1: Printing Process - Process Map
Process Map 3.0: Printing Press Process
Ink
Air emissions
f
Paper Waste
Spent Plates
Energy
Air emissions Cans Film
Coating
Ink Water
Dampening solution
Blanket Press
Spent Ink ir Water Spent solution
fountain
Air emissions
Support Process: Cleaning
Printing Plates
Rags
Cleaning Solvent
ung Solvent i
I I
Dirty rags
Spills
23
-------
Figure 2: Cause and Effect Diagram
Methods
selecting, adjusting
ink and soluti
Job type
rags too wet, slo
Cleaning
rollers
composition
solvent
bad ventilation
Workplace
Conditions
poor lighting
Machines
type
Press machine poor
maintenance
not efficient /
type
poor maintenance
_water, other
additives
Awareness
wrong quantity
quality /
Materials
bad
attitude
People
not
sufficient
Training
^^ Regulations
maintain inventory logs
Proper
reporting
24
-------
Figure 3: Dear Abby Letter
Dear Abby,
We run a small printing operation. 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 printing plants have
had to pay lots of money for air quality permits, waste management and special
equipment to meet regulations. These are issues that we wish to take seriously.
Our group did root cause analysis and we believe that our biggest problem is use of
solvents. Employees affect solvent use from loading the ink, to maintaining the
equipment, to keeping the presses clean and making sure we are in compliance with
regulations. However, as you know, our employees have a billion things to do every
day and they often don't stick around for enough time to get proper training.
Can you help us?
Signed,
Pressed for time in Albuquerque
25
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Figure 4. Root cause analysis: Fishbone Diagram
Methods
Machines
Materials
People
26
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Tool #4: Brainwriting
To address an opportunity effectively, it is important to
recognize all alternatives. Very rarely is there one "right" way
of preventing pollution. Instead, there are many different
potential solutions. This tutorial presents a technique of listing
many different alternatives for an opportunity.
Warm-up Exercise
You know the old adage "two heads are better than
one". This is especially true when trying to come up
with new ideas. When you generate ideas in a group
you will notice that each member of the group
brings their unique set of experiences and strengths
to the table.
Try the following exercise with your group. Look at the picture below
(turn it on it's side and upside-down). What does it remind you of? Write
down all the images that come to mind-even images that seem crazy
should be included. Now go around the room, each person sharing one
image with the group. One person should volunteer to keep a list of all the
images. Repeat this step until every member of the group is out of images.
How many images did the group come up with? How does this compare
with the number of images you generated alone?
27
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Introduction
In the last tool you evaluated all the probable causes of a loss and determined the
underlying reason, or root cause. Once the root cause has been identified, you may be
tempted to jump to a premature solution. When you address a loss without
considering all the alternatives of prevention you may be overlooking the most
appropriate option(s).
Looking for alternatives for pollution prevention by addressing its root cause is the
next step towards addressing an opportunity. There are several tools available to help
groups develop alternatives. You already explored one tool during the warm-up
exercise. In this exercise you will explore another method-brainwriting. Brainwriting
requires maximum interaction and creativity between group members. The group
should consider all possible alternatives, regardless of how far-fetched they appear to
be. Alternatives raised by the group may seem contradictory, or they may build on
one another making them better. A comprehensive list of alternatives can then be
compiled.
During this exercise you will:
• Conduct a brainwriting session.
• Develop a list of all possible alternatives for an opportunity for
improvement.
Brainwriting
First you have completed your process map to see how you can optimize your
processes and reduce losses, (see Figure 1) In the example provided, Activity-Based
Costing helped to identify that 80% of the environmental costs associated with
printing 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 printing 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.
28
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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.
29
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Figure 1: Printing Process Map
Process Map 3.0: Printing Press Process
Paper En
1 1 1
V V V
V
Ink w
Air emissions
f
Paper Waste T
Spent Plates
Energy
I ¥ »
Air emissions Cans Film
Coating
Ink Water
Dampening solution
Blanket Press
f
Spent Ink
Water Spent solution
fountain
Air emissions
Support Process: Cleaning
Printing Plates
Cleaning Solvent
y rags Spills
Wastewater
Air emissions
30
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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 better.
3.
Employees could use a centrifuge to
remove liquid solvent from rags before
sending off for cleaning.
4.
Investigate alternative printing systems.
5.
Start a "clean shop" program to train
employees to keep work areas clean to
prevent spills and waste.
6. Begin an employee incentive
program to reward best operating
practices for operating printing
machine and reduce loss from rejects
and excessive solvent use.
7.
Start an energy conservation program
and focus on presses.
8.
Institute a program to use less solvent
in all cleaning operations... less solvent
on the rags to clean, less solvent in the
fountain solutions.
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.
31
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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 systems better.
3. Purchase a centrifuge system to remove liquid solvent from rags before sent
off for laundry.
4. Investigate alternative printing systems.
5. Start a "clean shop" program to train employees to keep work areas clean to
prevent spills and waste.
6. Begin an employee incentive program to reward best operating practices for
operating presses to eliminate rejects and reduce solvent use.
7. Start an energy conservation program and focus on presses.
8. Institute an employee program to use less solvent in all areas.. .less on rags,
less for cleaning, less in operations.
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.
32
-------
Figure 4: Brainwriting Sheet
T 2.
8.
10.
33
-------
34
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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.
35
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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 effect a particular business. The
method of selection presented in the exercise is the bubble-up-bubble-down. This tool uses a
forced pair comparison to rank alternatives. Using this method you will be able to find the
most effective solution to the selected loss.
During this exercise you will:
• Evaluate all alternatives.
• Use the bubble-up-bubble-down method to reach a decision on the best
alternative.
Bubble-Up, Bubble-Down
Take the list of alternatives and compare the first two alternatives. Decide which of the two is
the best and move this alternative to the top of the list. Go to the next, or third alternative and
compare it to the second. If it is better than the second, move it up and compare it to the first,
if not, leave it in the third position. Continue this process until all the alternatives are rank
ordered. This process should go fairly quickly. Make sure you listen to everyone's opinions
and objections. Again, factors to consider are cost, effectiveness and the ability to implement
the alternative.
Bubble-up, Bubble-down should generate much discussion among employees on the best
solutions. These discussions will help to increase buy-in to the alternatives. As a rule,
employees never resist their own ideas.
An example of how the Bubble-Up Bubble-Down method was applied to the list of
alternatives generated in the last tool are listed below.
36
-------
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!
37
-------
Figure 2: List of alternatives, prioritized through Bubble-Up, Bubble-Down
1. Begin an employee incentive program to reward best operating practices for operating
presses to eliminate rejects and reduce solvent use.
2. Start a "clean shop" program to train employees to keep work areas clean to prevent
spills and waste.
3. Institute an employee program to use less solvent in all areas.. .less on rags, less for
cleaning, less in operations.
4. Pay employees small bonus for keeping good environmental records including hazardous
waste and air quality records.
5. Purchase a centrifuge system to remove liquid solvent from rags before sent off for
laundry.
6. Train people to maintain filtration systems better.
7. Start an energy conservation program and focus on presses.
8. Use non-toxic solvent to eliminate all environmental problems.
9. Investigate alternative printing systems.
10. Test solvent to see if we are replacing too soon.
38
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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
39
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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
may occur, (see Figure 2)
Things to consider in developing an action plan are resources needed, both financial and
human resources; the need for pilot testing or bench scale testing; information sources from
he outside such as trade associations, vendors and suppliers and the Environment
Department. Other issues such as employee support and maintaining product or service
quality should be considered. A list of questions that should be considered during action
planning is as follows:
Action Planning Questionnaire
1. What is the overall objective and ideal situation?
2. What steps are needed to get there from here?
3. What actions need to be done?
4. Who will be responsible for each action?
5. What is the best sequence of action?
6. How long will each step take and when should it be done?
7. How can we be sure that earlier steps will be done in time for later steps that
depend on them?
8. What training is required to ensure that all staff have sufficient know-how to
execute each step in the plan?
9. What standards do you want to set?
10. What volume or quality is desirable?
11. What resources are needed and how will you get them?
12. How will you measure results?
13. How will you follow up each step and who will do it?
14. What checkpoints and milestones should be established?
15. What are the make/break vital steps and how can you ensure they succeed?
16. What could go wrong and how will you get around it?
17. Who will this plan affect and how will it affect them?
18. How can the plan be adjusted without jeopardizing its results for the best response
and impact?
19. How will you communicate the plant to generate support?
Now put all this information in an Action Plan Form. Most of the information you need
should come from your answers to the questionnaire. The specific task, or step, to be
accomplished is written in the first column under "Action." In the following column list the
person who is responsible for completing this task. A performance standard should then be
provided. This standard is a way of establishing how well a task needs to be performed.
40
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Under "monitoring technique" enter a measurable goal or target used to track the plan's
implementation. A firm deadline should then be set, and finally, indicate the resources that
are needed to perform each task. This form will help you organize your thoughts, keep
track of all the actions that need to be completed, and ensure that the proper quality is being
maintained.
Use the form provided to track implementation of the project and to measure its success. A
sample action planning form is included at the end of this section.
Overall Target: Employee Incentive Program
Action
1. Develop
Program
incentives
2.Design a
program for
review and
giving
incentives
3 . Meet with
employees
4. Set up
improvement/su
ggestion box,
system
5. Review Team
6. Incentives
awarded
Responsible
person
Carol
Marcy
Carol, Mark and
Marge
Carol
Carol and Mark
Marge
Performance
standard
List of incentives
Approved
program by
Marge
Highly interactive
meeting
System in place,
all employees are
aware, easy to use
Review team
reviews
suggestions
monthly
Ideas
implemented,
paying off in $$,
improvements
Monitoring
technique
Discuss ideas
with Marge the
owner
Marge
approves,
allocates
funding.
Question
employees
before and after
Number of ideas
submitted
Marge evaluates
work
Check on
progress,
success
Completion
deadline
Jan 15
Feb 1
Feb 15
March 1
March?
Junel
Resources
needed
Team of Carol
and Mark
Action #1
complete
Firm date for
meeting;
meeting room
Box, access to
company
computer,
review team
Ideas
accepted/imple
mented
Cash bonuses,
days off, etc
Congratulations!!! You have completed the Pollution Prevention Training. Now it is time to
put these tools to work and remember pollution prevention is an ongoing process. If you
continue to implement pollution prevention in your business, you will increase the efficiency
of your process while helping the environment. Simply revisiting your process maps and
Pareto Chart once a year and using the tools to continue to make improvements will make a
big difference in your operation. Ongoing use of these tools will help you to participate in
the Green Zia Environmental Excellence Program.
41
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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
environmental improvement decisions.
• Schedule regular pollution prevention reviews of your business.
Remember: Pollution Prevention saves resources, saves money, and
prevents accidents!
42
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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
43
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44
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Process Maps for Printing
-------
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General Process Map for Lithography Printing
1
Customer
2
Pre-Press
3
Press
Post-Press
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Map 1.0: Process Map for Customer
Film or Disk
Paper
1
1.1
Customer Brings in job
1.2
Service Rep get job/quote
information creates job
ticket
1.3
Scheduler overviews and
schedules job
^-
Paper
Paper
i
1.4
All department review of
job
1.5
Purchase receives
stock order and orders
stock
Customer 1.0
1.1 Customer Brings in Job
The customer brings the job to the printing company on disc or film. The customer has the design already
finished and wants the design printed at the printing company.
1.2 Service Representative gets Job
The service representative gets the job and quotes information about that job. He/she also creates the job ticket
for that job.
1.3 Scheduler Overviews and Schedules Job
The scheduler gets the job, overviews it, and schedules the job. This includes scheduling the stock order for the
necessary supplies to do the job. If the job requires outside work, such as binding, envelopes, cutting thick paper,
etc., the scheduler will schedule contractors to do this after the job is printed.
1.4 Purchase department Receives Stock Order
During this process, the purchase department receives the stock order and orders the stock. Paper choices
include virgin paper, recycled paper, chlorine-free paper and kenaf.
1.5 All-Department Review of the Job
The department reviews the job to decide if there are any problems with the job and if the supplies are ready to
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Process Map 2.0A: Pre-Press
Energy
1
2.1
Original Disc to
Electronic Prepress
r
2.2
Electronically scan disk
into computer to preflight
it
Computer hardware
waste
2.4
Proof Development
fc-
Fix
1
I
disks (returned to
customer) pjx
Energy
[ J
Deve
1
2.3
Ripping and Film
Processing
Spent
er _ . . i
Container 1
1 r
" s
waste film
1
r D*
Iver
oper
r
r
;veloper
To the presses
Pre-Press 2.0
2.1 Original Disc is Taken to Electronic Pre-Press
The original design is taken into the computer run to be electronically examined.
2.2 Electronically Scan Disc
The disc is pre-flighted (make sure format is correct and there is no viruses).
2.3 Computer File Taken to Sci-tex Machine
The computer file is taken to the Sci-tex Machine to print out file onto film. While the machine prints the file onto film
fixer and developer removes the silver from the film. This step creates fixer, developer, and spent containers.
2.4 Water Proof Film
Film is put on a transfer sheet and water proofed so the customer can see the design before it is plated.
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Process Map 2.OB: Traditional Prepress
2.1B
Customer provides film
Film Plastic carrier
2.2B
Make a dummy
Masking sheets
2.3B
Masking
waste masks
No narrative prepared for this process.
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Process Map 2.4.1A: Color Key Process for Proofing
Fi|m Color Key
Energy
2.4.1A
Exposure
4 colors:black, yellow, cyan,
magenta
Process Map 2.4.1B: Blue Line
mounting sheet
2.4.2 A
Color Separation
Plastic
2.4.1B
Film put on blue paper
Energy
2.4.2B
Blue paper with film
exposed light exposer
No narratives prepared for these processes.
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Process Map 2.4 C: Water Proofing
Pigment layers Film Energy
2. 4. 1C
Vacuum Frame
Pigment layers
Water Pigment layers Energy
2.4.2C
Plastic Film Wa:
;te water(some
pigment contamination)
Transfer
Sheet
Paperstock Energy
2.4.3C
Film transfer
Transfer sheet
Paper Stock Energy
V V V
Transfer to paper
Spent transfer
sheet
2.4 C Water Proof Development
2.4.1C Film to Vacuum Compressor
The film goes through a vacuum compressor that will put the image onto colored sheets. This set requires the
usage of colored sheets, vacuum oil and energy. The waste created in this step is colored sheets, spent vacuum
oil, and fixer and developer vapors.
2.4.2C Water Proofing Machine
The colored sheet is put through a waterproofing machine that will separate the colors by water and create the
actual image onto the sheet. This process requires the usage of water and energy and generates water waste.
2.4.3 Transfer image to transfer Sheet
The water proofing machine transfers the image onto an adhesive transfer sheet. This process uses energy and
generates adhesive transfer sheet waste. The sheets may be recycled.
2.4.4C Transfer Sheet Given to Customer
The transfer sheet has the desired image and is given to the customer for approval. If the customer approves, the
image will be redone onto a plate. If the customer wants edits done to the image, the image will be edited and
once again placed onto a transfer sheet.
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Process Map 2.5: Prepress Plate Making
Colored Sheets Energy
Developer Energy Se ler
Waste
Metal Sheets Fixer and Developer Developer
(all sheets recycled) Vapors
Support Process Map for 2.5.3: Developer Reclamation
Container
1
2.5.3.1
Spent Developer
Drained
i
2.5.3.2
Filtered
Recycled back into
Process
Spent Filters/Sludge Spent Chemicals Fumes
Narratives on next page.
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2.5.0 Plate Making
2.5.1 Film Taken to Vacuum Compressor
The film is taken to a vacuum compressor that will place the image onto a transfer metal
sheet. Material use includes colored sheets and energy. Losses include metal sheets
(although it may be recycled) and fumes from fixer and developer.
2.5.2 Plate Processing
The plate moves through the plate processor. The plate processor removes photo polymer by
spraying developer on the plate. The plate is then scrubbed to remove the remaining photo polymer.
The plate is coated with a thin layer of plastic. Material use includes developer, energy and coating
plastic. Losses include spent developer, waste polymer, energy and plastic.
2.5.3 Image on Plate
The finished result is the image is now on the plate and ready to be printed. This step
generates spent plate waste (may be recycled).
Support Process for 2.5.3: Developer Reclamation
2.3.5.1 Developer Reclamation Unit
The spent developer is reclaimed through a reclamation unit, which is a filtration unit.
Filtered developer is recycled back into process.
2.5.3.2 Chemicals to Waste Hauler
The waste materials from the reclamation unit are barreled and managed by a certified
waste hauler.
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Process Map 3.0: Printing Press Process
RaPer Energy Ink
Energy
Dampening solution/
Ink Water fountain wash
3.1
Load Plate
1
1
Air en
r
1
3.2
Load Ink
r i
Tissions Ca
r i
s Fi
J 1
r i
m Spe
r '
r i
J 1
3.3
Blanket Press
r
nt Ink ^
Air em
i
Wa
ssion
r
ter
s 1
1
Spent
fou
r
r
r
solution
itain
Coating
Spent Coating
waste filters
Support Process: Cleaning
Printing Plates
Cleaning Solvent
Dirty rags Spi||s ,
Wastewater
Air emissions
10
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Process Map 3.0: Press Operations
3.1 Load Plate
The plate is placed into the blanket rollers of the press.
3.2 Load Ink
This step requires the usage of ink, solvents to thin ink, Polyamide Resin, metal foil and energy.
Losses include solvent vapors, ink, Polyamide Resin, and metal foil.
3.3 Blanket Press
The blanket rollers place the ink onto the plate. This process uses ink and dampening fountain
solution. The waste generated includes spent ink and fountain solution. Fountain solution is
discharged to sewer if it is non-hazardous waste.
3.4 Print
This step is where the color image is printed onto large sheet of paper. Once printed, the finished
pile is taken to the back for folding and cutting. This step uses paper, energy and ink. The waste
create include ink, paper waste, and spent plates. All paper, ink and plates may be recycled.
3.5 Apply Coating
A final coating is applied upon request from the customer. Waste coating is generated through
this process.
Support Process 3.0 for Press Operation
3.0 Roller Washes
Rollers require washing to remove ink. Solvent is typically used to clean rollers. Losses include
red rags soaked in solvent, solvent vapors, spill clean-up materials. Fountain solution is
discharged to sewer if it is not hazardous.
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Process Map 4.0: Post-Press Operations
Energy
4.1A
Trim product
Paper Waste
Energy
Paper
4.2A
Folding
Paper Rejects
Boxes Tape Packaging Materials
Boxed
Boxes Tape Packing Materials
Energy
Waste Paper
Boxes Tape Packaging Materials
Boxes Tape Packaging Materials
Boxes Tape Packaging Materials
Boxed
4.2C
Sent to Binder
T T T
°xes Tape Packing Materials
12
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Process Map 4.0: Post-Press Operations
4.1 Product Folded
The product is trimmed and then a folding machine folds the finished product. All waste paper
may be recycled. Process also uses energy.
4.2 Product Cutting
Paper is cut to size depending on job specifications. This step requires energy to run the machine.
Paper waste is created in this step and may be recycled.
4.3 Finished Process is Boxed and Shipped
The finished product is boxed and shipped to either the customer or to a bindery company for
binding, and cutting. This process requires the usage of boxes, tape, and packaging materials. This
step generates boxes, tape, and packaging material waste.
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Printing Regulatory
Guidance, Pollution
Prevention Information and
other Resources
-------
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Understanding Solvents: Common
Uses and Chemical Composition
Eliminate - Reduce - Reuse - Recycle - Exchange
Solvents are used to create a fluid environment in which reactions or processes
can be run efficiently and effectively. Solvents influence pH and temperature
factors that affect the binding mechanisms of soiling agents. The following
paragraphs are intended to serve as an introduction to the chemical composition,
general activity mechanisms, and common uses of various types of solvents
Petroleum-Based
This group refers to a class of solvents that are used as general-purpose cleaners.
Most petroleum-based solvents consist of a hydrocarbon "backbone" to which
chemical functional groups and oxygen groups have been added. In these
solvents, the inorganic functional groups are responsible for the activity of the
solvent. The exception to this rule is a subclass of petroleum-based solvents called
aromatic and aliphatic hydrocarbon solvents, which contain multiple bond
arrangements and/or are bonded into ring confirmations. In these solvents, it is
the carbon confirmation and arrangement of double and triple bonds between
neighboring carbon atoms that give the solvent its activity.
Industry has chosen the petroleum-based solvents with low molecular weight,
which have high volatility. The high volatility and reactivity of these solvents
allows maximum removal of soils and contaminants, creating compatibility with
varied work surfaces and subsequent process requirements while simplifying
process and technique, thereby minimizing costs. Furthermore, because many
soiling agents are organic compounds, ex.) grease, motor oil, waxes, and most
lubricants, they are miscible in organic petroleum-based solvents, allowing for
quicker, more effective clean up.
-------
Due to their high volatility, total containment of petroleum-based solvents during
application and waste storage is nearly impossible. The atmospheric escape of
these solvents, many of which are classified as Volatile Organic Compounds
(VOC's), has been shown to contribute to stratospheric ozone depletion, air
pollution through smog formation, and soil and groundwater contamination.
Types of Petroleum-Based
Solvents:
Halogenated petroleum-based solvents:
These solvents consist of the highly reactive functional groups chlorine, fluorine,
or bromine. These halogens share the same number of electrons available to
participate in chemical reactions. For this reason, the chemical reactivity of these
solvents is less dependent on which halogen atom comprises a functional group
than on how many functional groups are attached to the hydrocarbon "backbone,"
a number referred to as the degree of halogenation. A solvent with a high degree
of halogenation has a high volatility and strong cleaning properties.
Higher energy levels in the bonds make the molecule more reactive, which can
cause it to escape from the liquid phase into the gas phase and enter the
atmosphere. The popularity of halogenated solvents arose from their superior
contaminant and soil expulsion properties, low flammability, compatibility
with work surfaces and process equipment, and relatively low cost
Alternatives that Reduce
Risk:
1
Though it is often advisable to seek non-halogenated alternative solvents because
halogenated compounds are hazardous to human and environmental health,
several new halogenated alternatives have been developed with short atmospheric
lifetimes.
n-Propyl Bromide:
Many commercial "green" solvents have replaced their chlorinated solvents with
n-butyl bromide because it is a nonflammable VOC with a 10-11 day atmospheric
lifetime, giving it a low Ozone Depletion Potential. However, despite a low
bio-accumulation potential, n-butyl bromide solvents are non-biodegradable, and
in large volumes have the potential to penetrate soil and contaminate
groundwater. Furthermore, they may harm some work surfaces, especially
aluminum surfaces.
-------
High-volatility oxygenated solven
In these solvents, the halogen functional group is replaced by an oxygen group
such as a hydroxide group, such as alcohols; an ethyl group, such as ethers and
esters; or a carbonyl group, such as ketones, aldehydes, and carboxylic acids. The
hydroxide group has a similar chemistry to the halogen groups with one important
exception: most of the oxygenated solvents are highly flammable and therefore
restricted to applications such as ambient temperature immersion and manual
wipe.
Oxygenated solvents are also prone to undergo reduction/oxidization (redox)
reactions, which is the addition or elimination of double bonds or oxygen atoms.
Although redox reactions in these solvents rarely result in more toxic
compounds, the resulting solvent is less effective and more flammable under
atmospheric conditions. For this reason, a warning not to mix with oxidizing
agents often accompanies the oxygenated and aromatic and aliphatic hydrocarbon
solvents.
Alternatives that Reduce
Risk:
Acetone:
Excluded from the U.S. EPA's definition of VOC's due to its insignificant
reactivity in the presence of sunlight, Acetone is a nonetheless a highly volatile
organic solvent. Acetone is suitable as a drying agent and for ambient
immersion or manual cleaning applications of soils such as greases, waxes, and
inks. Due to its high flammability, safety cautions must be implemented during
handling as well as during recycling. Although Acetone need not be reported
under SARA 113, it is on the RCRA list of hazardous wastes, and must be
incinerated for disposal.
Alcohols (with perflourocarbons):
Alcohols, mainly isopropanol, methanol, and ethanol, are excellent cleaning
solvents for certain soils. The hydroxide functional group allows the alcohol to
exhibit some of the same properties as water, while the hydrocarbon "backbone"
allows the alcohol to dissolve low-molecular-weight oils. Alcohol solvents are
often biodegradable and water-soluble Alcohols are also flammable VOC's
and as a result can only be used directly in manual and cold immersion
applications, although their greatest efficacy occurs in heated or boiling liquid
applications.
This obstacle can be overcome by placing a perfluorocarbon vapor "blanket"
above the heated cleaning system. This vapor "blanket" shields the solvent from
atmospheric oxygen that causes combustion. Perfluorocarbons are nonflammable
-------
and have low toxicity, but are costly and have high global warming potential.
Though they are immiscible in alcohol and easily separable and reusable, the
capital and operational costs of perfluorocarbon systems are fairly high and
prohibitive when other methods are available. Perfluorocarbons, which can be
employed as solvents alone, have greatest potential in cleaning equipment that
uses fluorinated lubricants or polymeric and elastomeric materials that are easily
corroded by other solvents.
Glycol Ethers/ Ethyl Lactate:
Because glycol ethers emulsify well and separate easily, they are prime
candidates for the organic components of semi-aqueous solvents. They are also
being substituted for both harmful halogenated hydrocarbon and high-volatility
oxygenated solvents in capacities ranging from dry cleaning to degreasing.
Often azeotropic blends and additives such as isoparaffmic hydrocarbons are
supplemented in to increase the solvent's efficacy rating, work surface
compatibility, and/ or decrease the solvents flammability. However, glycol
ethers are highly flammable VOC's
Commercially important glycol ethers have been separated into two categories:
the E-series, or ethylene glycol ethers, and P-series, or propylene glycol ethers.
Because they have been linked to miscarriages, SARA 113 and OSHA heavily
regulate the E-series. Due to these concerns, alternatives are being researched.
n- Methylpyrrolidone (NMP):
NMP is a combustible VOC listed under the SARA 113 Title III. Despite this
listing, NMP is very useful in removing high-molecular-weight greases and
carbon deposits as well as coatings (polyurethane, ink, and resin), enamels, and
many plastics. It can be employed in both immersion and ultrasonic processes.
Since many oils are only soluble in NMP above 145 F°, oil soils can be easily
separated and the solvent reclaimed by lowering the solvent temperature.
Furthermore, NMP is biodegradable and can also be reclaimed through
separation and subsequent vacuum distillation.
-------
Aromatic and aliphatic hydrocarbon solvents:
^
These solvents are also referred to as unsaturated hydrocarbons. Due to their
flammability concerns and redox potential, aromatic and aliphatic hydrocarbon
solvents share the advantages and disadvantages of the oxygenated solvents.
Alternatives that
Reduce Risk
-I
Terpenes:
Derived from natural sources such as citrus fruit and pine trees, terpenes are
biodegradable and are useful in semi-aqueous solutions (from which they can often
be separated and reused). Terpenes are flammable VOC's and very strong
cleaners, removing resin, fingerprints, and high-molecular-weight greases. They can
be used in ambient immersion and ultrasonic applications, though they may be too
strong for some work surfaces.
Petroleum Distillates:
Produced from crude oil cracking, petroleum distillates are also flammable VOC's
used to remove high-molecular-weight greases, tar, and waxes in immersion or
manual applications. This class of solvents includes mineral and white spirits,
naphtha, kerosene, and Stoddard solvent, which vary in cost and toxicity. Petroleum
distillates are able to penetrate and clean porous surfaces, and evaporative losses can
be minimized through the use of a parraffmic hydrocarbon additive. Furthermore,
they can serve in some semi-aqueous solutions, from which they can be easily
reclaimed through separation or distillation techniques.
Aqueous Solvents
Aqueous solvents are a category consisting mainly of water and dissolved inorganic
water soluble components such as surfactants, chelating agents, emulsifiers,
sequestering agents, and corrosion inhibitors. Water is a polar compound, meaning
that a portion of the water molecule, the oxygen atom, has a greater affinity for the
-------
molecule's bonding electrons, and hence has a slight negative charge. As a result,
the remaining portions of the molecule, the hydrogen atoms, have a slight positive
charge. Due to this charge separation within their constituent molecules, aqueous
solvents are held together by intermolecular forces in which the negatively charged
oxygen atom of one water molecule creates a weak bond to the positively charged
hydrogen atom of another water molecule. These intermolecular attractions, referred
to as hydrogen bonding, in conjunction with its basicity/ acidity allow the solvent to
"attack" any soil that contains charged portions.
Aqueous solvents are generally superior to organic solvent methods. Due to the
benign nature of water, aqueous solvents are less hazardous to both human and
environmental health than their organic counterparts. Aqueous solvents are often
corrosive or harmful to work surfaces, and are often ineffective with porous
surfaces or soils. Furthermore, due to their immiscibility with organic contaminants,
aqueous solvents must be repeatedly applied to common organic soiling agents to
achieve effective removal. Often the process requires high pressure or ultrasonic
technology. Therefore, in weighing the environmental factors involved in replacing
organic solvents with aqueous solvents, the increased volume of wastewater streams
must be considered. When utilizing aqueous solvents, it is tempting to dispose of the
waste solution down the drain; however, the local water authorities should always
be consulted about proper waste disposal.
Types of Aqueous
Solvents:
Alkaline aqueous solvents:
Alkaline aqueous solvents have a pH greater than 7. Adding base to an aqueous
solution creates an alkaline solvent, which contains negatively charged ions. These
negatively charged particles disrupt the polar bonds binding the contaminants to the
work surface, as well as obstruct the intermolecular bonds holding the contaminant
together, thereby dissolving the contaminant. Due to the corrosive nature of these
ions, inhibitors must be added to protect metallic work surfaces, especially aluminum
surfaces. With the right additives and process optimization, alkaline solvents can be
utilized with all types of liquid cleansing processes. With thorough filtration and
rinsing, very high levels of cleanliness can be achieved, although the process may
become water intensive. Alkaline aqueous solvents are widely applicable, low
waste, and cost effective
Neutral Aqueous solvents:
Having a pH of approximately 7, neutral aqueous solvents are mixtures of water and
above-mentioned process specific additives. Weaker than alkaline solvents, neutral
solvents are effective at removing light oils, salts, particles, and soils that are easily
-------
removed. For these contaminants, the dissolving properties of hydrogen bonding are
sufficient to break up and remove the soil. Due to their weaker activity, neutral
solvents are less widely applicable and are most effective in spray and ultrasonic
applications, especially in degreasing processes.
Acidic Aqueous solutions:
Acidic aqueous solutions have a pH less than 7 and may be comprised of mineral
acids, chromic acids, or organic acids that are miscible in water due to their acidic
properties. Acids have free floating positive charge, making them excellent at
removing scale, rust, and oxidizing agents from metals. The positive portions of the
acid surround and dissolve the aberrant negatively charged metal region. Some metal/
acid combinations cause hydrogen embrittlement on the surface of the metal. This
can be significantly reduced or eliminated by changing acids or heat treating the
metal before the cleansing treatment. Because acidic aqueous solvents are less
adaptable to general cleaning processes, they are less common as cleaning solvents.
Semi-Aqueous
Two different types of semi-aqueous solvent procedures are commonly used. The
first involves a solvent in which hydrocarbon/ surfactant cleaners are emulsified in
water, meaning that the hydrocarbon/ surfactant exists as droplets suspended in the
aqueous support. This arrangement combines the more effective contaminant
dissolution and high-molecular-weight soil removal characteristics of petroleum-
based solvents, with the increased environmental safety of aqueous methods.
The other semi-aqueous method entails an initial concentrated hydrocarbon
application followed by an aqueous rinse cycle. Again, this method utilizes the
effectiveness of organic solvents while lessening the environmental impact of the
overall process by reducing the amount of organic solvent employed. The application
techniques for both semi-aqueous methods are similar to those used in aqueous
methods, though flammability, phase separation, and odor problems can arise with
the mixing of the solvent types, making equipment design an important consideration.
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Super Critical
Supercritical fluids are common gasses such as carbon dioxide under extreme
pressure and temperature. Under these conditions, the fluid no longer exhibits the
characteristics of a liquid or a gas, but rather has properties conducive to high soil
dissolution. The high temperature of a critical fluid confers a high energy level to the
individual molecules, which under atmospheric pressure would cause the molecules
to increase molecular vibrations and velocity, causing the fluid to expand.
However, because critical fluids are also under high pressure, the high-energy
molecules are not able to expand and must exist in a tightly packed, high-energy
configuration. It is this dense, high-energy arrangement that gives critical fluids their
high soil dissolution properties. This current technology combines application
flexibility with low cost However, it requires large capital investment to design
and maintain a system capable of safely withstanding such high temperatures and
pressures. More testing must be completed to understand the effects on sensitive
work surfaces.
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GENERAL REGULATORY GUIDANCE FOR NEW MEXICO SMALL BUSINESSES
The purpose of this document is to assist small businesses in New Mexico in trying to understand
the environmental regulatory requirements associated with doing business. It is not intended to
be a substitute for actual regulations. Businesses are responsible for operating in full compliance
of the law (regulations). Each bureau in the New Mexico Environment Department (NMED) has
staff available that can help in understanding what is expected of a business from a regulatory
point of view.
The Pollution Prevention (P2) Program in NMED will periodically issue specific guidance
materials as an attachment to this document for certain businesses. These will be designed to
provide additional information to a specific business. For information call the NMED Pollution
Prevention Program staff at 505-827-0677 or the Technical Resource Center in Albuquerque at
505-843-4251.
AIR EMISSION REGULATIONS:
The EPA, in an attempt to control air pollution through regulations, has created a set of rules
with many acronyms. Since businesses can come across these acronyms in many publications,
they are listed below:
NESHAP: National Emission Standards for Hazardous Air Pollutants
NAAQS: National Ambient Air Quality Standards
HAP: Hazardous Air Pollutants
TAP: Toxic Air Pollutants
OEL: Occupational Exposure Limits
VOC: Volatile Organic Compounds
MSDS: Material Safety Data Sheet
CTG: Control Techniques Guidelines
MACT: Maximum Achievable Control Technology
BACT: Best Available Control Technology
GACT: Generally Available Control Technology
RACT: Reasonably Available Control Technology
Much of the national strategy for controlling air pollution centers around the NAAQS. These
standards set limits for the concentration in the ambient (outdoor) air of the six most common air
pollutants: ozone, carbon monoxide, particulate matter, sulfur dioxide, nitrogen dioxide, and
lead.
The EPA has established industry based regulatory requirements for the most serious air
pollutants, such as HAPs. In many cases the EPA has also established Control Techniques
Guidelines that require industries to use certain technologies, such as MACTs.
-------
Any business that has the potential of releasing pollutants to the ambient (outdoor) air, such as
VOCs, HAPs, or Criteria Pollutants, may be subject 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 that they conduct 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 aid in understanding 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 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 operations with the ultimate goal
of eliminating all air pollutants as much as possible.
The Air Quality Regulations that apply to you're the business will mostly be determined by what
the business does. The best way to find out what air quality regulations apply 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, call the City of Albuquerque/Bernalillo Air Quality
Assistance Program (AQAP) at 505-768-1964.
HAZARDOUS WASTE REGULATIONS:
Any business that generates waste that is classified as "listed" or "characteristic" in RCRA must
deal with this waste as outlined in the New Mexico Hazardous Waste Regulations. The EPA has
generated a list of chemicals that are considered hazardous. They have also stated that certain
materials that exhibit a hazardous characteristic (ignitibility, corrosivity, reactivity, or toxicity)
should be considered hazardous. To determine which products contain hazardous material,
contact either the EPA or the New Mexico Hazardous Waste Bureau. In some cases this
information will be contained on the Material Safety Data Sheet (MSDS) that came with the
product.
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It is important to understand that any product that contains "listed" or "characteristic" material is
only regulated by the hazardous waste regulations when it becomes a waste. Examples include:
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 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.
Please 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
business' classification is based on a monthly generation, it is possible to move from one
classification to another on a regular basis. All generators of hazardous waste are required to
register with the Hazardous Waste Bureau and pay a generator fee based on the 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. 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. 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 that trained employees handle the hazardous material properly to avoid
accidental spills, that the facility only uses permitted haulers, that the waste goes to a RCRA
permitted facility, that the waste is properly stored, and that hazardous waste is never disposed of
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at the facility. It is also advisable to seal the floor of the facility if hazardous materials in a liquid
form are used in the operation.
The best way for any business to avoid the costs of contamination clean up is to eliminate the use
of hazardous materials in the 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 clean up. If the contaminant is a RCRA "listed" or
"characteristic" waste above the concentration value allowed, then the wastewater is by
definition a hazardous waste and must be dealt with under New Mexico Hazardous Waste
Regulations. Placing hazardous wastewater directly onto or into the ground is strictly prohibited.
Since the cost of cleaning up either surface water or ground water can be substantial, it is in the
best interest of any business to eliminate, minimize, and/or control its wastewater.
If non-hazardous wastewater is being discharged so that it can move directly or indirectly into
ground water (e.g. septic system, dry sump, etc.), a business is required to file a "Notice of Intent
to Discharge" with the New Mexico Ground Water Bureau in accordance with the NM Water
Quality Act. The Bureau will then determine if the business requires a Discharge Permit. In some
cases the business may be required to request a NPDES Permit from the EPA if the discharge is
to surface water.
If non-hazardous wastewater is being placed into a sewerage system, a business is required to
notify the local Publicly Owned Treatment Works (POTW) of 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 wastewater going into the sewerage systems is
allowed by the POTW, this does not necessarily relieve the potential contamination liability. A
good example is a leaking sewer pipe containing hazardous constituents below RCRA levels
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 clean up. Most businesses will
find that the costs associated with proper handling of the wastewater are far cheaper than the cost
of cleaning up ground water.
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Another potential source of contamination is through the foundation of a building. If a business
handles hazardous material as a regular part of doing business and a spill occurs that seeps
through cracks in the floor, it will eventually reach ground water. This spill can be detected
through monitoring of the ground water. Assuming that 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, or cafeterias should
evaluate ways in which the wastewater can be eliminated, reduced, recycled, reused, or handled
in such a fashion that the risk of liability for contaminating surface water or ground water is
virtually zero. This should include dealing with hazardous waste and all wastewater in a proper
fashion, sealing cracks in floors, training of employees, and possible treatment of their
wastewater before it leaves their premises.
If you have any questions you can contact the Ground Water Bureau at 505-827-2965 and the
Surface Water Bureau at 505-827-0187.
OSHA REGULATIONS:
Every business is required to provide a safe and healthy working environment for its employees.
The Occupational Health and Safety Bureau (OHSB) is responsible for making sure businesses
are in compliance with OSHA regulations. OSHA regulates permissible exposure limits (PEL's)
for employees exposed to certain air contaminants in the workplace. The Bureau conducts
regular inspections of facilities and evaluates the establishment for safety and health compliance.
The OSHB has a consulting program to assist facilities to be in compliance with OSHA
regulations. The service is free of charge to New Mexico small businesses. Attached is a copy of
"Frequently Asked Questions" about the program, a copy of "General Health & Safety Issues,"
as well as a poster to display at your facility. The OSHB 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.
Since there are a variety of circumstances whereby UST 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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SPECIFIC REGULATORY GUIDANCE FOR LITHOGRAPHIC PRINTERS
This briefing paper is intended to be attached to the "General Regulatory Guidance for New
Mexico Small Businesses" to provide additional regulatory information specifically for
"Lithographic Printers". 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:
To establish if your business is a major or minor source you will need to calculate the amount of
ink, cleaning solvent, blanket wash solvent, and fountain solution you will use per year and their
contribution to VOC and HAP emissions. This is best done in conjunction with the Small
Business Assistance Program staff. They can be contacted 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 Printers" that can assist you
in being compliant with Hazardous Waste Regulations. Characteristic wastes unique to the
printing industry are as follows:
• Ignitability: Chemical products such as blanket and roller washes, cleanup solvents,
isopropyl alcohol, and inks. Contaminated shop towels being thrown out for disposal.
• Corrosivity: Plate and film processing chemicals, particularly etching chemicals. Acids,
waste battery acid, and alkaline cleaners, depending on their pH.
• Reactivity: Waste Bleaches and oxidizers.
• Toxicity: Waste fixer, plate processing chemicals, ink, and cleanup solvents, and specific
pesticides.
Many other chemicals are used that would contain "listed" constituents. Most of the "listed"
wastes are in the "F" category, which are generally solvents. Typical examples are isopropyl
alcohol, methanol, toluene, and trichloroethane, others are listed on the "Fact Sheet for Printers".
If in doubt, check with the Hazardous Waste Bureau.
WASTEWATER REGULATIONS:
The greatest potential problem is the silver in the films and fixer. Used fixer should either be sent
to a recycler or treated on site by using a silver recovery system such as one with metallic
replacement cartridges. Never discharge fixer to the sanitary sewer system without recovering
silver and without permission from the Publicly Owned Treatment Works (POTW).
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OSHA REGULATIONS:
Attached to this document is a checklist entitled "Printing Industry Health & Safety Checklist"
that can assist you in being compliant with OSHA.
UNDERGROUND STORAGE TANK REGULATIONS:
There is nothing unique in the printing industry that isn't already covered in the General
Regulatory Guidelines.
SOLID WASTE REGULATIONS:
There is nothing unique in the printing industry that isn't already covered in the General
Regulatory Guidelines.
ADDITIONAL SOURCES OF INFORMATION:
An EPA document "Federal Environment Regulations Potentially Affecting the Commercial
Printing Industry" (EPA744B-94-001) is available that can help you understand the federal
regulations. Keep in mind that all state regulations are required to be at least as strict as the
federal regulations. Some New Mexico state regulations, such as the Air Quality and Hazardous
Waste Regulations, refer to the federal version in their implementation.
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Pollution Prevention and Regulatory Compliance Contacts for New Mexico
STATE AGENCIES:
Green Zia Environmental Excellence
Program
Occupational Health & Safety Bureau
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(g),nmenv.state.nmus
Hazardous Waste Bureau
Debby Brinkerhoff
NM Environment Department
2044 Galisteo
P.O. Box 26110
Santa Fe, NM 87502
505-827-1511
FAX: 505-827-1833
E-mail:
debbv brinkerhoff(@,nmenv.state.nmus
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 mcelrovtginmenv.state.nm.us
Ground Water Quality Bureau
Industrial Waste Team Leader
NM Environment Department
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
505-827-2900
FAX: 505-827-2965
Solid Waste Bureau
Phillip Westen
NM Environment Department
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
505-827-0559
FAX: 505-827-2902
E-mail:
Phillip westen(@,nmenv.state.nm.us
Underground Storage Tank Bureau
Joyce Shearer, Ph.D.
NM Environment Department
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
505-476-3779
FAX: 505-827-0310
E-mail:
Joyce shearer(@,nmenv.state.nm.us
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Please note that a list of all Public Owned Treatment Plants (sewage treatments
plants) are listed for all of New Mexico on the following page. Waste Treatment
Plant operators are important regulatory contacts for small businesses. Please
refer to the list and contact your local plant operator for information specific to
your community and business.
City of Albuquerque
Public Works Department
Bob Hogrefe
Southside Water Reclamation Plant
4210 Second Street, SW
Albuquerque, NM 87185
Ph: 873-7030
Fx: 873-7087
Rhogrefe(@,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: iriberatore(@,CABQ.gov
New Mexico State University
WERC P2 Center
1155 University Blvd., SE
Albuquerque, NM 87106
505-843-4251
E-mail: chrisc@werc.net
Online Resources:
US EPA Printing Compliance Assistance Centerwww.pneac.org
US EPA: Design for the Environment: www.epa.gov/opprintr/dfe
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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 printing industry. Please contact Bob Hogrefe at
505- 873-7030 for a copy.
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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.
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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.
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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New Mexico Occupational
Health & Safety Bureau
New Mexico Environment Department 525 Camino de los Marquez - PO Box 26110
Santa Fe, New Mexico 87502 (505) 827-4230 Fax (505) 827-4422
Printing Industry Health & Safety Checklist
YES NO
Photo Developing Section
D D Is an eyewash station available within close proximity?
D D Do employees have somewhere to wash in the event of contact with the chemicals?
D D Is PPE provided to the employees (i.e. safety glasses with side shields, gloves,
etc.)?
D D If so, have employees been trained on the proper use of PPE?
Press Section
D D Are all pinch and nip points within the presses where employees work (cleaning or
maintenance) covered or guarded?
D D Has an assessment been made to ensure that employees are not overexposed to
noise?
D D If no, have steps been taken to avoid noise overexposure (i.e. noise sampling, PPE availability, or
audiograms, etc.)?
D D Are chemicals (i.e. wash, inks, etc.) properly stored and labeled?
D D Is PPE, where needed, available to the employees (i.e. ear protection, gloves, safety
glasses, etc.)?
D D If so, have employees been trained on the proper use of the PPE?
Paper Binding and Cutting
D D Are the points of operation guarded (i.e. cutting shares, folding, and binding
sections)?
D D Are pinch or nip points guarded within the machine?
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YES NO
D D Has an assessment been made to ensure that employees are not overexposed to
noise?
D D If no, have steps been taken to avoid noise overexposure (i.e. noise sampling, PPE availability, or
audiograms, etc.)?
Maintenance Section
D D Does the employer contract out repair and maintenance work to an outside
company?
D D If no, does the company have a written lock-out/tag-out program?
D D Do procedures exist that detail the steps to isolating specific machines from all their energy
sources (i.e. electrical, mechanical, pneumatic, chemical, gravity, etc.)?
D D Are employees adequately trained on these procedures?
General Housekeeping
D D Are isles and passageways free of clutter?
D D If forklifts are used within the facility, are they battery powered?
D D If no, have precautions been taken to avoid an employee's overexposure to carbon monoxide gas
(CO)?
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
CONSULTA TION 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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New Mexico Occupational
Health & Safety Bureau
New Mexico Environment Department 525 Camino de los Marquez - PO Box 26110
Santa Fe, New Mexico 87502 (505) 827-4230 Fax (505) 827-4422
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,
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D D Is the path unobstructed?
YES NO
D D Are they subjected to an annual inspection?
D D Are employees trained to use them?
If not,
D D Is there a written policy that requires employee evacuation?
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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New Mexico Occupational
Health & Safety Bureau
New Mexico Environment Department 525 Camino de los Marquez - PO Box 26110
Santa Fe, New Mexico 87502 (505) 827-4230 Fax (505) 827-4422
CONSULTATION/TECHNICAL SERVICES
FREQUENTLY ASKED QUESTIONS
What is the Consultation Service all about?
The Consultation program provides safety and industrial hygiene surveys of workplaces, along with
evaluation of, and assistance with establishment of safety and health programs. Although the service
was established by the same Act that created the Occupational Safety and Health Administration, and
the associated enforcement/compliance agencies on the federal and state level, the Consultation Service
does not issue fines or penalties. Since the same regulations are covered, the service allows the
employer to benefit from the professional assistance, without fines being imposed.
What does your service cost and who is eligible?
The Occupational Health & Safety Bureau (OHSB) offers consultation services free of charge to New
Mexico employers with 250 or less employees on location or 500 statewide. Limited services are
available to larger companies. Consultation is offered only at the request of an employer.
What types of places do you visit?
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?
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Depending on the size of the company and the scope of the visit, a consultation may take anywhere
from one or two hours to a full day. If exposure monitoring is requested or recommended, another day
is often scheduled.
What kinds of things do you look at?
In order to evaluate the systems in place, sufficient information from the employer may be needed.
This would include assessing existing safety and health programs, the OSHA 200 logs, accident
investigation reports, and a walk-through of the facility to identify potential injury and illness hazards
in the workplace.
Do we have to let you in all areas?
You, the employer makes that determination. If you requested a comprehensive survey, the consultant
will look at all areas.
Can it be arranged for both the safety and the industrial hygiene visits to be conducted on the same day?
Visits are scheduled based on the caseload of the consultants. Where the caseloads
permit such an arrangement can be made.
Do I (the employer) have to fix everything you find?
The employer is obligated to correct all serious hazards found by the consultant, within a reasonable
time frame. Time extensions are granted for abatement of hazards when needed, if the employer is
providing interim protection for employees.
How are hazards classified as "serious" & "other than serious"?
A serious violation results where there is substantial probability that death or serious physical
harm could result. An other than serious violation is a hazard that has a direct relationship to job
safety and health, but probably would not cause death or serious physical harm.
How much will it cost to correct/fix the hazards identified?
Usually, it is not prohibitively costly to correct hazards identified by our consultants.
However, where cost becomes an overriding consideration or where the employer can show that
engineering controls are not feasible the employer may seek a variance from OHSB. In this case the
employer must show that a combination of work practices, administrative controls, and personal
protective equipment will provide equal or better protection for the employees.
Do you come back to verify hazard correction?
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.
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How do we request an extension of time on corrections?
All extensions have to be requested in writing. The letter should include the reason for the
extension, what has been done to date to correct hazards; and if corrections have not been made,
the employer must state what interim measures have been taken to protect the employees.
What is the SHARP Program all about?
SHARP or Safety and Health Achievement Recognition Program is one of our special
programs for companies wishing to go the extra mile to establish a fully functional overall safety
and health program, in addition to the correction of hazards. SHARP is primarily a recognition
program for exemplary companies, but an added incentive for SHARP participants is a one-year
exemption from OHSB's general schedule inspections.
Does Sharp keep OHSB enforcement out in all cases?
No, At SHARP sites, OHSB will continue to make inspections in the following situations:
imminent danger;
fatality/catastrophe;
formal complaints;
referral from other government agencies; or
follow-up on previously cited violations.
Where can I get information on establishing written programs (i.e. blood borne pathogen, hazard
communication, confined space, etc?
Many of the safety and health programs are available through the New Mexico Occupational
Health & Safety Consultation Program. They are available upon request.
How do we know which elements of the safety and health program requirements need to be fixed, if it
doesn't show up on your report to us?
It is addressed in the safety & health program management section of the report the employer
receives. These issues are also discussed by the consultant with the employer.
Is it necessary to have a written certification of hazard assessment at work sites that do not require (PPE)
Personal Protective Equipment for any task?
Yes, according to 1910.132(d)(2), the employer shall verify that the required workplace hazard
assessment has been performed through a written certification that identifies the workplace
evaluated.
Can you come to our company and conduct a class or safety meeting?
Onsite training and education by consultants will be based on available resources and the
employers request. The training and education will be tailored to the nature of the hazards or
potential hazards in each specific workplace. Training in specific areas is also available through
private consultants and the New Mexico Workers Compensation Administration or your insurer.
Can the consultant come back for specific things such as checking new equipment or processes that we
bring on line?
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Yes, Visits for specific purposes can be requested, in addition to regular consultation visits.
May I call your office anytime to ask questions?
Consultants are available to answer questions between 7-5pm Monday-Friday
Can anyone gain access to my report?
No, our files are confidential and are destroyed after 3 years.
Will a consultation visit lead to an inspection by OSHA compliance? Will your findings be passed on
them?
All information is kept confidential. OHSB compliance inspectors cannot discover where we have
been and then inspect those companies. The only time enforcement is contacted, is if a company
neglects to correct serious hazards beyond time extensions. Then we are obligated to refer those
items to enforcement, but only after we have made every attempt to work with the company.
What determines when a compliance inspection is going to occur? How do they decide whom they are
going to visit?
Factors that may trigger a compliance inspections include:
formal complaints by employees or their authorized agents;
fatalities;
catastrophe or major incidents;
history of the company (previous OSHA activity);
referral by other governmental agencies;
general schedule inspections; or
special emphasis programs
Have you been or will you go to my competitor?
Our service extends to all eligible companies who request it. All information is kept confidential;
therefore, no hazards, or processes that may be a trade secret, seen in your facility will be
discussed in another place of business.
Where can I get a copy of the regulations?
The Government Printing Office (GPO) processes all sales and distribution of the CFR. For
payment by credit card, call (202) 512-1800, M-F, Sam to 4 pm or fax your order to (202) 512-
2250, 24 hours a day. For payment by check, write to the Superintendent of Documents, Attn:
New Orders, PO Box 371954, Pittsburgh, PA 15250-7954. Regulations and other material are
available on the Internet at www.osha.gov.
-------
Quality Publications Links
A number of articles have been published that demonstrate how the Baldrige
model and the Green Zia program can be used to measure environmental
performance and drive environmental excellence.
These articles are copyrighted by John Wiley & Sons. No part of these reprints may
be reproduced in any form or by any means, except as permitted under Section 107
or 108 of the 1976 United States Copyright Act, without either the prior written
permission of the publisher or authorization through the Copyright Clearance Center,
222 Rosewood Drive, Danvers, MA 01932 (978-750-8400). Permission has been
given for the articles to be posted on Dr. Pojasek's web site for your personal use.
You may obtain permission to reproduce these reprints by writing to:
Permissions Department
John Wiley & Sons, Inc.
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Striving for Environmental Lessons Learned and the
Excellence with the
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How to Build
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EMS Conformance
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Environmental Excellence
How Do You Measure
Environmental
Performance?
How to Build Performance Into the Responsible
Care® MSV Conformance Standard
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-------
Green Zia Information
The Green Zia Program is a unique environmental excellence program in the
State of New Mexico http://www.nmenv.state.nm.us/ UJij£> (Scroll down to
"Special Programs"). It is a voluntary program designed to support and assist all
New Mexico businesses to achieve environmental excellence through continuous
improvement and effective energy management. The program encourages integra-
tion of environmental excellence into business operations and management prac-
tices through the establishment of a prevention-based environmental management
system. The Governor of New Mexico makes recognitions and awards annually to
organizations that successfully participate in the program. Even though your busi-
ness may not be located in New Mexico, you can use this program as a means of
self-evaluation. In this manner, you can start a performance-based environmental
management system or use it to be more successful with your conformance-based
environmental management system such as ISO 14001.
The Green Zia Criteria Document (2001)
Green Zia Application Writer's Workshop (2001)
Green Zia Examiners Training (2001)
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-------
Baldrige Model Information
When it comes to measuring business excellence, most companies turn to the
Baldrige model. This model grew out of the Malcolm Baldrige National Quality
Award Program as administered by the U.S. Commerce Department's National
Institute of Standards and Technology (NIST). This program has been called, "The
single most influential document in the modern history of American business." The
Baldrige model measures performance with a unit-less number on a 1000-point
scale. For the past seven years, a hypothetical stock index made up of publicly
traded U.S. companies that have received the Malcolm Baldrige Award has outper-
formed the Standard & Poor's 500 Index by almost 5 to 1. Currently about 60 coun-
tries and 44 of the 50 states have programs patterned after the 13-year old Baldrige
program. Many other organizations - including the United Way, trade associations,
government agencies and private companies - have created their own performance
programs based on the Baldrige model. Whether they intend to apply for the award
or not, thousands of organizations assess their performance against the Baldrige
criteria. By doing so, these organizations improve their competitive advantage,
productivity, and customer and employee satisfaction while achieving stronger
financial performance and overall business results. Information on the program is
available on the NIST Web site at http://www.quality.nist.gov. Zia£>
Several important documents from this site have been placed on this CD-ROM.
Getting Started: A Guide to Self Assessment and Action
Why Apply?
2001 Criteria for Performance Excellence
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-------
P2 and the Quality Model
Chapter 7 of the Guide presents a quality model for developing a performance-
based environmental management system (EMS). This type of EMS can also
be used to implement a pollution prevention (P2) program. This section of the
CD-ROM is designed to help introduce you to these sources of information. For
convenience, this information is provided in three sections:
• Publications on the Quality Model
• Information on the Green Zia Program (New Mexico)
• Background information on the Baldrige Program.
Quality Model Publications - There are reprints on the use of the quality model for
environmental performance. These articles are copyrighted and meant for your
personal use. You will need to have your Internet connection activated to access
these reprints from the CD-ROM.
Green Zia Information - The New Mexico Green Zia Program is a unique deriva-
tive of the Baldrige program designed to measure environmental performance.
Program information is provided on the CD-ROM as well as links to other Internet
sites with additional program information.
Background Information on Baldrige - The Malcolm Baldrige National Quality
Award offers a proven means of enhancing business performance. There is much
background information on the use of the Baldrige principles to help your organi-
zation develop and implement a prevention-oriented environmental performance
program.
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Publications Links
Green Zia Information
Baldrige Info.
-------
Reprints on P2 Tools
A series of articles on the P2 Tools presented in An Organizational Guide for
Pollution Prevention appears in the John Wiley and Sons journal, Pollution
Prevention Review. These articles were written by Robert B. Pojasek, Ph.D.,
Pojasek & Associates.
These articles are copyrighted by John Wiley & Sons. No part of these reprints
may be reproduced in any form or by any means, except
tion 107 or 108 of the 1976
as permitted under Sec-
United States Copyright Act, without either the prior
written permission of the publisher or authorization through the Copyright Clearance
Center, 222 Rosewood Drive, Danvers, MA 01 932. (978-750-8400). Permission has
been given for the articles to be posted on Dr. Pojasek's web site for your personal
use. You may obtain permission to reproduce these reprints by writing to:
Permissions Department
John Wiley & Sons, Inc.
605 Third Avenue
New York, NY 101 58-001 2
(212)850-6011
permreq@wiley.com
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pdf Using the Systems
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Activity-Based Costing
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Finding P2 Alternatives
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pdf Process Mapping
625k
pdf Selecting P2
541k Opportunities
pdf Prioritizing P2
538k Alternatives
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Root Cause Analysis
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pdf Implementing P2
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Sector Approachs to Using P2 Tools
The New Mexico Environmental Department (NMED) has prepared manuals for
five industrial and commercial sectors to demonstrate how the tools can be
used. These files are in .pdf format. The user should check the NMED website for
any additional information regarding the use of these tools.
Click on the title to view the Sector Manual.
Printing Industry
Wood Working
Jewelry Manufacture
Dry Cleaning
Auto Repair
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-------
Information on the P2 Tools
Chapter 4 of the publication An Organizational Guide to Pollution Prevention
mentions a number of tools that can be used in the P2 implementation strate-
gies covered in Chapters 5-8 of the Guide. This section of the CD-ROM is de-
signed to provide more information on these tools in three categories:
• Reprints on each P2 tool
• Nothing to Waste Manual
• Sector Approaches to using the P2 tools
Reprints - There is a reprint on the use of each of the P2 tools. These articles
are copyrighted and meant for your personal use. You will need to have your
Internet connection activated to access these reprints from the CD-ROM.
Nothing to Waste Manual - This manual was designed to teach the P2 tools to
very small businesses. You may find it useful to help you learn the tools. A pdf
version of this manual is on this CD-ROM. A link is also provided to a version on
the Internet.
Sector Approaches - The Green Zia Program in New Mexico has used the P2
tools to develop sector approaches in the following industries: printing, dry clean-
ing, wood working, jewelry, and auto repair. These documents will provide you
with an idea of what the tools look like in practice.
Back HOME
Reprints on Each P2 Tool
Nothing to Waste Manual
Sector Approaches
-------
Training Case Study
During the presentations of the Guide to the regional offices, exercises
have been prepared using the printing industry as an example. For those
seeking to train their staff on the use of the manual, the following
sources may provide useful information on the printing industry: WWW
EPA Printing Web Site
P2Rx Printing Web Site
Industry Printing Web Site
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Backto Manuals Page
-------
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
Wood Working Shops
Guidance for improved environmental
performance and pollution prevention in
your woodworking 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 the Green Zia Program at the New Mexico Environment Department.
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 Wood Working Shops Page 5
Process Maps for Wood Working Shops Tab 1
Wood Working Shop Regulatory Guidance, Pollution Prevention Ideas
and Other Resources Tab 2
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The Green Zia
Environmental Excellence
Program
Guidance materials for woodworking shops
Introduction
This packet contains information on how to establish a pollution prevention program
specifically for a wood working 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 a wood working 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!
-------
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.
-------
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 wood working 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 wood working 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.
-------
This page left blank intentionally.
-------
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 in to this establishment -
inch4de 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?
-------
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 wood working operations and are
included in this packet. You should customize these maps for your operation, since no
two businesses are exactly alike. These maps become a reference for you to use for your
pollution prevention program and can be updated to reflect changes as you improve your
operations. These maps are also great for training new employees and 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.
-------
Example of a process map for Prefmishing:
Wood
Filler PPE
V V
3.1
Fill Nail Hole
V
Spent
3. Prefinishing
Putty Sander Sand
Knife ppE paper Energy
1 „ 1 „
3.2
s
V 1
' V V
Air Filller Wood Used Sand
Solvent Emissions Particulates Dust Paper
Sander pPE Energy Sand Acetone^ Bmsn ^^
V_L^
3.4
Sanding
Resin Wood
Particulates Dust
!
, i ., i
3.5
^ [-,-„„;„-*;-„
1 I
Wood Used
Used Sand ^ Rosin T Brush T
RaPer Spent Air Spent
Acetone Emissions Ammonia
Water Bmsn Rags Resin
I
V
Spent
Solvent
„ I „
3.3
se Wood Fibers
V V
— *
Dirty Resin
Rag Particulates
H3ydr°9en Brush
Peroxide
v
Spent
Bleach
V
3.6
Bleaching
*
Alr Used
Emissions Bmsn
Please review the process maps in the back of this booklet and make changes to
reflect your operation.
Once you have reviewed and revised the process maps to your
operation, move to the next section...Activity-Based Costing!
-------
This page left blank intentionally.
-------
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:
• Drying lumber
• Machining lumber
• Pre-Assembling
• Prefinishing
• Applying a coating
• Finishing
• Final assembly
Intermittent activities:
• Compressor maintenance
• Spray gun cleaning
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 using solvent-based
materials for applications and cleaning 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
Wood Putty
Filler PPE Knife
3. Prefinishing
Sander
PPE
3.1
Fill Nail Holes
i i i
Paper
Energy
3.2
Initial Sanding
Water Brush Rags Resin
ii i 1
3.3
Raise Wood Fibers
Spent
Solvent
Air
Emissions
Filller Wood
Particulates Dust
Used Sand
Paper
Spent
Solvent
Dirty Resin
Rag Particulates
s
R
Parti
an
i
,1 I
3.4
Sanding
i
es
;ul
' T i
n Wood USE
ates Dust F
Ac
2tO
1
ne Bm
,7 J
Ammonia
,i
3.5
Derosination
r
id Sand '
3aPer Sper
Aceto
Wood ,
Rosin
t A
ie Emiss
Used ,
Brush
r
ions An
Hydrogen
Peroxide
V
Brush
V
3.6
Bleaching
i
r sp<
Spent Ble£
nmonia
' 1 T
;nt Air
ich Emissio
T
Usec
13 Brus
Activities
Materials and Losses
Drying lumber
Machining lumber
Pre-Assembling
Pre-Finishing
Applying a coating
Finishing
Final assembly
Compressor maintenance
Spray gun cleaning
Energy
Adhesives
* Sol vents
Acetone
Personal Protection Gear
Ammonia
Bleach
*Filters
* Stain
*Lacquer
*Polyurethane
* Shellac
(*) Indicates most important waste streams
and materials
-------
Table 1. Activity-Based Costing Analysis (Per year)
Workstep
Costs
/Losses
Labor
Raw
material
Disposal
fees
Other
ledger
costs
Hidden
Costs
Total
%of Total
Shellac
$650
$1,000
($200)
$1,850
9.5
Stain
$1,300
$1,500
($400)
$3,200
16.5
Lacquer
$50
$75
($200)
$325
1.7
Solvent
Use
$2,000
$5,000
$150
($2,250)
$9,400
48.2
Filters
$800
$850
$450
($2,300)
$4,400
22.6
Poly-
Urethane
$100
$50
($150)
$300
1.5
Total
$4,900
$8,475
$450
$150
($5,100)
$19,475
Table 2. Hidden Cost Analysis (per year)
Shellac
Activities/Cost
Factors
Storage
Recordkeeping
Materials
X
Space
X($150)
Utilities
X
Services
X
Total hidden costs for shellac
Labor
X
X ($50)
($200)
Stain
Rags Laundry
Storage
Recordkeeping
X
X
X
X($150)
X
X ($200)
X
Total hidden costs for stain
X
X
X ($50)
($400)
Lacquer
Storage
Recordkeeping
X
X($150)
X
X
Total hidden costs for lacquer
X
X ($50)
($200)
Solvent Use
Recordkeeping
Permit fees
Monitoring
Storage
Reporting
Rags Laundry
Vent Equip.
X
X ($200)
X
X
X
X
X ($300)
X
X
X
X
X
X
X
X ($400)
X
Total hidden costs for solvent use
X ($50)
X
X ($800)
X
($50)
($450)
($2,250)
Filters
Disposal
Recordkeeping
Generator Fees
X
X
X
Total hidden costs for filters
X ($1,500)
X ($50)
X ($750)
($2,300)
Polyurethane
Storage
Recordkeeping
X
X($100)
X
X
Total hidden costs for polyurethane
X
X ($50)
($150)
-------
Environmental Costs
to
t/5 $8,000
o
^ $6,000 "
to
3 $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
-------
Table 2. Hidden Cost Analysis (per year)
Activities/Cost
Factors
Materials
Space
Utilities
Services
Labor
Waste Stream
Monitoring
Reporting
Rags Laundry
Disposal
VentEquipt.
Storage
Recordkeeping
Generator fees
Total hidden costs for (waste stream)
Waste Stream
Monitoring
Reporting
Rags Laundry
Disposal
Vent. Equip.
Storage
Recordkeeping
Generator fees
Total hidden costs for (waste stream)
Waste Stream
Monitoring
Reporting
Rags Laundry
Disposal
Vent. Equip.
Storage
Recordkeeping
Generator fees
Total hidden costs for (waste stream)
-------
This page left blank intentionally.
-------
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
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
-------
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 wood working 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.
-------
Since solvent use is related to the types of materials used for the finishing operations, the
type of spraying operations used to apply the materials, and the requirement to clean to
spraying equipment with solvent, several things may come to mind. The present spraying
operation uses a high-pressure gun to atomize the material, which is susceptible to
overspray, resulting in more finish waste and less transfer efficiency. This also means
that the filter in the spray booth will collect more material requiring frequent
replacement. Workplace conditions such as poor lighting may lead to poor application of
materials to the furniture parts. 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 wood working 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.
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.
-------
Figure 1: Prefinishing - Process Map
3. Prefinishing
Wood Putty Sander sanH
Filler PPE Kn
V V V
3.1
Fill Nail Holes
V V
ife ppE
T 1
Paper Energy
. 1 .
3.2
V
Spent Air Filller
Solvent Emissions Particulates
V V
Wood Used Sand
Dust Paper
SanderppE Energy Sand Acetone^ Bmsn ^^
., i .,
3.4
Sanding
Resin Wood U
Particulates Dust
L U
"-^
3.5
^ [-,-„-;„„*;„„
i
T Woe
I
d Used
sed Sand t Rosjn T Bmsh T
PaPer Spent
Air Spent
Water Brusn Rags Res
1,, 1 „
3.3
V V V
in
»
Spent Dirty Resin
Solvent Rag Particulates
Hydr°9en Brush
Peroxide
V V
3.6
*
Spent Air Used
Bleach Emissions Brush
Acetone Emissions Ammonia
-------
Figure 2: Cause and Effect Diagram
Methods
using high
pressure
spray gun
using solvent
based material
poor lighting
Machines
workplace
conditions
requires solvent
c|ean up
poorPPE
equipment
spray gun
/
poor
maintenance
poor ventilation
^
spray booth
poor
maintenance
overs pray
- filters
type
type
mposition
/
/*-
\ \a Solvent
/* /* use
\^ ^/ not used attitude / ^_.^.
/ "^.^ / sufficient
dirty *- s reaulations
^^ brushes /* K reyuiduurio
Materials
People
proper
reporting
-------
Figure 3: Dear Abby Letter
Dear Abby,
We run a small wood working 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 wood working 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 high
pressure spraying operation that causes a lot of overspray and wasteful use of finishing
material. 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,
Wood working in Santa Fe
-------
Figure 4: Root cause analysis: Fishbone Diagram
Methods
Machines
Materials
People
-------
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 ?
-------
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 wood working 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 wood working 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.
-------
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.
-------
Figure 1: Wood Working Process Map
3. Prefinishing
Wood Putty
Filk
F
v
Spen
r PPE Knife
V V
3.1
II Nail Holes
t Air
Solvent Emissions
Sander ppE Energy Sand
V 1
Resin
Particulates
3.4
Sanding
r
Sander
PPE
,
r i
r
Sand
_ Energy
Paper a'
,
r i
r
3.2
i
Fil
Initial Sanding
r
ler
Particulates
i
Wo
r i
od Use
Dust
Acetone grL
PPE
i
,1
i
r
dSand
Paper
sn Ammonia
, I
3.5
Wood Used Sand 1
Dust Paper
Derosination
I
Woo
rl
r *¥UU- ^
Rosin
Spent
I
Jsed
Brush
Air
Water Brusn Rags Res
1
I „
3.3
^ i
Spent Di
od Fibers
r ]f
ty Re
in
*
sin
Solvent Rag Particulates
Hydrogen
Peroxide
V
Brush
V
3.6
;hing
*
r Spent Air u d
Spent
Bleach Emissions Brush
Acetone Emissions Ammonia
-------
Figure 2: Sample of brainwriting
1.
Use material that does not contain
solvents to eliminate all environmental
problems.
2.
Train people to use the spray gun
equipment better.
3.
Pre-finish furniture parts with rags or
brushes.
4.
Use old solvent to pre-soak spray gun
parts.
5.
Convert to natural finishes.
6.
Replace existing sprayer with new
equipment that uses high-volume/low
pressure.
7.
Send furniture out to be finished.
8.
Invest in better equipment.
9.
Provide incentives for employees who
reduce losses.
10.
Create an employee problem-solving
team to deal with waste of all kinds on
a regular basis.
-------
Figure 3: List of alternatives
1. Use material that does not contain solvents to eliminate all environmental problems.
2. Train people to use the spray gun equipment better.
3. Pre-finish furniture 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 spray gun parts
6. Begin an employee incentive program to reward best operating practices for operating
a clean work area.
7. Replace existing sprayer with new equipment that uses high-volume/low pressure.
8. Pay employees small bonus for keeping good environmental records including
hazardous waste and air quality records.
9. Create an employee problem-solving team to deal with waste of all kinds on a regular
basis.
10. Convert to natural finishes.
11. Train workers on pollution prevention and ways to reduce and reclaim spills.
12. Provide incentives for employees who reduce losses.
13. Invest in better equipment.
14. Send furniture out to be finished.
-------
Figure 4: Brainwriting Sheet
1. 2.
3. 4.
6.
8.
10.
-------
This page left blank intentionally.
-------
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.
-------
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.
-------
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!
-------
Figure 1: List of alternatives prioritized using Bubble-Up, Bubble-Down
1. Replace existing sprayer with new equipment that uses high-volume/low pressure.
2. Train people to use the spray gun equipment better.
3. Invest in better equipment.
4. Use material that does not contain solvents to eliminate all environmental problems.
5. Pre-finish furniture parts with rags or brushes
6. Use old solvent to pre-soak spray gun parts
7. Begin an employee incentive program to reward best operating practices for operating a
clean work area.
8. Pay employees small bonus for keeping good environmental records including hazardous
waste and air quality records.
9. Create an employee problem-solving team to deal with waste of all kinds on a regular basis.
10. Convert to natural finishes.
11. Train workers on pollution prevention and ways to reduce and reclaim spills.
12. Start a "clean shop" program to train employees to keep work areas clean to prevent spills
and waste.
13. Provide incentives for employees who reduce losses.
14. Send furniture out to be finished.
-------
Tool #6: Action Planning
Being able to successfully manage a project is important when trying to
accomplish a task, especially when you are under a deadline. You need to set up a
schedule, ensure that you have the necessary resources, and assign the right
person to each part of the job. In this tutorial you will create an "action plan" for
the implementation of an alternative to prevent pollution.
Warm-up Exercise
Your group has been assigned the task of making chocolate
chip cookies. The cookies need to be ready in one hour and
the cooking time is twelve minutes. Pick a person to manage
this project. The manager must then assign the ten tasks
listed below to individuals in the group.
You will need to know how much time is required for each
task, what tasks need to be accomplished before others, what
resources (i.e. bowls, flour etc.) are required, and what the most efficient way of organizing
these tasks (and remember the clock is ticking). Create a schedule.
Making chocolate-chip cookies:
Mix dry ingredients
Mix wet ingredients
Put the batter on the pan and put pan into the oven
Combining wet and dry ingredients
Turn on the oven
Taste cookies
Wash tools and utensils
Grease pan
Take cookies out of the oven
-------
Developing an Action Plan
Before you begin to implement your alternative you should complete this questionnaire. It will
ensure that you are being thorough in your planning and have considered all the important issues
that may arise such as the resources that are needed and the problems that 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
-------
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.
-------
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!
-------
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 Wood
Working Shops
-------
This page left blank intentionally.
-------
General Process Map for Furniture Manufacturing
1
Drying and
Machining
2
Pre- Assembly
3
Prefinishing
4
Coating
5
Finishing
6
Final Assembly
-------
Wood Working Shop Process Maps
Map 1.0: Drying and Machining
1.1 Drying kiln
Raw lumber generally has a high moisture content and must be dried before it can be used in
furniture. The lumber is usually dried in a kiln using wood waste as the fuel source.
1.2 Cut lumber to size
After the wood is dried, it is sawed into a shape of the approximate dimensions of the
individual furniture pieces. Power saws are generally used such as table saws, circular saws,
band saws, scroll saws, and radial arm saws.
1.3 Size flat surfaces
The cut pieces of wood are then planed to make two surfaces parallel, flat, and the final
dimensions of the furniture pieces. Both power and hand planner are used.
1.4 Smooth out edges
The wood is then sent through a joiner to square up the edges and make them the final
dimensions of the furniture pieces. This is generally done using a power joiner.
1.5 Form round pieces
Some of the pieces of furniture are required to be round such as table legs. This is done on a
power lathe.
-------
1. Drying and Machining
Heat
Energy
PPE
Energy
PPE
Energy
PPE
Energy
PPE
Energy
Raw
Wood
i
r i
r
1.1
Drying Kiln
i
Ene
r i
rgy A
Emis
r
ir
sions
\
(
i
Saw
, I
r
1.2
Cut Lumber
to Size
i
Nc
2h
r i
od T En
Ps Waste
Wood
r
ergy ^
Ss
Di
r
W
si
\
i
Planner
, 1
1.3
Size Flat
Surfaces
i
NC
;h
i
r SE
od Di
ps
r
W T
st Enerc
Joiner
1 I 1
r
1.4
Smooth
out Edges
V Saw i
Wood Dust Ene
Ships
1
Lathe
, I
r
1.5
Form Round
Pieces
r i
We
™ Ch
I
r Saw '
od Dust En
ps
Machined
Furniture
Pieces
r
ergy
Map 2.0: Pre-Assembly
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2.1 Place wood pieces in jig
Generally furniture is made up of sub-assemblies that are easier to handle and apply finishes
to. These sub-assemblies are made up from the wood pieces machined in the previous steps.
They are generally placed in some sort of a jig or merely clamped in place.
2.2 Glue pieces together
Many of the subassemblies are glued together using adhesives containing solvents.
2.3 Nail pieces together
Sometimes the subassemblies also require nailing. In some cases nailing is used instead of
glue. A power nailer is generally used.
2.4 Apply veneer
A veneer is sometimes applied to some of the surfaces. This is done using an adhesive that
contains solvents. Heat and pressure may also be applied.
2.5 Trim veneer
Usually the veneer is slightly larger than the surface it was applied to. This requires trimming
to insure a perfect fit. A power router is generally used.
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2. Pre-Assembly
Machined
Furniture
Pieces
Clamps
2.1
Furniture Jig
Glue
Adhesive Applicator
Rags PPE
2.2
Gluing
Air
Rags
Spent
Spent
Solvents
Emissions Adhesives
Pneumatic
Nailer Energy
Nails PPE
2.3
Nailing
Bent Energy
Nails
Pressure PPE
Heat Adhesive
2.4
Veneer Applied
Energy
Spent Air
Solvent Emissions
Energy PPE
Router
2.5
Veneer Trimming
V
Waste
Veneer
Energy
Furniture
Sub-Assembly
Map 3.0: Pre-Finishing
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3.1 Fill nail holes
If nails were used in the pre-assembly they are countersunk using a punch. A wood putty that
generally contains a solvent is then used to fill in the nail holes.
3.2 Initial sanding
The surfaces of the furniture pieces are then sanded after the putty has dried. This can be
done using either a hand or power sander such as a disk, belt, or roller sanding machine.
3.3 Raise wood fibers
To get an even smoother surface the furniture piece is sprayed, sponged, or dipped with
water to cause the fibers of the wood to swell and raise. After the surface is dried, a solution of
resin is applied and allowed to dry, causing the raised fibers to become more brittle.
3.4 Sanding
The raised fibers are then sanded down to form a particularly smooth surface. This can be
done using either a hand or power sander.
3.5 Derosination
Because certain types of wood contain rosin, which can interfere with the effectiveness of
certain finishes, a process known as derosination may be employed. This is accomplished by
applying a mixture of acetone and ammonia. This is generally applied by brush.
3.6 Bleaching
Once the unwanted rosin is removed from the wood, bleaching is done to lighten the color of
the wood when the natural color is darker than the stain or finish to be applied. The process
entails spraying, sponging, or dipping the wood into a bleaching agent, such as hydrogen
peroxide.
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3. Pre-Finishing
Wood Putty
Filler Knife
Spent
Solvent
Air
Emissions
Sander Ener9V Sand
Filller Dust Used Sand
Particulates Paper
Water Rags
PPE
1 I 1
3.1
Fill Nail Holes
i
r i
i
i
PPE
, I
Pa
' 1
oe r
' i
3.2
Initial Sanding
i
f Wood i
r
Brush Resin
, I I
3.3
Raise Wood Fibers
i
I
f Dirtv i'
Spent
Solvent
Rag
Resin
Particulates
Resin Dust Used Sand
Particulates Paper
Acetone
Ammonia
qnpnt Rosin .. Brush _
bpent A|r Spent
Acetone Emissions Ammonia
Hydrogen
Peroxide Brush
PPE
1 ll
Paper
M J
3.4
Sanding
I
T Wood '
brush
, \\
PPE
M J
3.5
Derosination
' 1
\
' Wood '
I
' Used '
r i
r
3.6
Bleaching
' 1
I
r Air '
r
Spent Emissions Used
Bleach Brush
Pre-Finished
Sub-Assembly
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Map 4.0: Coating
4.1 Place furniture pieces in spray booth
Most coatings are applied by spraying.
4.2 Apply coating
The most common method of spraying used, is a spray gun powered by compressed air with
high pressure to atomize the coating material. Most of the stains used contain solvents. The
operators are required to wear protective personal equipment (PPE) such as masks.
nnnnnn
4.3 Light sanding
After the piece has been allowed to dry it is lightly sanded either by hand or with a power
sander. The piece may then be put back into the spray booth for an additional coating. Steps 4.2
and 4.3 are repeated as many times as necessary to obtain the desired appearance.
4.4 Wash coating
After staining, a washcoat, consisting of 2 to 13 percent solids by volume, is applied to the
furniture piece. Washcoating is used to aid in adhesion, assist in filling or color uniformity, and
partially seal the wood from subsequent staining operations. Nitrocellulose-based lacquers
containing solvents are generally used and are sprayed on.
4.5 Filling
Fillers are applied to the wood surface to produce a smooth, uniform surface for later stages
in the finishing process. Fillers usually range in solids contents from 10 percent to 45 percent by
volume in a solvent base. Fillers are usually spray applied, then wiped into the wood.
4.6 Sealing
Sealing consists of applying one or many coats of sealer. The primary purposes of sealers are
to provide adhesion, make sanding more effective, to seal the wood, and establish a foundation
for final finishing. Solids contents of sealers, such as polyurethane, typically range from 10 to 30
percent by volume in a solvent base. Sealers are usually sprayed on.
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4. Coating
1 Comp
1 A
1
1
1
!
Pre-Finished 41 1
Sub-Assembly 1
Place in Spray +
Booth
i
Spe
Solve
essed
r Spr;
PPE
r v i
4
Apply (
1
ayer Energy Sander Energy Sand |
Stain PPE Paper |
,ll 1 ll 1 i
2 4.3 1
1
"T I
r Energy i Spent T T
it Air Stain Coating Used Sand
nt Emissions Particulates Paper
Lacquer Sprayer
High Solid
Low-Voc
Material Wiper
Sprayer Polyurethane
1
PPE
, I
4.4
Wash Coating
i
I
' Spent '
r
1
PPE
, I
bpraye
, 1
4.5
Filling
i
I
r Dirty '
;r
i
PPE
, I
r
4.6
Sealing
I
' Air i
r Spent i
r
Coated
Sub-Assembly
Spent Lacquer Air
Solvent Emissions
Spent Filling Wipers Emissions
Material sPent
Solvent
Air Solvent Spent
Emissions Polyurethane
Map 5.0: Finishing
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5.1 Light sanding
After the sealer has been allowed to dry the furniture piece is lightly sanded either by hand or
with a power sander.
5.2 Apply topcoat
After the furniture piece has been coated, a topcoat, such as varnish or shellac, is applied in
one of the final stages of the finishing process. Top coats provide a clear coat whose function is
to protect the color coats, enhance the beauty of the furniture, and provide a durable finish.
Typical solids contents range from 13 to 30 percent by volume in a solvent base. Topcoats are
usually sprayed on.
5.3 Light sanding
After the piece has been allowed to dry it is lightly sanded either by hand or with a power
sander.
5.4 Apply second topcoat
A second topcoat is usually applied in the same fashion as outlined in step 5.2.
5.5 Rub out finish
Rubbing consists of the application of an abrasive in conjunction with a lubricant to level the
topcoat.
5.6 Polishing
Polishing consists of the application of soft abrasives or possibly only waxy ingredients to
increase the gloss. This is the final process finishing step.
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5. Finishing
Coated
Sub-Assembly
Sealer
Particulates
Used Sand
Paper
Shellac Sprayer
Energy
1 iJ
Rape
, I
5.1
Light Sanding
i
r i
PPE
1 I J
5.2
Apply Topcoat
I
T Air i
1
Energy
, I
Paper
1
5.3i
Light Sanding
i
r v
sPent Emissions sPent
Shellac Solvent
Shellac Used Sand
Particulates Paper
Shellac
Sprayer
Spent Emissions Spent
Shellac Solvent
Rubbing
Abrasive cloth
Spent Dirty
Abrasive Cloth
Polishing
Wax cloth
,. I ,
5.4
Apply Second Topcoat
v Air i
i
r i
5.5
Rub out
Finish
i
r i
*
r i
5.6
Polishing
i
r i
Spent
Wax
Dirty
Cloth
Finished
Sub-Assembly
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Map 6.0: Final Assembly
6.1 Place furniture sub-assemblies in jig
The sub-assemblies are generally held together in some sort of a jig or merely clamped in
place.
6.2 Connect sub-assemblies together
The sub-assemblies can be connected together using adhesives containing solvents, or nailed
together using a power nailer, or screwed together using wood screws, or bolted together using
bolts and nuts, or any combination of the above. As an example the process map 6.2, shows the
sub-assemblies being glued together.
6.3 Inspect final product
The furniture is inspected for any damage, imperfections, or missing pieces.
6.4 Repair any problems
This can included a variety of tasks such as filling in holes, refmishing an area of the
furniture, or replacing damaged sub-assemblies. As an example the process map 6.4, shows the
furniture having an additional coating of shellac. The furniture would most likely then be rubbed
out and polished as shown in steps 5.5 and 5.6.
6.5 Prepare for shipment
Generally furniture is packed in a cardboard container with some sort of material to protect it
from damage during shipment.
6.6 Ship to customer
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6. Final Assembly
Clamps
Finished
Sub-Assemblies
6.1
Furniture Jig
Glue
Adhesive Applicator
Rags PPE
6.2
Connect Sub-
Assemblies
Air
Rags
Spent
Spent
Solvents
Emissions Adhesives
6.3
Inspection
Shellac Sprayer
PPE
6.4
Repairs
T Spent
Spent Shellac Air
Solvent Emissions
Packing Cardboard
Material Container
Tape
6.5
Prepare for Shipment
Waste
Waste Tape Damaged
Packing Containers
Material
6.6
Ship to Customer
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Wood Working Shops
Regulatory and Pollution
Prevention Guidance and
Other Resources
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GENERAL REGULATORY GUIDANCE FOR NEW MEXICO SMALL BUSINESSES
The purpose of this briefing paper is to assist small businesses in New Mexico in trying to
understand the environmental regulatory requirements associated with doing business by giving
a general overview. It is not intended to be a substitute for actual regulations. Businesses are
responsible for operating their business in full compliance of the law (regulations). Each bureau
in the New Mexico Environment Department (NMED) have staff available that can help you
directly in understanding what is expected of your business from a regulatory point of view. It is
in your best interest to contact the appropriate bureau if you have questions.
Periodically the Pollution Prevention (P2) Program in NMED will issue specific guidance briefing
papers as an attachment to this document for certain businesses. These will be designed to
provide additional information to a specific business. For information call the NMED Pollution
Prevention Program staff at 505-827-0677 or the Technical Resource Center in Albuquerque at
505-843-4251.
AIR EMISSION REGULATIONS:
The EPA, in an attempt to control air pollution through regulations, has created a set of rules
with many acronyms. Since businesses can come across these acronyms in many publications,
they are listed below:
NESHAP: National Emission Standards for Hazardous Air Pollutants
NAAQS: National Ambient Air Quality Standards
HAP: Hazardous Air Pollutants
TAP: Toxic Air Pollutants
OEL: Occupational Exposure Limits
VOC: Volatile Organic Compounds
MSDS: Material Safety Data Sheet
CTG: Control Techniques Guidelines
MACT: Maximum Achievable Control Technology
BACT: Best Available Control Technology
GACT: Generally Available Control Technology
RACT: Reasonably Available Control Technology
Much of the national strategy for controlling air pollution centers around the NAAQS. These
standards set limits for the concentration in the ambient (outdoor) air of the six most common air
pollutants: Ozone, Carbon Monoxide, Particulate Matter, Sulfur Dioxide, Nitrogen Dioxide, and
Lead.
The EPA has established industry based regulatory requirements for the most serious air
pollutants, such as HAPs. In many cases the EPA has also established Control Techniques
Guidelines that require industries to use certain technologies, such as MACTs.
Any business that has the potential of releasing pollutants to the ambient (outdoor) air, such as
VOCs, HAPs, or Criteria Pollutants may be subject 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
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a business has the potential to emit. For HAPs it is 10 tons per year of any single HAP or 25
tons per year of the total HAPs. For the Criteria Pollutant it is 100 tons per year of any criteria
pollutant. In addition the State of New Mexico has added TAPs as a category to be regulated.
Some businesses that would normally be considered a major source can be classified as a
minor source by changing the way they conduct their business. Businesses classified as a
major source have significant regulatory requirements such as annual fees, maintaining
progress reports, records, and a compliance schedule, monitoring emission limits, as well as the
possible requirement to have specific control technology installed (MACT, GACT, or RACT). All
major sources are required to obtain a Title V Permit. It is generally desirable for a business not
to be classified as a major source. An EPA document "Potential to Emit, A Guide for Small
Businesses" (EPA-456/B-98-003) is available from the EPA and it may help you to understand
Air Quality Regulations.
The State of New Mexico, in addition to HAPs and Criteria Pollutants, has also generated
regulations on Toxic Air Pollutants (TAPs) with OELs. These basically limit businesses from
allowing TAPs to be emitted to the outside air around their building. OSHA regulates the same
kinds of exposure limits inside of a building.
Due to the complexities of Air Quality Regulations, the harm air emissions cause to the
environment, and in many cases the high costs associated with "end of the pipe" control
technology, it is in the best interest of any business to evaluate their operations with the ultimate
goal of eliminating all air pollutants as much as possible.
What all this means is, with few exceptions, the Air Quality Regulations that apply to your
business will mostly be determined by what your business does. The best way to find out what
air quality regulations apply to your business is to contact the New Mexico Environment
Department (NMED) Small Business Assistance Program (SBAP) at 1-800-810-7227.
Businesses that are located in Bernalillo County are locally regulated with respect to air
emissions. For assistance you need to call the City of Albuquerque/Bernalillo Air Quality
Assistance Program (AQAP) at 505-768-1964.
HAZARDOUS WASTE REGULATIONS:
Any business that generates waste that is classified as "listed" or "characteristic" in RCRA must
deal with this waste as outlined in the New Mexico Hazardous Waste Regulations. The EPA has
generated a list of chemicals that are considered hazardous. They have also stated that certain
materials that exhibit a hazardous characteristic (ignitibility, corrosivity, reactivity, or toxicity)
should be considered hazardous. To determine which products used in your business contain
hazardous material, contact either the EPA or the New Mexico Hazardous Waste Bureau. In
some cases this information will be contained on the Material Safety Data Sheet (MSDS) that
came with the product.
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.
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All businesses that generate hazardous waste are classified based on the quantities of
hazardous waste they generate monthly. The three classifications are:
1. Conditionally Exempt Small Quantity Generator (CESQG): generates less than 220 pounds
or 100 kilograms of hazardous waste per month. A CESQG cannot accumulate more than
2,200 pounds or 1,000 kilograms of their combined hazardous waste at any one time.
Usually this amounts to about one-half of a 55-gallon drum. CESQG's may dispose of their
hazardous waste by mixing it with a solid waste, assuming there are no free liquids in the
waste, and taking it to a permitted municipal solid waste (MSW) landfill. You need to verify
that the MSW landfill will accept the mixed waste.
2. Small Quantity Generator (SQG): generates between 220 pounds and 2,200 pounds or 100
kilograms and 1,000 kilograms of hazardous waste per month. No more than 13,200 pounds
or 6,000 kilograms may be stored on site any longer than 180 days and must be disposed of
at a facility permitted to recycle, treat, store, or dispose of hazardous waste.
3. Large Quantity Generator (LQG): generates more than 2,200 pounds or 1,000 kilograms of
hazardous waste per month. Hazardous waste with no weight limit may be accumulated for
no more than 90 days unless permitted by the State.
Each classification has different record keeping, manifesting, and reporting requirements. Since
a businesses' classification is based on a monthly generation, it is possible to move from one
classification to another on a regular basis. All generators of hazardous waste are required to
register with the Hazardous Waste Bureau and pay a generator fee based on their classification.
The Hazardous Waste Bureau has an established outreach program that can assist any
business in determining their classification and the regulatory requirements that go with it. You
may contact the Bureau at 505-827-1511.
It is important for any business generating hazardous waste to understand that RCRA has
established a "cradle to grave" responsibility for the generator of said waste. In effect this means
that if the hazardous waste the business generates contaminates soil, surface water, or ground
water in any manner until it is properly disposed of, the business will be held responsible for the
clean up of the contamination. The cost of clean up could be substantial. It is therefore
imperative for any business to 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.
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WASTEWATER REGULATIONS:
Any business that generates wastewater that contaminates surface water or ground water can
be held responsible for the cost of cleanup. If the contaminant is a RCRA "listed" or
"characteristic" waste above the concentration value allowed, then the wastewater is by
definition a hazardous waste and must be dealt with under New Mexico Hazardous Waste
Regulations. Placing hazardous wastewater directly onto or into the ground is strictly prohibited.
Since the cost of cleaning up either surface water or ground water can be substantial, it is in the
best interest of any business to eliminate, minimize, and/or control its wastewater.
If non-hazardous wastewater is being discharged so that it can move directly or indirectly into
ground water (e.g. septic system, dry sump, etc.) a business is required to file a "Notice of Intent
to Discharge" with the New Mexico Ground Water Bureau in accordance with the NM Water
Quality Act. The Bureau will then determine if the business requires a Discharge Permit. In
some cases the business may be required to request a NPDES Permit from the EPA if the
discharge is to surface water.
If non-hazardous wastewater is being place into a sewerage system a business is required to
notify the local Publicly Owned Treatment Works (POTW) the nature and concentrations of the
contaminants in the wastewater. Attached is a listing of the New Mexico Publicly Owned
Treatment Works. Wastewater that has been determined to be hazardous is prohibited from
being placed in any sewerage system.
Business need to be aware that even though their wastewater going into the sewerage systems
is allowed by the POTW, this does not necessarily relieve them of potential contamination
liability. A good example is the case in which a sewer pipe leaks and the wastewater contains
hazardous constituents, below RCRA levels, that were generated by your business. Over time
the wastewater seeps into the ground water and the concentrations exceed State or Federal
water quality standards. If the 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.
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OSHA REGULATIONS:
Every business is required to provide a safe and healthy working environment for its employees.
The Occupational Health and Safety Bureau (OHSB) is responsible for making sure businesses
are in compliance with OSHA regulations. OSHA regulates permissible exposure limits (PEL's)
for employees exposed to certain air contaminants in the workplace. The Bureau conducts
regular inspections of facilities and evaluates the establishment for safety and health
compliance. The OSHB has a consulting program to assist facilities to be in compliance with
OSHA regulations. The service is free of charge to New Mexico small businesses. Attached is a
copy of "Frequently Asked Questions" about the program, a copy of "General Health & Safety
Issues", as well as a poster you are encouraged to display at your facility. They can be
contacted at 505-827-4230.
UNDERGROUND STORAGE TANK REGULATIONS:
Any business that stores a regulated substance in an underground storage tank that is not
directly connected to some sort of processing operation may or may not be regulated by the
Underground Storage Tank Bureau (USTB). If the substance is a hazardous waste, it is
regulated under RCRA and you would need to contact the Hazardous Waste Bureau. Since
there are a variety of circumstances whereby LIST regulations have jurisdiction, it is best to
contact the USTB directly for guidance. They can be contacted at 505-827-0188.
SOLID WASTE REGULATIONS:
The Solid Waste Bureau (SWB) deals primarily with regulating solid waste facilities (non-
hazardous waste landfills, transfer stations, and 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.
SPECIFIC REGULATORY GUIDANCE FOR WOOD FINISHING 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 "Wood
Finishing 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 is a letter from the Environment Department explaining the finalized regulation from
the EPA, which limits emissions of hazardous air pollutants (HAPs) from wood furniture
manufacturing operations. Also attached is a copy of the "Initial Notification Report" as well as a
copy of the "Monthly Recordkeeping Worksheet" and a "Rolling 12 Month Recordkeeping
Worksheet" that will help you in maintaining the necessary records. If you have any questions
you can contact the NMED Small Business Assistance Program at 1-800-810-7227 or the City
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of Albuquerque Air Quality Assistance Program at 505-768-1964 if your business is located in
Bernalillo County.
HAZARDOUS WASTE REGULATIONS:
The most common hazardous waste comes from solvent-based products used in stripping wood
(methylene chloride, xylene, acetone, ethyl acetate, and toluene), coating wood (lacquers,
stains, paints, and thinners), and cleaning spray guns (solvents and thinners). Paint booth filters
may also be hazardous depending on what's in the paint (such as chromium, nickel, or lead).
Other wastes to consider are absorbents used to soak up leaks or spills, shop rags, and aerosol
cans. If you have questions please contact the NMED Hazardous Waste Bureau at 505-827-
1511.
WASTEWATER REGULATIONS:
There is nothing unique in wood finishing shops that isn't already covered in the General
Regulatory
Guidelines.
OSHA REGULATIONS:
Attached to this briefing paper is a document entitled "Woodworking Shops" that can assist you
in being compliant with OSHA.
UNDERGROUND STORAGE TANK REGULATIONS:
There is nothing unique in wood finishing shops that isn't already covered in the General
Regulatory Guidelines.
SOLID WASTE REGULATIONS:
There is nothing unique in wood finishing shops that isn't already covered in the General
Regulatory Guidelines.
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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 Gallaghertginmenv.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. Box 26110
Santa Fe, NM 87502
505-827-1511
FAX: 505-827-1833
E-mail:
debbv brinkerhoff(fl),nmenv.state.nm.us
Occupational Health & Safety Bureau
Debra McElroy
525 Camino de los Marquez, Suite 3
P.O. Box 26110
Santa Fe, NM 87502
505-827-4230
FAX: 505-827-4422
E-mail:
debra mcelroy(@,nmenv.state.nm.us
Ground Water Quality Bureau
Industrial Waste Team Leader
NM Environment Department
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
505-827-2900
FAX: 505-827-2965
Solid Waste Bureau
Phillip Westen
NM Environment Department
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
505-827-0559
FAX: 505-827-2902
E-mail:
Phillip westen(@,nmenv.state.nm.us
Underground Storage Tank Bureau
Joyce Shearer, Ph.D.
NM Environment Department
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
505-476-3779
FAX: 505-827-0310
E-mail:
Joyce shearer(@,nmenv.state.nm.us
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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: jliberatore(@,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
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CONTACT PERSON
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Charles Bowman, WW Utilities
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Fred Seifts
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Frank Analla
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Paul Pizzoli, Utilities Director
Louis Huning, Mayor
Bob Carter
Vida M. Trujillo
Leroy Quintana, Mayor
Bobby Bennett, Mayor
Manuel B. Alcon President
Rosendo Saiz
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Thomas Howell
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Lonnie Graham
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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
F. L. (Roy) Miller
Mathew Meeks
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THOREAU WATER AND SANITATION
TRUTH OR CONSEQUENCES, CITY OF
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VAUGHN, TOWN OF
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(505)862-7136
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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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INITIAL NOTIFICATION REPORT
Applicable Rule: 40 CFR 63, Subpart JJ - National Emission Standards for Wood Furniture
Manufacturing Operations
Notification reports are due to EPA Region 6 by September 3, 1996.
1. Print or type the following information for each plant in which Wood Furniture
Manufacturing Operations are performed:
Owner/Operator/Title
Street Address Quad Phone ( )
City State Zip Code
Plant Name Phone ( )
Plant Contact/Title
Plant Street Address (if different than above)
Quad
City State Zip
Code
2. Briefly describe the wood furniture manufacturing process used at your facility:
3. Estimate of annual use of coatings, adhesives, cleaning, and washoff materials:
.gallons
4. a. If #3 is less than 3000 gallons, then you may be exempt from this regulation.
This form, along with materials usage recordkeeping can serve as the required
documentation of your exemption.
Exempt
b. If #3 is more than 3000 gallons, please indicate (x) your anticipated compliance
approach for meeting the requirements of this regulation:
Compliant Coatings Averaging
Control Device Combination
INITIAL NOTIFICATION REPORT (continued)
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5. Certification by responsible official.
A Responsible Official can be:
The President, Vice-President, Secretary, or Treasurer of the Company that owns the
Plant
* The Owner of the Plant
* The Plant Engineer or Supervisor
A Government Official if the Plant is owned by the Federal, State, City , or County
Government; or
* A ranking military officer if the Plant is located on a military base
I, the undersigned, certify the information contained in this report to be accurate and
true to the best of my knowledge.
(Signature of Responsible Official) (Date)
(Print or Type Name) (Title)
6. Mail this form to:
NMED Air Quality Bureau
Small Business Assistance Program
PO Box 26110
Santa Fe, New Mexico 87502
If you have any questions filling out this form, please contact the Small
Business Assistance Program (SBAP) at 1-800-810-7227.
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State of New Mexico
ENVIRONMENT DEPARTMENT
Harold Runnels Building
1190 St. Francis Drive, P.O. Drawer 26110
Santa Fe, New Mexico 87502-0110
GARY E. JOHNSON MARK E. WEIDLER
Governor Secretary
To: Wood Furniture Manufacturers March 1996
On December 7, 1995, the United States Environmental Protection Agency (USEPA) finalized a
regulation which limits emissions of hazardous air pollutants (HAPs) from wood furniture
manufacturing operations. These HAPs are regulated because they have the potential to cause health
problems. The USEPA estimates that with this regulation Americans will reduce toxic air emissions by
33,000 tons annually. Of the HAPs listed by USEPA; toluene, xylene, methanol, methyl ethyl ketone,
methyl isobutyl ketone and formaldehyde are the most commonly used chemicals in wood surface
coating and gluing operations.
The new regulation:
4 Applies to many new and existing manufacturers of wood furniture or wood furniture
components. See the other side of this page to determine if the regulation applies to your
business.
4 Allows exemptions. Small manufacturers using less than 250 gallons per month or less than
3000 gallons per rolling 12 month period of all of finishing materials, adhesives, cleaning
solvents, and wash-off solvents combined, can be exempted from this regulation, if they can
document their materials usage. In order to begin documenting any exemption, please complete
the enclosed "Initial Notification Report Form" and send it back to the Small Business
Assistance Program (SBAP). We are constructing a list of exempted wood furniture
manufacturers and will be informing the Environment Department Air Quality Bureau
Enforcement Section and the USEPA of your exemption status. Enclosed is a "Monthly
Recordkeeping Worksheet" and a "Rolling 12 Month Recordkeeping Worksheet" that will help
you maintain the necessary records to help your business document any eligible exemptions.
Along with monthly recordkeeping, your business should maintain all purchase receipts of
finishing materials, adhesives and solvents.
4 Requires all wood furniture manufacturers which are not exempt to send an "Initial Notification
Report Form" to EPA Region 6 by September 3, 1996. Additional reporting and work practice
requirements also apply. A copy of the initial notification report form is enclosed. Please send
the form to the SBAP by September 3, 1996 and we will fax it to EPA.
This informational package has been assembled by the SBAP, of the New Mexico Environment
Department Air Quality Bureau, to help businesses comply with this new regulation. The primary
purpose of the SBAP is to assist small businesses which are or will be subject to requirements under the
Clean Air Act or New Mexico Air Quality Regulations. The goal of the SBAP is to help businesses
comply with federal and state air quality regulations through education and technical assistance, not
enforcement. Services are free. Please see the enclosed brochure. If you have any questions or would
like to use our services please contact the SBAP at 1-800-810-7227.
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40 CFR Part 60
Subpart JJ - National Emissions Standards for
Wood Furniture Manufacturing Operations
Who does this new regulation apply to?
This regulation applies to businesses operating under any of the following standard industrial
classification codes.
SIC
2434
2511
2512
2517
2519
2521
2531
2541
2599
5712
Descr/Df/OA7
Wood Kitchen Cabinets Clncludes Vanities. Bathroom & Othert
Wood Household Furniture. Not Uoholstered Clncludes Garden1)
Wood Household Furniture. Uoholstered
Wood TV. Radio. Phono, and Sewina Machine Cabinets
Household Furniture Not Elsewhere Classified Clncludes Willow. Wicker. Reed1)
Wood Office Furniture
Public Buildina and Related Furniture
Wood Office and Store Fixtures. Partitions. Shelvina. and Lockers
Furniture and Fixtures. Not Elsewhere Classified
Furniture Stores Manufacturina Custom Cabinets
II. What is required?
A. The following businesses are required to submit an initial notification report form (enclosed) to
USEPA Region 6 by September 3, 1996 in accordance with 40 CFR § 63.806:
1. Businesses using more than 250 gallons per month, for every month, or more than 3000
gallons per rolling 12 month period of finishing materials, adhesives, cleaning solvents, and
wash-off solvents combined; and
2. Businesses using more than 5 tons of a single HAP or more than 12.5 tons of HAPs combined
per rolling 12 month period.
B. For businesses meeting the criteria in A 1. or A 2., air permitting, reporting, and work practice
standards requirements will also apply.
C. For those businesses that are smaller than those described in A 1. or A 2., records of monthly
material usage must be kept for five years.
Note: You may be able to reduce HAP emissions, while maintaining current production, with the use
of pollution prevention techniques or by using compliant coatings. Such prevention options
may also help your business reduce its materials usage costs. Please contact the Small
Business Assistance Program at 1-800-810-7227 (in Bernallilo County call 505-768-1964) if
you would like to use our services or receive more information.
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November 15, 1995
FACT SHEET
FINAL AIR TOXICS REGULATION FOR WOOD FURNITURE
MANUFACTURING OPERATIONS
TODAY'S ACTION...
The Environmental Protection Agency (EPA) is today issuing a final rule to reduce air
toxics emissions from wood furniture manufacturing operations. Wood furniture
manufacturing facilities, including cabinet shops and residential and industrial furniture
makers, emit air toxics during finishing, gluing, and cleaning operations.
The EPA final rule is the result of successful partnerships among major stakeholders;
the rule was developed largely through a regulatory negotiation with representatives
from the furniture manufacturing industry (including small business), the coatings
industry, environmental groups, and State and local air pollution agencies.
The final regulation demonstrates the EPA commitment to making pollution prevention
an integral part of regulatory actions whenever possible; the control requirements
outlined in the rule are based solely on pollution prevention options instead of end-of-
pipe controls.
WHAT ARE THE HEALTH AND ENVIRONMENTAL BENEFITS?
The EPA final rule will reduce emissions of air toxics, such as toluene, xylene,
methanol, and formaldehyde, by 33,000 tons annually, representing a 60 percent
reduction from current levels. Exposure to these and other air toxics associated with
wood furniture manufacturing can cause adverse health effects, including eye, nose,
throat, and skin irritation; damage to the heart, liver, and kidneys; and reproductive
effects.
BACKGROUND
Under the Clean Air Act (CAA) Amendments of 1990, the EPA is required to regulate
emissions of 189 listed toxic air pollutants. On July 16, 1992, the EPA published a list
of source categories that emit one or more of these air toxics. For listed categories of
"major" sources (those that emit or have the potential to emit 10 tons/year or more of a
listed pollutant, or 25 tons or more of a combination of pollutants), the CAA requires the
EPA to develop standards that will require the application of very stringent controls
known as maximum achievable control technology.
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On July 16, 1992, the EPA published a list of industry
groups (known as "source categories") to be regulated,
which included major sources of wood furniture
manufacturing operations.
WHO WILL BE AFFECTED BY THE FINAL REGULATION?
The EPA final rule applies to about 750 wood furniture
manufacturing facilities nationwide.
WHAT ARE THE MAIN COMPONENTS OF THE EPA FINAL RULE?
The EPA final rule is based on two requirements—emissions
limits and work practice standards. The final rule
provides flexibility to industry by offering a choice of
four different compliance options.
The final rule limits the amount of hazardous air
pollutants (HAP) that can be contained in the coatings used
for finishing, gluing, and cleaning operations. The
emissions limits can be met through using a variety of
coatings that contain lower quantities of HAP.
The work practice standards will reduce waste and
evaporation of HAP. Good housekeeping measures such as
keeping containers of materials closed, periodic training
of operators who use solvent and/or coatings, and
performing periodic inspections to locate and repair
leaking equipment are required by the work practice
provisions. In addition, the rule requires use of spray
equipment which is believed to be more efficient in
applying coatings. The work practice standards also
require accounting for the quantity of solvent used for
cleaning and washoff, the number of times each piece of
equipment is washed off, and the reason for the washoff.
These practices will focus attention on quality control
issues that will result in the minimization of HAP and
volatile organic compound emissions.
The EPA's final rule outlines the monitoring,
recordkeeping, and reporting requirements.
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HOW MUCH WILL THE RULE COST?
The total industry-wide capital investment is estimated to
be $7.0 million. The total nationwide annual cost is
estimated to be about $15 million.
FOR MORE INFORMATION...
Anyone with a computer and a modem can download the
rule from the CAA Amendments bulletin board of the EPA
electronic Technology Transfer Network by calling (919)
541-5742 (look under "Recently Signed Rules"). For
further information about how to access the board, call
(919) 541-5384. For further information about the rule,
contact Paul Almodovar of the EPA Office of Air Quality
Planning and Standards at (919) 541-0283.
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Pollution Prevention in
Wood Finishing: Solvent
Eliminate - Reduce - Reuse - Recycle -
Quality vs.
An
In the wood furniture finishing industry, the largest source of environmental pollution and risk to
workers' health is the evaporation of organic solvents used throughout the finishing process.
Due to the common use of spray techniques with low (~ 25%) transfer efficiency and flash drying
techniques, almost 100% of the toxic solvents used to apply the coating chemicals evaporate into the
surroundings. Furthermore, toxic particles resulting from over-spray and contaminated rags are often
regulated as RCRA waste and must be disposed of properly, which is a costly process.
The quality and market value of a piece of furniture is directly tied to the finished surface and look.
Higher quality pieces must undergo a greater number of coatings and subsequent drying processes in
order to achieve a desired finish. This leads to greater volumes of solvent vapors and over-spray
particles.
It is important to remember when considering the opportunity for pollution prevention, that it is the
finished product that determines the piece's worth, not the procedure used to attain that product. In
evaluating a process change, do not dismiss an idea that has not been used in the past. Pollution
prevention within the wood finishing industry often involves changing the processes. This fact-sheet
is meant to provide a resource on the hazards associated with solvents commonly employed in wood
finishing processes, as well as a guideline for pollution prevention opportunities and technologies
currently employed and available to the industry.
Sol
The top 10 solvents released into the atmosphere during various wood furniture finishing processes,
in order of release volume, are toluene, methanol, xylene, methyl ethyl ketone, acetone, N-butyl
alcohol, 1,1,1-trichloroethane (TCE), and dichloroethane. Most of these chemicals are volatile
organic compounds (VOC's), highly flammable, and pose significant human health risks.
Toluene is an aromatic, petroleum-based solvent that upon environmental release volatilizes in the lower
atmosphere, reacting with other atmospheric components and sunlight to form ground-level ozone, the main
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component of smog and other air pollutants. Human inhalation or ingestion of toluene can result in headaches,
weakness, memory loss, and may also affect kidney and liver functions.
Methanol, a highly flammable alcohol, is readily absorbed by human gastrointestinal and respiratory tracts,
where it is converted to formaldehyde and formic acid, making it toxic even in moderate doses. High doses
can damage the central nervous system and cause blindness. Prolonged exposure can cause liver and blood
damage. Environmentally, methanol evaporates into the atmosphere and reacts to form formaldehyde,
contributing to the formation of various air pollutants and rain contamination.
Xylene contributes to ground-level ozone formation and groundwater contamination due to its moderate soil
mobility. The human body rapidly absorbs xylene through skin contact, inhalation or ingestion. High-level,
short-term exposure can cause skin, eye, nose, and throat irritation as well as impaired lung and memory
function and potential changes in the liver and kidneys. Both long-term prolonged exposure and short-term
high-level exposure can cause headaches, dizziness, and loss of muscle coordination.
Methyl Ethyl Ketone (MEK) is a flammable liquid that after even moderate exposure can cause symptoms
ranging from headaches, dizziness, and nausea to numbness in the fingers and nose and eventually
unconsciousness. Repeated moderate to high-level exposure may damage the liver or kidneys. Vapors are
irritating to the nose, skin, and throat, and may cause damage to the eyes. MEK released to the environment
will evaporate into the lower atmosphere where it contributes to the formation of air pollutants.
Acetone is both a volatile and flammable organic compound. In the lower atmosphere it can contribute to
ozone formation. It is also irritating to the eyes, nose, and throat, and in large quantities can cause headaches,
unsteadiness, drowsiness, vomiting, and respiratory depression.
1,1,1-trichloroethane (TCE), which degrades slowly in the lower atmosphere, can return to earth via rain.
Once introduced into groundwater and soil it degrades very slowly, contaminating resources. Repeated
contact with TCE may cause serious skin cracking and infection, as well as eye and respiratory irritation. High
concentrations cause reversible liver and kidney dysfunction, central nervous system and respiratory
depression, stupor, coma, and death. Lower concentration levels produce light-headedness, impaired
coordination, drowsiness, convulsions, and throat irritation.
Pollution Prevention
When examining the opportunities to reduce waste, it is important to identify to needs and
requirements of the target market. For mass-produced, lower-end furniture, such as some office and
home furniture, there are several processes that utilize water-borne or hybrid water-borne coatings,
which greatly reduce solvent vapors, though they make it harder to repair irregularities in the coating.
If it is determined that all coatings are necessary to produce the desired appearance, there are still
many pollution prevention and cost reduction opportunities which are possible.
Operational Improvements:
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Make production planning and scheduling changes. For example, identify blemishes before adding coatings.
"V Reduce the frequency of equipment cleaning to reduce the amount of solvent needed. Stain all products of
one color at a time, or designating a certain spray configuration to a prevalent color. Schedule the
production line so lighter batches are stained before progressively darker colors.
Increased Transfer Efficiency:
Transfer efficiency is the percentage of coating particles that adhere to the furniture surface. In
coating procedures such as brushing, wiping, rolling, and dipping, this efficiency is nearly 100%.
These processes are they are fairly uncommon because they are labor and capital intensive. High-
pressure spraying techniques are more common but less transfer efficient. There are several
technologies available which can increase the transfer efficiency while still affording the ease of the
spray gun system.
"V Use airless and air-assisted airless systems. These nearly double the transfer efficiency.
"V Explore the use of electrostatic spray systems, which spray negatively charged coatings at the positively
charged wood.
"V Try high-volume low pressure spray systems (HVLP), which have higher transfer efficiencies than even
the airless systems and increase the accuracy and speed.
Alternative to the Spray Process:
"V Use ultraviolet (UV) - curable coatings that can be configured to add color or raise grain. However,
only use this for non-flat pieces.
Increasing Exhaust Filtration Capacity:
"V Retrofit a filtration device to existing spray booths in order to increase the capture of solvent vapors.
"V Use a biofiltration system made from organic matter. This system "digests" the organic solvent
vapors and makes them harmless.
"V Reuse or clean paper or plastic filters.
Increase Commitment to Pollution Prevention
"V Develop a policy a post it in a prominent location. Involve employees and hold training sessions.
"V Give employees incentives for good pollution prevention ideas.
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"V Organize a reference manual for staff that explains waste reduction and management procedures.
"V Use inventory control to save money on duplicate purchases and to screen hazardous waste.
"V Reuse and recycle everything you can. Provide clearly labeled bins and implement incentive
programs.
Pollution Prevention can $ave You Money and
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